Memorandum submitted by EDF Energy
1. EDF Energy is one of the UK's largest
energy companies with activities throughout the energy chain.
Our interests include nuclear, renewables, coal and gas-fired
electricity generation, combined heat and power, electricity networks
and energy supply to end users. We have over 5 million electricity
and gas customer accounts in the UK, including both residential
and business users. We welcome the opportunity to respond to the
EAC Inquiry—Adapting to climate change.
EDF ENERGY—KEY
POINTS— EDF Energy supports
the Governments actions to mitigate Climate Change, and also recognises
the need for adaptation measures as our understanding of the unavoidable
impacts of climate change becomes more certain.— The Power
Sector already carries out significant reporting under current
regulations and provides significant information on the sector
under the Government's established reporting regimes. There needs
to be compelling arguments to justify the provision of additional
information.
— EDF Energy believes it would be more
appropriate to review the adaptation strategy for electricity
supply at a sectoral level rather than targeting individual operators.
EDF ENERGY INPUT
TO THE
EAC INQUIRY ON
CLIMATE CHANGE
ADAPTATION
Background
2. We are pleased to see Government taking
an active role in adapting to climate change. We present here
some views on Climate Change Adaptation as they appear to an operator
of large infrastructure assets and networks within the UK.
On Adaptation Reporting
3. The power sector already undertakes significant
reporting under current regulations and provides significant information
on the sector under the Government's established reporting regimes.
This includes being Category 2 responders under the Civil Contingencies
Act 2004, membership of the Energy Emergency Executive Committee
(E3C) and the Critical Infrastructure Resilience Programme (CIRP).
There needs to be compelling arguments to justify the provision
of additional information.
4. Climate change adaptation is a much broader
issue than mitigation and affects a much wider and more diverse
stakeholder group. This of course necessitates the involvement
of a number of Government departments in order to best represent
the interests of these stakeholder groups. While gathering views
from all groups is important, it should be recognised that some
organisations will be engaged in a variety of forums and care
should be taken to avoid duplication of reporting efforts.
5. Industry regularly provides information to
a wide range of Government departments on climate change related
issues and environmental issues. A cohesive approach is required
from these departments to ensure that this information is collated
and used in the best possible way.
6. We believe it would be more appropriate
to review the adaptation strategy for electricity supply at a
sectoral level rather than targeting individual operators, given
the national strategic importance of electricity infrastructure.
This would also make best use of existing reporting arrangements
and avoid an unnecessary additional administrative burden on operators.
7. In the case of the UK power sector the
Government needs to recognise that the vast majority of current
power station assets will no longer be operational in 25 years
time. In this context Government should consider placing any site
specific adaptation reporting requirements on new installations
and then only through the Environmental Impact Assessment and
Planning processes.
8. Should Government wish to include the
power sector within the Adaptation Reporting power initiative
then we believe the following key points should be considered:
— EDF Energy already carries out a wide
range of activities in relation to climate change;
— it is necessary for Government to define
a clear objective of the reporting power, one that genuinely adds
value to the reporting needs in respect of climate change issues;
— EDF Energy supports a phased approach
to the introduction of the adaptation reporting power with major
new infrastructure reporting first;
— EDF Energy believes that any reporting
should be on a sectoral basis in the first instance;
— any reporting carried out should reflect
the level of detail that can be provided on the impacts of climate
change, and at this stage we believe that this should be relatively
"light touch";
— we believe that the reporting authorities
will need a harmonised approach to reporting for the adaptation
reports to be of benefit to Government. We believe that the Guidance
needs to be reviewed to reflect this; and
— Government needs to manage expectations
around what can be delivered as experience with climate change
mitigation shows that it takes time for requisite skills development
and capacity building.
On the Adapting to Climate Change Programme
9. EDF Energy agrees with the statements
made in Governments Adapting to Climate Change in England report
and in the Stern report that Government's role in relation to
Climate Change Adaptation should be one of facilitation. This
should involve ensuring that adequate resources and information
are available to organisations to allow them to make informed
decisions regarding the protection of their assets.
10. We do not believe that it is appropriate
for each Devolved Administration to be producing a separate Adaptation
programme. As an organisation operating assets within different
administrations we are concerned about contradictory regulation.
This is an area in which common approaches to reporting and adaptation
need to be developed.
11. We agree with the Government's observation
within the Adapting to Climate Change Programme that a different
approach will be required for large long-lived new infrastructure.
That is why we propose that any reporting on this infrastructure
is carried out in line with the current planning process.
12. Organisations operating large infrastructure
assets have it in their own interest to protect these assets.
Therefore they should be allowed to proceed with their own activities
to protect the assets with support from Government.
13. EDF Energy has been involved in a number
of initiatives to understand the impact of climate change on our
assets. EDF Energy, along with National Grid and E.On UK, worked
with the Met Office in 2006 to produce a scoping study on the
impacts of climate change on the UK electricity industry and,
as a part of a broader group of participants, has also commissioned
a further study, "Impact of Climate Change on the UK Energy
Industry", to develop practical responses to Climate Change.
14. Additionally our subsidiary that operates
our nuclear plant in the UK, British Energy, completed a series
of studies in order to inform ourselves and our stakeholders on
the impacts of climate change on our coastally located nuclear
power stations.
(a) A report from the Met Office summarises the
kinds of effects that may be expected at each of our power station
sites (temperature, precipitation, wind and coastal factors).[22]
(b) Two reports for the public that outline the
potential impacts of climate change that British Energy faces
at our sites[23]
and a note to inform the public of impacts of climate change on
replacement nuclear build.[24]
These reports provide confirmation that we are currently operating
our plants in the safest possible manner.
15. We also support the Government's observations
on the development of skills and resources to deal with Climate
Change Adaptation. As noted earlier the development of these skills
across the economy will take some time and Government needs to
manage these expectations.
5 October 2009
22 http://www.british-energy.com/pagetemplate.php?pid=354 Back
23
http://www.british-energy.com/documents/Climate_Change_and_replacement_nuclear_build.pdf Back
24
http://www.british-energy.com/documents/Climate_Change_and_replacement_nuclear_build.pdf Back
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