Emissions Performance Standards - Energy and Climate Change Contents

Supplementary memorandum submitted by WWF-UK


  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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