Memorandum by Professor Michael Jefferson
1. I assume that the Select Committee is
well aware that the UK ranks 25th out of the 27 EU Member Countries
in terms of the share of renewable energy resources in the final
use of energy. I further assume that the Select Committee is sceptical
about the realism of the15% target for this share by 2020 allocated
to the UK. Having spent some 35 years directly involved in the
energy industry; taken an interest in renewable energy for some
30 years; taken an interest in climate and climate change for
over 50 years; and taken a close professional interest in renewable
energy and global climatic change for 20 years (including 17 years
direct involvement with the Intergovernmental Panel on Climate
Change) it might be thought that I would applaud the UK's endeavours
to expand renewable energy provision and tackle greenhouse gas
emissions. Such are the weaknesses of policies and measures, however,
that despite the UK's relative strengths in terms of wind and
wave resources and the efficiency of its agricultural industry,
no such plaudits are merited.
2. The UK's Renewables Obligation (RO) scheme
overly rewards investors, places excessive costs on energy users
(particularly domestic and business electricity users), supports
mature technologies but does little for less mature technologies,
and costs an excessive amount in carbon emissions avoidance (£400
per tonne carbon, on a grid average basis according to Ofgem).
These are criticisms made by the government's own agencies in
this field—Ofgem, The Carbon Trust and the National Audit
Office, among others. Instead of radical change, the government
has recently fiddled about with minor changes in banding. It is
widely agreed that the Feed-in Tariff system (as applied in Germany,
for example) would be more efficient than the RO scheme (although,
simply by considering the low wind energy load factors this system
has fostered in Germany, and the sub-optimal support of solar
PV in a country with low solar insolation, it is clear even this
system is not above criticism). Recent research has concluded
that UK wind energy projects receive 40% more in subsidy (from
electricity consumers) than they would under a German-style REFIT
Feed-in-Tariff system. Despite the recent government review of
the RO system, and its minor tinkering, a major overhaul is required.
3. Given the UK's relatively strong wind
resource, it might be thought that the UK wind energy sector would
be performing strongly. It is not (little more than 10% of Germany's
contribution). The UK wind energy industry is keen to point the
finger of blame at issues and others which do not bear close examination.
First, planning difficulties are blamed, yet peer-reviewed literature
indicates that planning delays are no more serious than they are
in Germany, Denmark, or Spain. Secondly, key members of the industry
[especially the Chief Executive of the British Wind Industry Association
(BWEA), and some of her senior colleagues and associates] consider
that load factors are irrelevant. The Chief Executive of the BWEA,
when responding to quotations of load factors from Ofgem data,
has said: "These claims about low load factors are absolute
nonsense, load factors are irrelevant ... a stream of factual
inaccuracies, bogus pseudo-science ... we can refute them all
with valid evidence." [see: http://www.bwea.com/media/news/070830.html]
Dr. Donald Swift-Hook, an ex-Chairman of the BWEA and Chairman
of the Wind Energy section of the World Renewable Energy Network/Congresses
has stated more than once (on the basis that there is insufficient
wind in what he termed "the Milton Keynes area") that
to place wind turbines there "is crazy". Nevertheless,
on another occasion he has remarked of quotation of Ofgem data
on wind turbine load factors that such "claims" are
"stupid" and "akin to imposing a Communist-style
command economy." [The Scotsman, 31 August 2007,as
reported by Ian Johnston.]
4. The Companion Guide to PPS22 states (using
the term capacity factor, which is inter-changeable with the term
load factor): "Capacity factors in the UK may generally fall
anywhere between 0.2 and 0.5, with 0.3 being typical in the UK."
[para. 34, p.165] Not surprisingly, some may consider, there is
a resonance with the following statement by the BWEA: "At
very good sites the capacity factor can be over 40%. At other
sites the capacity factor may be under 30%." [http://www.bwea.com/ukwed/operational.asp]
And for many years the BWEA has encouraged developers and any
other interested parties to assume a 30% load factor in their
calculations. One pities the BWEA's Director of Communications,
when confronted with the realities, stated that a 30% load factor
is "an arbitrary and inaccurate threshold." [Charles
Anglin in a complaint to the BBC, 22 November 2007] What are the
facts? According to Ofgem data for 2007, of the 81 onshore wind
energy developments which were operating in England throughout
the twelve months only 13.6% achieved a load factor of 30% or
over. In other words, 86.4% had load factors below 30%, and the
weighted average load factor was 24.42%. There were 49 (60.5%
of the total) wind energy developments achieving a load factor
of under 25%, and 23 (28.4% of the total) achieving under 20%.
No offshore developments in England achieved over 28%. A detailed
Note of this situation, due for publication, is attached. In Scotland
the situation was better: one-third of developments achieved a
load factor of 30% or more. In Wales under 20% did so (excluding
North Hoyle), and in Northern Ireland 26%.
5. The implications of this situation are
stark. In England over £26 million, out of a total of ROC
payments/consumers' subsidies of just over £34 million in
2007, went on wind energy developments achieving load factors
below 30%; and nearly £16 million on those achieving below
20%. If policy and planning rules required wind energy developments
only to take place in high average wind speed areas then this
problem could be largely avoided (say, speeds over 8 metres per
second—m/s—at a hub height of 80 metres above ground
level, bearing in mind that an OXERA research report commissioned
by the former DTI concluded that at average wind speeds below
8.5 m/s permanent subsidies would be required). Largely avoided,
it should be stated, because even in high average wind speed areas
turbines can be sub-optimally placed. One needs only to consider
the experience in Cumbria of two developments a mere 2.3 kms.
apart—Lowca, which achieved load factors of over 30% in
each year from 2003 to 2006; and Siddick, which has never achieved
27%. The Chairman of the Board of Nuon (2002-2008), Ludo van Halderen,
has said: "Wind energy should be developed where it makes
sense instead of seeing wind farms receiving substantial subsidies
in countries where they run for barely a fifth of the year (a
load factor of 23%)." ["Responding to Climate Change":www.rtcc.org/2008/html].
6. Among the results of this misallocation
of resources are:
— turbines are being placed where they
do not maximise electricity generation from renewable energy,
nor houses supplied from renewable energy, nor carbon emissions
avoided—contrary to government policy objectives;
— turbines placed in areas of relatively
low average wind speeds divert supplies of turbines, rotor blades
and ancillary equipment from sites where the average wind speed
is higher, electricity generation would be greater, and carbon
emissions avoidance would be higher. This is a major reason why
supply chain difficulties have mounted for the wind energy industry,
nationally and internationally, lengthening delays and pushing
up costs (as more than one BWEA report from BVG Associates has
discussed, and among the reasons for Shell's withdrawal from the
London Array).
— Turbines are being proposed, and
in some cases placed, over large areas of what loosely may be
described as "Central England" where average wind speeds
are relatively low, yet landscapes and historic assets (and sometimes
SSI's and officially designated AONB and AOGLV areas) are jeopardised.
Zones of Visual Influence and Cumulative Zones of Visual Influence
are casually handled by the planning authorities in too many instances,
and the would-be developers typically engage in distortion of
facts and evidence. The result is great social discontent with
decisions which too often run counter to the public interest,
largely because a "gravy train" exists for developers.
The general public, for the most part, simply do not realise that
through their subsidies as electricity consumers they are funding
individual turbines to the extent of over £174,000 per year
where the load factor is about 22%, to over £237,000 per
year where the load factor is 30%. It is a matter for separate
debate whether any subsidy should be paid where load factors achieved
are below, say, 25% (and some reduction from the maximum available
where less than, say, 30% is achieved); and whether current subsidy
levels are optimal even where load factors in excess of 30% are
achieved.
— Some regional planning authorities,
and others, in their spatial plans have assumed that wind energy
developments should not be placed where average wind speeds are
below 7 m/s. Although this is not an irrational criterion, it
is in fact a contravention of PPS22 Key Principle 1(v):
"Regional planning bodies and
local planning authorities should not make assumptions about the
technical and commercial feasibility of renewable energy projects
(e.g identifying generalised locations for development based on
mean wind speeds). Technological change can mean that sites currently
excluded as locations for particular types of renewable energy
development may in future be suitable."
There are good reasons for seeking the
earliest withdrawal of this "Key Principle", in order
to relieve planning authorities of undesirable costs and other
burdens; provide greater certainty to would-be developers; permit
closer focus on wind energy proposals on sites where average wind
speeds are relatively high; protect large swathes of the countryside,
where average wind speeds are relatively low, from severe and
avoidable threats; and reinforce the statement in the Companion
Guide to PPS22:
"The planning system exists to
regulate the development and use of land in the public interest.
The material question is whether the proposal would have a detrimental
effect on the locality generally and on amenities that ought,
in the public interest, to be protected." [para.39, p.167]
Care should be taken, however, to ensure
that all known and likely planning applications relevant, or likely
to be relevant, to cumulative visual influence are taken fully
into account from the outset.
— It is widely assumed that, because
the UK has a relatively good wind resource, this is generally
true. The preceding discussion has indicated this is not the case.
One can go further. It has been claimed that the chances of low
wind speeds insufficient to turn wind turbines in the UK occurring
in the UK are "around one hour in every five years."
[Graham Sinden] In that case, one wonders, how was it that for
hours over eleven days (arguably twelve) in October, 2007, there
was insufficient wind recorded at around 90% or more of the 64
Met Office sites?
— Other examples of distortion, exaggeration
or duplicity concerning the UK wind energy industry could be cited.
Claims for electricity generation, households which would be supplied,
and carbon emissions avoided by proposed and operating wind energy
schemes abound. Despite repeated UK Advertising Standards Authority
adjudications against wind energy developers claiming that their
schemes would avoid emissions based on 860 grammes CO2 per kWh
(coal displacement), this comparison is still seen in planning
applicants' documents (even the BWEA seemed to retreat from this
point on 15 October 2007). This sort of conduct undermines public
support for renewable energy and action to curb anthropogenic
greenhouse gas emissions.
7. The recommended conclusion to be drawn
from the above is that a major and critical review is required
of UK onshore wind energy operations, aimed at ensuring for the
future that developments only take place in acknowledged relatively
high average wind speed locations, and where even in these there
is high confidence turbines are optimally placed. The electricity
consumers' subsidy system should be urgently reviewed as it is
excessively costly for consumers and over-rewards investors (who
may have no other links to the UK, operate from tax havens, and
have no history of involvement in the renewable energy sector).
Load factors are an important consideration, as is agreement on
realistic household electricity use (many households comprising
the elderly, those who work from home, or have large families
are not adequately reflected in the official statistical average);
and on grammes CO2 per kWh to be assumed (various government departments
back 430 grammes or 480 grammes, while the Advertising Standards
Authority has backed the former in the past).
8. Among other considerations required
of such a review is that onshore wind, inparticular, is a mature
technology. There are other technologies which arguably are deserving
of much greater support: second and third generation biofuels;
offshore wave; and Concentrating Solar Power (CSP). Offshore wind,
because of the additional challenges of installation and maintenance
(though noting earlier comments on supply chain challenges which
will gravely hamper the government's ambitions in this field for
7,000 offshore turbines by 2020), may also deserve greater incentive
than the modest band advantage they have been offered over onshore
wind. However, greater caution is required in the technical assessment
of all renewable energy technologies (and advanced nuclear, and
carbon sequestration, technologies) than appears to have been
the case in recent years—nationally and internationally.
The importance of using biomass wastes rather than their foodstuffs
component should be obvious, and points in the direction of second
(and eventually third) generation biomass and biofuels. However,
serious questions are asked about the efficiency of producing
ethanol from biomass, and results in claims that this cannot be
done efficiently because cellulose is highly resistant to biochemical
attack. The proposed EU Directive on the promotion of the use
of energy from renewable resources [COM(2008) 19 final of January
23, 2008] paid brief lip service to second generation bio- technology;
seemed nave in its discussion of the use of first-generation biofuel
technology and the ability to prevent tropical forest destruction;
appeared unaware of the proportion of anthropogenic global carbon
emissions arising from tropical forest destruction (about 18%
of the annual total); and failed to mention, as did its commissioned
background report, that without substantial imports of feedstocks
no less than 27% of the EU's current arable land would be required
to grow biofuel crops to meet its 10% target by 2020.
9. Offshore wave has only been pursued by
small entrepreneurial and academic units in the UK to date, despite
the UK's large natural resource. This is unfortunate. By comparison,
the Severn barrage, first put forward in 1849, is being given
excessive promotion. The proposed EU Directive mentioned above
contains, in Article 5 (2) a reference to construction of renewable
energy plants with very long lead-times and having a capacity
of 5 GW or more, started by 2016 and operational by 2020. This
is a reference to the Severn barrage achieved by UK government
negotiators, based upon an assumed total generating capacity in
excess of 8 GW for a barrage running from Cardiff to Weston (an
even larger barrage with a claimed total generating capacity in
excess of 15 GW has been mooted in the past). With annual UK electricity
generating power at around 395,000 GWh, 8 GW capacity suggests
a theoretical output of 70,000 GWh, or 17.7% of that total. Actual
output, as a result of diurnal tidal flows, has variously been
estimated as likely to reduce the contribution to between 4% and
5% at a cost of between £15 billion and £25 billion.
Again, "special interests" abound behind the scene,
especially those of large engineering and construction companies,
currently facing especially tough prospects due to recession.
However, although the Severn barrage offers a contribution to
electricity supplies, it is a huge project well beyond current
UK experience, therefore fraught with great difficulties and the
likelihood of major cost escalation. It will also have severely
adverse environmental impacts (it may be recalled that EdF declared
their La Rance barrage "destroyed the local ecology",
and that tidal barrages once considered for the Minas and Cumberland
basins in the Bay of Fundy have not proceeded due to environmental
concerns). However, relative to most other estuaries along the
English and Welsh coasts, in particular, the Severn is arguably
less important for over-wintering and migratory birds due to its
turbidity. However, a 4% to 5% contribution is really rather modest
in relation to what is required to make a major difference, and
greater efforts to improve energy efficiency and focus directly
on curbing carbon emissions might well provide larger-scale benefits.
10. The large-scale potential of CSP is
clear, and the technology has a history going back a century.
Space does not permit discussion of its potential here. Reference
is made to the writer's: "Win-Win Strategies for Tackling
Oil and Natural Gas Constraints while Expanding Renewable Energy
Use" in Barbir, F. and Ulgiati, S. "Sustainable Energy
Production and Consumption", NATO Science for Peace and Security
Series, Springer, 2008. (Please contact the author for a copy
of this paper.)
11. The perceived costs of pylons and wind
turbines (now generally 125 metres or 410 feet high to blade tip)
for many people in rural areas is so high that they exceed the
perceived costs of fossil fuels and, in many cases, nuclear power
(see public attitudes in the proximity of Sizewell). How such
perceived costs are translated into defensible "external
costs" are beyond the powers of this economist.
12. There are many other issues which should
be discussed here, among them: why is there no rational micro-generation
policy so that, for example, within twelve months of completion
of purchase those who have paid stamp duty (much increased under
the present government) could get up to that amount refunded provided
they had invested in an approved micro-generation scheme. Those
with sufficient land could invest in a ground-sourced heat exchanger,
providing for a huge number of rural dwellers and many suburban
dwellers an efficient means of avoiding fossil fuel use. This
is important in a country with poor solar insolation and highly
variable wind conditions (not least in urban and suburban areas
where small wind turbines stuck on chimney stacks may take 150
years to repay the investment—and only have an expected
life of under 20 years).Why has the European Emissions Trading
Scheme been so costly and ineffectual to date, why has administrative
allocation of emission rights been so prolonged, and who has been
allowed to benefit and why (yet another example of the great gravy
train in motion)? The Inquiry also intends to examine important
issues relating to comparative electricity generation costs, outside
the writer's competence.
14 June 2008
|
