Supplementary memorandum submitted by
WWF-UK
WWF-UK CLARIFICATION
REGARDING QUESTION
47 FROM JOHN
ROBERTSON
WWF wishes to make a clarification on its position
with respect to the answer to Question 47 provided by Green Alliance.
John Robertson addressed the following query to Chris Littlecott:
"So would I be right in thinking that perhaps, unlike
your colleague at the end, you have a more flexible way of looking
at it in that you drive in hard targets to begin with but you
would be more flexible in driving towards, in effect, by the time
we get to 2030 or 2040, hard targets then?" This question
followed previous discussion on whether introducing a tough EPS
could provide a disincentive to investing in CCS technology.
Green Alliance suggested in its response that
when applying the EPS to CCS plants, we could "give them
a percentage of wriggle room" in recognition of the fact
that they will be testing their technology, so that power companies
are not disincentivised from actually building CCS. From WWF's
perspective, introducing a percentage of wriggle room on EPS levels
for CCS plants is not needed in order to incentivise the building
of CCS technology. A fixed plant based EPS that applies to
all types of plant has the advantage of providing clear physical
certainty as to the types of plant than can or cannot get built
and together with the necessary financial incentives, will actually
support the development of CCS technology in a way that ensures
that CCS can help unabated fossil fuel plants meet the EPS set
by the UK government.
In other words, an EPS must not merely be
set at the level of carbon intensity of any new plant implied
by the current Government requirements for CCS demonstration (which
would risk happening if wriggle room was introduced in the way
an EPS applies to CCS plants). An EPS of this kind would act
solely as a mechanism to operationalise the CCS requirement rather
than as a mechanism that drives the decarbonisation of the UK
power sector, which should be the UK's key energy policy objective
in line with the recommendations of the Committee on Climate Change.
The fundamental point here is that the UK needs to avoid building
a large number of new fossil fuel fired electricity plants until
we have proven the technical and economic feasibility of CCS,
to avoid the risk of being left with a long-term legacy of unabated
high carbon emitting plants. This is why WWF has been calling
for CCS demonstration projects to be focussed in the first instance
on existing plants, such as the coal-fired plant at Longannet
and the existing gas-fired plant at Peterhead, and for government
and consumer funding of new electricity supply capacity to be
focussed primarily on supporting the UK's renewable energy sector.
October 2010
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