Memorandum submitted by the Association
for the Conservation of Energy
INTRODUCTION TO
THE VIEWS
OF ACE
The Association for the Conservation of Energy
is a lobbying, campaigning and policy research organisation, and
has worked in the field of energy efficiency since 1981. Our lobbying
and campaigning work represents the interests of our membership:
major manufacturers and distributors of energy saving equipment
in the United Kingdom. Our policy research is funded independently,
and is focused on three key themes: policies and programmes to
encourage increased energy efficiency; the environmental, social
and economic benefits of increased energy efficiency; and organisational
roles in the process of implementing energy efficiency policy.
We welcome the opportunity to submit written evidence
to this inquiry.
1. ACE is concerned that the National Policy
Statements on the whole, and the Draft Overarching National Policy
Statement for Energy (EN-1) in particular, do not sufficiently
investigate the potential for reducing UK electricity demand.
The Department for Energy and Climate Change (DECC) seems to view
energy supply policy as entirely separate from energy demand policy.
Any consideration of future supply requirements has to be founded
upon a detailed assessment of energy demand.
2. ACE sees no evidence that such an assessment
has taken place. The statements on the potential for reducing
energy demand simply claim that any efficiency savings will be
displaced by increased demand from electric heating (presumably
heat pumps), electric vehicles, and an increase in the number
of households. This is not an acceptably rigorous assessment.
3. It is vital that electricity demand reduction
be considered fully because the successful implementation of policies
in this area may negate the need for additional generating capacity.
Government is relying upon technologies that are in most cases
highly controversial, often unproven, and potentially very costly
to meet an "electricity need" that could be reduced
through the implementation of effective demand reduction policies.
How do the costs and benefits of such investment in generation
capacity compare to the costs and benefits of demand reduction?
It appears that Government has ignored the question.
4. In 1981 The House of Commons select
Committee on Energy (Sixth Report to Session 1980-1) posited this
specific criticism of Government policy: Government "still
has no idea whether investing £1,300M in a single nuclear
plant is as cost-effective as spending a similar sum to promote
energy conservation". This report was issued at a time when
Government had just announced its intention to promote a new generation
of nuclear power stations (of which just one was finally built).
It is plainly ludicrous that a generation later Government is
still failing to address this most basic question.
5. Government frequently espouses the virtues
of energy efficiency: it is the cheapest way of reducing carbon
emissions, it improves energy security, it increases the productivity
of our businesses and industry, saves money for householders and
generates economic wealth. Yet, when designing national energy
policy, Government would rather opt for controversial, unproven
and/or costly technologies such as nuclear power or carbon capture
and storage.
6. ACE believes that it is possible to radically
reduce our electricity consumption, whilst allowing for the increasing
penetration of heat pumps and electric vehicles (which would largely
consume electricity during off-peak hours). One scenario sees
electricity demand falling to 282 Twh in the long-term.[1]
Potential demand reduction policies could include:
Fully insulating homes that use traditional
electric heating systems, and replacing these systems with heat
pumps that are between two and four times more efficient.
The rigorous implementation of minimum
efficiency standards on all electrical products.
Consideration of "scrappage schemes"
to accelerate the replacement of inefficient products.
7. In conclusion, energy efficiency must
be given primacy in energy policy in order to reduce costs to
businesses and householders, and to maximise security of supply.
As such, Government must undertake and publish a thorough review
of the potential for reducing the UK's consumption of electricity,
and set these options alongside those for increasing generating
capacity to present the full range of alternatives for meeting
the UK's electricity needs.
January 2010
1 A Renewable Electricity System for the UK: A Response
to the 2006 Energy Review. (2006). UCL http://www.cbes.ucl.ac.uk/projects/energyreview/Bartlett%20Response%20to%20Energy%20Review%20-%20electricity.pdf Back
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