Memorandum submitted by RSPB|
The RSPB welcomes this opportunity to comment on
the Government's proposal for reform of the electricity market.
This response sets out our overall position on EMR and on renewable
energy in particular, and highlights our key concerns and recommendations
for the reform package.
We believe that the overall aim of EMR should be
to decarbonise the electricity sector, reducing average emissions
from generation to 50gCO2/kWh by 2030 as recommended
by the Climate Change Committee. EMR should also:
sustainability as a guiding principle for the reform package and
for energy policy more generally
an ambitious renewable energy target for beyond 2020
a strong Energy Performance Standard that is reduced over time.
2 THE RSPB AND
Climate change is already affecting birds and wildlife
in the UK and globally, and it threatens to drive future biodiversity
loss unless urgent action is taken to reduce emissions and keep
the world within "safe" levels of climate change. One
study published in Nature indicates that climate change
could cause up to 35% of species to be committed to extinction
The RSPB therefore strongly supports the UK's greenhouse gas reduction
targets and recognise the critical role that renewable energy
will play in delivering them as part of a wider package that prioritises
The huge amount of new infrastructure needed to decarbonise
our energy supply can, however, have a detrimental impact on wildlife
in the UK if poorly located and/or designed. The Government has
committed to reversing biodiversity decline by 2020. We believe,
therefore, that Government has a duty to ensure these targets
are met with minimal environmental impact.
The RSPB is unique amongst UK NGOs because we engage
with individual applications for renewable and other energy infrastructure
across the UK, advising developers how they can minimise the impact
of their developments. We will also object to developments when
their environmental impacts are likely to be unacceptable. Since
1990, we have placed sustained objections to only 5.7% of wind
3.1 The overall objective of EMR should be
decarbonising the power sector
There is now general consensus that the power sector
will need to be near-fully decarbonised by 2030 and able to provide
for increases in demand from electrification of transport and
heat. We believe that the overriding aim of EMR should be to deliver
an average emissions intensity of 50gCO2/kWh by 2030
in the most sustainable way and at reasonable cost to the consumer.
This reflects the Climate Change Committee's advice on the fourth
carbon budget and is critical to ensuring the UK remains on target
to delivering its commitment of an overall 80% reduction in emissions
3.2 An ambitious renewable energy target should
be set for 2030
We are concerned that the Redpoint analysis that
underpins DECC's proposals on EMR assumes that renewable energy
will deliver 34% of electricity by 2030 in all scenarios. Meeting
our 2020 target implies 29% of electricity coming from renewable
sources by 2020, so this assumption suggests a significant slow-down
in growth for the renewable energy sector in the period 2020-30.
Indeed, the only significant differences between the scenarios
explored by Redpoint are in the amount of nuclear, CCS and gas
CCGT, as well as net costs.
We therefore recommend that an ambitious target is
set for 2030 that reflects continued growth in renewable energy
throughout the 2020s, and that DECC commission further analysis
to explore what further policy support and market conditions may
be required to deliver greater growth.
3.3 Energy savings should be prioritised
We note the lack of ambition in and attention to
the role of reducing overall energy use in decarbonising the power
sector. EMR should have as an objective delivering a market that
drives much more ambitious energy savings. As part of the EMR
package, we would like to see DECC carry out specific analysis
of different energy saving scenarios for the period up until 2030
and develop further policy interventions to ensure the market
structure facilitates demand management and energy efficiency
4 EMR AND ENVIRONMENTAL
We understand and support this Government's initial
focus on the electricity market given the huge levels of capital
required to decarbonise our energy system. Investment is, however,
only one part of the equation that will deliver the low carbon
energy needed to make development sustainable. Equally important
is a policy and planning framework that minimises the ecological
and environmental impacts of that investment itself, and thereby
facilitates deployment and enhances public acceptance.
We are concerned that DECC and CLG have largely ignored
this to date, and believe that sustainability should be a "guiding
principle" for EMR itself and for energy policy more generally.
This reflects the commitment made by the Conservative party in
Rebuilding Security that sustainability will be a key objective
of conservative energy policy, and the principle of safeguarding
the natural environment enshrined in the Liberal Democrat constitution.
4.1 Spatial guidance for renewables
The current approach to deploying renewable energy,
established under the previous Government, is market-led in terms
of technology choice and locations for new developments. This
has led to conflicts over individual developments that could otherwise
have been avoided. As an example, the Lewis windfarm proposal
was to be sited on an internationally protected area and an intact
peatland - an important carbon store. Inevitably the scheme was
rejected, but only after years of conflict and millions of pounds
wasted in lost investment.
The planning system is not delivering sustainable
renewables at the pace required, and the situation appears to
be worsening. Evidence from Renewable UK suggests that approval
rates at the Local Authority level fell to 53% (by MW) in 2009,
relative to 68% in 2008.
The RSPB in concerned that proposed changes to the planning system,
such as removal of regional targets for renewable energy and the
lack of spatial guidance in the draft energy National Policy Statements,
will only exacerbate this situation.
We believe that Government needs to give more strategic
direction to the industry to facilitate deployment and minimise
the environmental impact of meeting our climate goals. This should
act alongside the planning system, which offers a backstop to
resolve individual cases. Such an approach will also improve public
acceptability by clearly and transparently minimising environmental
Strategic direction can be delivered either through
market rules or as guidance linked to the planning system. To
be delivered through the market, however, would require greater
use of centralised instruments. For example, low carbon contracts
between Government and a developer could include requirements
pertaining to the environmental sensitivity of the site being
developed. We understand, however, that this is not the direction
in which EMR is being taken, and are therefore calling on DECC,
CLG and Defra to develop a system that offers onshore wind developers
spatial guidance on where development would be most environmentally
suitable. Such an approach could then be applied at the Local
Authority or group of Local Authority level, and could be rolled
out to other technologies as required in the future.
4.2 Accounting for sustainability in subsidy
The technology neutral principle in the Renewables
Obligation has also led to undesirable environmental outcomes.
For example, the generous banding of bioliquids has brought forward
proposals for electricity generation based on biofuels made from
palm oil and jatropha. We are also aware of over thirty proposals
for large-scale biomass power plant with a combined capacity of
3.9GW and an annual wood demand of approximately 23 million oven-dried
tonnes. This compares to a total of 9.3 millions tonnes of wood
harvested in the UK in 2010.
We would therefore like to see technology premia in the RO and
any future support schemes banded to reflect sustainability, with
the least sustainable technologies receiving less support and
the most sustainable receiving more.
5 AN EMISSION
We support the proposal for an EPS of 300g CO2/kWh
that is reduced to 100g CO2/kWh by 2025. An EPS at
the level proposed by DECC is inadequate, and the proposed grandfathering
provision sends a message that unabated gas and partially abated
coal will continue to have a role to play into the future, which
is incompatible with our longer-term emission targets.
An EPS that is progressively reduced over time according
to a clear timetable is not simply a backstop. It provides certainty
to the industry by sending a clear signal to developers as to
what kind of plant will be acceptable in the future, directing
investment and innovation. It also prevents the potential lock-in
to unabated gas, to which Government's current proposal risks
leading. Finally, as noted in the ECC Committee's 2010 report
on an EPS, a strong EPS would send an important signal internationally,
positioning the UK as a leader on climate change and encouraging
other countries to follow suit. A weak EPS, as currently proposed,
would have the opposite effect.
6 A COORDINATED
OTHER EU MEMBER
EMR should explicitly seek to deliver a coordinated
offshore grid in the North Sea. Under current market arrangements
every offshore windfarm has its own onshore connection(s). A coordinated
grid that links clusters of offshore windfarms to the onshore
grid would minimise the total number of onshore grid connections
required. This will have less overall environmental impact and
will be cheaper for consumers.
EMR should also seek to deliver greater interconnection
with grids in continental Europe. This was identified in a major
study by the European Climate Foundation
as key to decarbonising the European power sector, as it allows
the integration and balancing of geographically dispersed renewable
energy resources. By enabling international trade in electricity
this should reduce costs to consumers and improve energy security.
Furthermore, it reduces the overall capacity of renewables required
to meet targets across Europe, and, by consequence, the environmental
61 Thomas et al. (2004) Extinction risk from climate
change Nature 427 pp.145-148 Back
Renewables UK (2010) State of the Industry report Back
Forestry Commission (2011) UK wood production and trade Back
ECF (2010) Roadmap 2050 - a practical guide to a prosperous
low carbon Europe Back