Memorandum by the John Muir Trust
WHY JOHN
MUIR TRUST
IS GIVING
EVIDENCE
1. The John Muir Trust is a Scottish based,
UK charity whose aim is to conserve and protect wild places with
their indigenous animals, plants and soils for the benefit of
present and future generations, and to increase awareness and
understanding of the value of such places. The John Muir Trust
is concerned about the effects of climate change and the implications
of global warming for people, the environment and wild land. The
John Muir Trust supports calls for a strong UK Climate Change
Bill, incorporating targets of 80% greenhouse gas (GHG) reductions
by 2050—using the IPCC conclusions in its 2007 reports that,
in a global context, 50% cut in emissions from a 1990 baseline
by 2050 and, for industrialised countries like the UK at least
80% cut by 2050, are required to try and prevent average global
warming exceeding 2°C.
2. These reductions should be achieved by
a combination of measures—including increasing the proportion
of energy produced by a broad range of renewable energy sources,
but also, crucially and as the preferred choice, by reducing energy
consumption. Within that context, renewable developments need
to take place with due respect to the local and national importance
of one of the UK's key assets—its natural heritage. Our
natural heritage is increasingly recognised as being of major
economic importance, as well as of social and environmental benefit.
The John Muir Trust has been represented as an objector at the
Beauly Denny 400kV transmission line Public Local Inquiry and
at the Muaitheabhal wind development application Public Local
Inquiry. The latter application, concerning a site in South Lewis,
is the first major proposed wind development in a National Scenic
Area to come forward.
3. It is within that context that the Trust
makes this submission. The John Muir Trust welcomes the House
of Lords inquiry into the economics of renewable energy as an
opportunity for the strategic issues involved in energy and climate
change decision making, and the success so far, to be considered.
Lessons learned can then be used to achieve the Government's key
aims.
KEY GOVERNMENT
AIMS
4. The following key aims of the UK Government
should be borne in mind at all times when making decisions on
energy issues, if a sustainable and holistic approach is to be
achieved.
5. The Government's top priority in this
context is to limit greenhouse gases as much as possible, to make
the UK's contribution to global efforts to minimise global warming.
6. The Requirements of the Electricity Act
1989 section 3A (as amended), need to be met. "The Regulator
must carry out the ... functions in the manner which he or it
considers is best calculated:
(i) to secure that all reasonable demands
for electricity are met;
(ii) to promote efficiency and economy on
the part of the Applicants;
(iii) to contribute to the achievement of
sustainable development; and
(iv) to pay adequate regard to its effect
on the environment".
7. So it is welcome and essential that the
inquiry is not limiting itself to considering renewable energy
generation in isolation but is also looking at how renewable energy
fits into Britain's overall energy generation and transmission
policy. The inquiry aims to set out the costs and benefits of
renewable energy and establish how they compare with other sources
of energy. However, the most efficient energy is that which is
not used—energy which would have had to be produced but
was saved because of energy conservation or efficiency measures.
ENERGY CONSERVATION
AND EFFICIENCY
8. It is well recognised that energy conservation
measures in business and homes could have a very significant effect
on demand, whilst addressing fuel poverty—increasingly a
major issue. The Scottish Parliament in its 2005 Report into Climate
Change found that "approximately 40% of energy could be saved,
and half of the 60% CO2 reduction target for 2050 could be achieved
cost-effectively by improved energy efficiency. Energy efficiency
measures have struggled to gain a high priority for individuals
and businesses. A range of radical additional policy instruments
is required.
The Executive's planned Scottish energy efficiency
strategy should include targets for:
— different sectors at individual,
public sector and business level;
— the development of small-scale renewable
energy projects; and
— an overall reduction in demand for
energy, as rising demand threatens to undermine all other measures.
Large reductions in Scottish emissions require
change towards lower-emission methods of electricity generation.
The Executive must work urgently with the UK Government to produce
an energy strategy that provides a clear vision of the energy
generation mix required to meet emissions reduction targets, and
a clear route map towards achieving that mix".
9. Unfortunately, three years on, the urgency
of the situation has not led, in either Scotland or the UK, to
speedy implementation of major programmes for energy conservation
or to "joined-up thinking" throughout the UK governments
and, within those governments, across departments to produce that
much-needed energy strategy. It seems inexplicable, given the
relative costs of energy conservation versus any kind of electricity
generation, that the focus is not squarely on conservation. So
it is vital that this inquiry focuses on what is the maximum that
can be achieved, throughout the UK, towards the key aims set out
above, and how to make it happen. Decision-making should not be
focused on exceeding secondary targets (renewable energy) if there
are better, more cost-effective, less environmentally-damaging
options to achieve the primary aims of reduced GHG emissions and
also ensuring an adequate energy supply (easier to achieve if
consumption is reduced).
ENERGY HIERARCHY
MODEL
10. UK governments and local authorities
should be using an "energy hierarchy" model, see below,
whereby every decision, in whatever department, is considered
against the model to see which option is the most sustainable
in order to rationalise the policy approach. The hierarchy sets
out different options for delivering carbon reduction, with those
at the top having least risk of adverse social and environmental
impact. All elements of the hierarchy must be pursued but capacity
should be taken up in the top elements to prevent environmental
conflicts when setting targets for those elements lower down the
hierarchy.
Table 1
ENERGY MEASURE
| Conservation and avoidance energy management systems to control lighting, heating etc
|
Energy efficiency (including insulation, efficient building design, energy efficient appliances)
|
Micro-renewables and micro-CHP Household/development scale incl CHP boilers, rooftop turbines, heatpumps, pv, solar thermal etc
Heat
Electricity
|
Macro-renewables, Community scale wind, biomass, hydro etc
Heat
Electricity
|
Macro renewables and Carbon Capture & Storage, Commercial scale
wind, wave, tidal, biomass—avoiding areas of environmental sensitivity
Distributed Generation
Grid based Generation
|
Non-renewable generation
CHP
Electricity generation only
|
11. Comparative costs, which are indicative only,
using Energy Saving Trust statistics for conservation measures,
are of the order below:
| (i) | Cavity Wall Insulation
| £8.64/MWh |
| (ii) | Loft Insulation 0-270mm
| £7.07/MWh |
| (iii) | Loft Insulation 50-270mm
| £25.92/MWh |
| (iv) | Draught Proofing |
£15.55/MWh |
12. Compared with the costs for new power stations, using
government source statistics,
| (i) | Nuclear | £38/MWh
|
| (ii) | Coal (including carbon cost)
| £44/MWh |
| (iii) | Gas (including carbon cost)
| £44/MWh |
| (iv) | Onshore wind | £55/MWh
|
| (v) | Offshore wind | £84/MWh
|
13. A key problem, when considering the relative costs
of any kind of energy provision and what we might call "climate
change" costs, is the fact that most additional costs associated
with renewable energy production and increased transmission costs
are met by the consumer ultimately, whilst provision to encourage
energy conservation measures generally comes from taxation. In
essence, the government pays out to increase energy conservation
measures, through grants, whilst the consumer pays for the Renewable
Obligation Certificate Scheme (ROCs) and for increased transmission
costs through electricity charging.
14. Add to this the fact that these activities often
involve different UK governments and it is easy to see why, so
far, there seems to be no move to look at what the returns are,
in each case, for the various "subsidised" initiatives—far
less any attempt to rationalise the overall approach to gain the
most per pound spent. Consideration should include gains in both
GHG reductions and energy equivalent—either by production
or saving measures. In terms of real problems and real solutions,
it should not matter whether that pound is from the consumer directly
or from the government, from taxes. But in political acceptability,
it matters a great deal.
PROPOSED MODEL
FOR INCREASING
CONSERVATION MEASURES
15. As it is desirable to shift emphasis from energy
production to conservation, one way which might be politically
achievable would be for energy conservation measures to be installed
at no immediate cost to the householder/business who would continue
to pay the same amount for their energy per year, as if there
was no energy saving—with the surplus paid paying off the
costs of the installation. Once this "debt to the government"
had been paid off, the householder would then pay the true cost
of his/her current energy consumption and gain from the savings.
Whilst possibly cumbersome in administration, such a scheme could
get round the political difficulty of moving away from the current
system of consumers picking up the costs of ROCs and increased
transmission costs, towards conservation measures.
RENEWABLE ENERGY
COSTS—ECONOMIC
AND ENVIRONMENTAL
16. There are very major problems with a market which
is called a competitive market but which is heavily subsidised
in a number of ways which skew decision-making. The Renewable
Obligation encourages speculative applications for very large
onshore wind power developments in sensitive, remote, environmental
areas for the following reasons.
17. There is no national energy generation and transmission
strategy, for the UK or for devolved nations. So there is no presumption
of "good" or "bad" sites. It is a free-for-all,
with the early bird catching the bigger percentage of ROCs subsidy.
The planning system in Scotland (the John Muir Trust has not had
the capacity to engage with the other UK countries' planning system)
cannot prioritise when considering an application. Each must be
considered in isolation.
18. There is no requirement that the proposed power development
might, at some time in the future, become economic as the subsidies
are the main reason the scheme is proposed. The original rationale
for ROCs was to kickstart the renewable sector, not as a permanent
prop.
19. There is no requirement for all aspects of a development
to be considered in relation to assessment of carbon emissions
from that development. Whilst Environmental Statements for developments
might refer to "payback time", these generally only
consider the carbon emissions associated with construction of
turbines. There are major concerns regarding sites on peatland,
over the release of carbon from the peat. Peat bogs in the UK,
the majority of which are in Scotland, store the equivalent of
Britain's output of carbon dioxide for the next 21 years. There
is great uncertainty about how much carbon might be released from
wind developments on peat sites. This needs further work, urgently,
and a moratorium on building on deep peat until sufficient understanding
allows rational choices.
20. Transmission costs are not picked up by the developer
but by consumers throughout the UK, who are paying most of the
additional transmission costs. There is, therefore, a perverse
incentive to go to cheap sites, far from the market for electricity.
This is a completely separate incentive from the much-quoted argument
about wind speeds. In fact, with regard to the perceived advantage
of the increased wind speed in the Western Isles, Professor Andrew
Bain, who has submitted evidence to this inquiry, has calculated
that the increased wind speeds in the Western Isles do not offset
the increased transmission costs of installing a Western Isles
interconnector and taking electricity to the market in either
central Scotland or into England, for instance. However, it is
not in the developer's interest to assess this. Less obviously,
it is not in the interests of either the transmission company
(who will make a good guaranteed return from consumers and increase
their asset holding) or the interests of National Grid to do a
true cost/benefit analysis.
OFGEM
21. It is Ofgem's duty to consider "efficiency and
economy" and "sustainable development" but Ofgem
is under considerable pressure to facilitate the perceived need
for large amounts of increased transmission capacity. Ofgem have
said, in regard to the proposed Beauly-Denny 400kV interconnector,
that it is not their job to assess all alternatives when a proposal
is brought forward. This is an area which needs looked at. The
John Muir Trust would suggest that undertaking such broad balancing
duties is properly a government responsibility and that it should
be done by developing a national energy strategy. In the meantime,
however, Ofgem must take a broader view of its remit than it has
with regard to the Beauly-Denny application, for instance.
DECENTRALISED GRID
22. The current rush for large-scale onshore wind developments,
connected by a hugely centralised grid system shows a poverty
of imagination and thinking rooted in the early 20th Century.
There is a huge risk of stranded assets if there is not a strategic
rethink about how energy is produced, saved and distributed. Others
have given evidence to this inquiry about the inappropriateness
of the current grid models and security standards being used,
when considering wind generated supply. Intermittent supply cannot
be treated in the same way as firm supply. One way in which wind
power production can be better used is when it is used on a community
scale, as part of a mix of power sources and, looking towards
the future, using hydrogen storage which requires more Research
and Development.
CONCLUSION
23. The John Muir Trust believes it is the government's
duty to consider all aspects of energy production and conservation
carefully, to consult widely and produce a National Energy Strategy
to achieve a sustainable, effective energy system and maximise
the greenhouse gas emissions reductions. If attention continues
to be focused on increasing renewable energy targets, without
any requirement for the developments brought forward to have to
demonstrate their ability to actually bring about greenhouse gas
emissions reductions, we face a possible worst case scenario.
This would be where we achieve renewable energy targets through
inappropriate developments, at great cost to important environments,
only to discover that our greenhouse gas emissions are up, along
with our energy consumption, and our energy supply is not secure.
Energy conservation measures must be prioritised immediately.
They can bring about the most effective results, most quickly
with most environmental gain. They will also have most social
benefit, with regard to jobs and fuel poverty. It is only lack
of political will, possibly due to extensive industry lobbying,
which prevents this happening.
Helen McDade
Head of Policy, John Muir Trust
13 June 2008
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