SC(3) CR-E5

Sustainability Committee

Inquiry into Carbon Reduction in Wales: Electricity Generation (including renewable energy)

Response From Friends of the Earth Cymru

Background

Almost weekly, we hear of fresh scientific evidence warning that the impacts of man-made climate change are occurring sooner and are more intense than many predicted.

On March 14th, for instance, former Prime Minister Tony Blair, who has taken a prominent role in raising awareness of climate change on the international stage, stated that the world has less than two years in which to start implementing cuts in greenhouse gas emissions, or accept that global warming is irreversible. This is one of the starkest warnings yet of the immense threat that civilization now faces. It is a warning that is supported by scientific evidence.

Last year, the Inter Governmental Panel on Climate Change (IPCC) issued its 4^th report on the science of climate change. This predicted that, if we continue as at present, average global temperatures would rise by around 3^oC this century, with the possibility that the rise could be in excess of 6^oC. The IPCC predicts that a temperature rise of 2^oC above pre-industrial levels would have catastrophic consequences but, in its report on the mitigation of climate change issued on May 4^th, concluded that it was economically and technically feasible to prevent this provided that action is taken urgently and a number of barriers can be overcome. EU governments have agreed that they should aim to keep global warming below 2^oC.

Although the IPCC’s scientific predictions are extremely worrying, many scientists believe they under-estimate the severity of the threat and were watered down in order to achieve political consensus amongst the 113 countries that signed off the final version of the reports. The New Scientist, for instance, has carried a number of articles claiming that recent evidence, particularly that relating to sea level rise, has been excluded. One of the world’s leading climate scientists, Dr Jim Hanson of NASA, wrote in July that the massive ice sheets of Greenland and Antarctica are disintegrating much faster than predicted and that this could result in a sea level rise of around 5 meters by the end of the century. And in June, the US National Academy of Sciences stated that carbon dioxide emissions have been rising by about 3% a year, which is higher than the worst case scenario outlined in the IPCC reports.

At the Welsh launch of the UK’s Committee on Climate Change, on March 13th in Cardiff, the chairman of the Commission, Lord Adair Turner, showed, in his presentation, how the predictions of temperature rise and climatic instability by the Met Office were considerably more worrying than the predictions of the IPCC.

It is clear that we face a massive challenge and have to take bold and radical action now to avoid catastrophe. As the chairman of the IPCC, Dr Rajendra Pachurai has stated:

"We have a very short window of opportunity for turning around the trend we have in rising greenhouse gas emissions. We don’t have the luxury of time.”  

It is against this background of a growing awareness of the severity of the threat posed by climate change and the failure of government’s to act that our parent body, Friends of the Earth (England, Wales and Northern Ireland), launched the Big Ask campaign in 2005. This called for new legislation which would require successive Government’s to cut UK annual carbon dioxide emissions by at least 3% every year. The campaign won the support of the majority of MPs in all the political parties and, as a result, the Government has drafted a Climate Change Bill for inclusion in this year’s Queens Speech. Although we welcome the introduction of the Bill, we regret that it falls short of what is required to meet the challenge of climate change. We believe that the Bill ought to include annual emission reduction targets to ensure that the UK achieves cuts of at least 80% by 2050, and should include emissions from aviation and shipping.

We welcome the fact that, on February 13^th this year, Assembly Members unanimously supported the motion that "mitigating the impact of climate change is the most important challenge facing the National Assembly and believes that this must become the first priority of the Assembly Government”.

General Questions

1. Is the proposed 3 per cent annual reduction target by 2011 'in areas of devolved competence’ sufficient to enable Wales to make its full contribution to meeting UK-wide targets? If not, what targets should be put in place?

The first issue that needs to be addressed in this question is that of 'areas of devolved competence’.

The generation and use of energy is responsible for almost all of the carbon dioxide emitted by human activity in Wales. DEFRA’s 'Greenhouse Gas Inventories for England, Scotland, Wales and Northern Ireland: 1990-2004’ shows that in Wales in 2004, this was made up of:

• Power generation - 31%

• Manufacturing industry & construction - 26%

• Road transport - 14%

• Residential -  11%

• Petroleum refining - 8%

• Commercial/Institutional - 3%

Gaining a clear understanding of how Welsh Assembly Government powers can influence emissions in these areas is difficult. While the Welsh Assembly Government has devolved competence over transport policy, for instance, emissions in this sector can be influenced by the Treasury’s powers over vehicle and fuel taxation.

The Energy Review, produced by The Cabinet Office in 2002, points out that, while responsibility for energy policy in the UK is mainly reserved to the DTI, a number of areas relating to energy policy are devolved to Wales. These are

• environment policy

• support for innovation

• housing

• planning (apart for power station consents over 50MW)

• control of the budget for energy efficiency schemes in Wales e.g The Home Energy Efficiency Scheme (HEES) and part of the activities of the Carbon Trust.

The Welsh Assembly also has a world leading remit to promote sustainable development that takes into account energy issues.  

The areas not devolved are

• promotion of renewable energy

• promotion of energy efficiency

• building regulations

• power station consents (over 50MW)

• overhead electricity line and gas pipeline consents.

Despite the lack of devolved powers on energy policy, the Welsh Assembly has attempted to play a significant role in this area. As the Richard Commission pointed out:

"The boundary between devolved and non-devolved issues did not appear to pose a problem, with the Assembly Government seeking to work with and influence Whitehall and businesses on non-devolved issues such as energy.” [Ch.5 Para.74]  

An example of this was the publication, by the Economic Development Committee, of reports on renewable energy (in 2002) and energy efficiency (in 2003). These were based on "the Assembly’s responsibility to promote sustainable development whilst facilitating economic growth and development”. Both reports attempted to steer Wales towards becoming 'a global showcase for clean energy developments and energy conservation’, a vision set out in the Assembly Government’s national economic development strategy, 'A Winning Wales’ (January 2002). This was indeed an ambitious aim for a Government that did not formally have responsibility for energy policy.

Since then, the Welsh Assembly Government has progressed energy policy in Wales by, for instance, setting a target to reduce carbon dioxide (CO2) emissions in Wales by 20% by 2020 from the 2000 level and producing an Energy Efficiency Action Plan (February 2004), TAN 8 -Planning for Renewable Energy - and the accompanying Ministerial Interim Planning Policy Statement (July 2005), and the Energy Route Map consultation document (June 2005). A number of energy actions are also referred to in the Sustainable Development Action Plan (October 2004), the Wales Spatial Plan (2004), the Environment Strategy (2005) and its Action Plan. Point 1 of the latter promised to set ambitious targets to reduce greenhouse gas emissions in Wales by March of this year but this did not happen.

Although the Welsh Assembly has had some influence in shaping Welsh energy policy, there have been two key areas where it would like to have control but to date has failed to do so. These are the devolution of Building Regulations and the power to decide on electricity generating stations over 50MW. Both could have an important impact in controlling CO2 emissions in Wales.

The Government of Wales Act 2006 enables the Welsh Assembly Government to acquire new powers for it to achieve reductions in CO2 emissions. Schedule 5, Part 1, lists the 20 devolved areas, called Fields, within which the national Assembly for Wales can seek legislative competence to pass Assembly Measures over certain topics, called Matters. We believe that there are six areas in which added powers could be sought to help develop carbon reduction policies. These are agriculture, economic development, environment, highways and transport, housing and local government. We understand, though, that the Act allows for exceptions to Matters for which legislative competence could be sought and that these could restrict the Assembly Government’s powers in relation to carbon emissions.

There appears to be some confusion as to what powers the Welsh Assembly Government currently has and is able to acquire in order to reduce CO2 emissions. At the Governance of Wales seminar, held at the Senedd on June 21^st, it was evident that legal experts were themselves uncertain of the powers currently or potentially available, with one pointing out  that more were available than most people realised. We hope this inquiry will clarify the situation.

We welcome the fact that 'One Wales’ states that specific sectoral targets will be set for the residential, public and transport areas but believe that the Welsh Assembly Government should be asked to clearly define the areas of devolved competence available to enable it to deliver the proposed cuts in emissions. In this regard, we urge the Welsh Assembly Government to gain the devolution of powers over the setting of Building Regulations as soon as possible and to ensure that they are implemented fully.

We also believe that the Assembly Government should be required to specify how it proposes to "work with the heavy industry and power generation industries to reduce emissions in those sectors”, as stated in 'One Wales’. Power generation is the largest single source of CO2 emissions in Wales. Yet Wales has no powers to specify emission limits on new power stations over 50 MW. So the Assembly Government could not specify Combined Heat & Power (CHP) power stations which could be 80+% efficient rather than Combined Cycle Gas Turbine (CCGT) power stations which are around 58% efficient.

Recently, a new 800 MW CCGT at Uskmouth was given the go-ahead by the UK government. It will be built only as 'CHP-ready’ although there surely must be plenty of scope for a district CHP scheme around Newport especially as there is much new development land at Llanwern.

Another two 2GW CCGT power stations have been proposed at Pembroke and Milford Haven without CHP. There is little hope that Wales could achieve overall CO2 reductions in the foreseeable future if all these power stations go ahead as proposed. The fitting of CHP, as practised in some other European countries, could significantly reduce these emissions.

As well as maximising opportunities for delivering emission reductions in devolved areas, the Assembly Government should also work as closely as possible with the UK government in non-devolved areas and in the implementation of the Climate Change Bill. In our submission to the consultation on the Bill, we have asked that the UK government negotiates an agreement with each of the devolved jurisdictions regarding the level of cuts for that jurisdiction. This should take the form of a published strategy for each jurisdiction showing how the targets will be met, or a "memorandum of understanding”. It may also be that the devolved jurisdictions decide to pass their own legislation to place further duties on their Ministers.

The main UK-wide targets that Wales is, or shall be, required to contribute are:

• the Kyoto protocol target of reducing greenhouse gas emissions by 12.5% a year by 2010 from 1990 levels as the UK’s contribution to the EU target of 8%.

• the UK Government’s target of reducing CO2 emissions by 20% by 2010 from 1990 levels.

• the Climate Change Bill provisional targets of 26-32% CO2 reductions by 2020 and 60% by 2050 from 1990 levels. This is now being reviewed by the Committee on Climate Change, in response to the latest IPCC reports, with the possibility of it being raised to 80% by 2050.

• The EU 2020 target of 20% of energy requirements (electricity, heat and vehicle fuels) coming from renewable sources.

A major concern we have with the proposed 'One Wales’ 3% annual emission reduction target is that it only "aims” to achieve reductions and as such is not a firm commitment. The wording ought to be strengthened to demonstrate a greater determination to achieve cuts.

Even once this is done, the 'One Wales’ 3% target, although a step in the right direction, would be too small a step to enable Wales to make its full contribution to meeting UK-wide targets. As it would apply to existing areas of devolved power only, it would not address important sources of CO2 in Wales, such as power generation and industry. And by being introduced from 2011 onwards, it would make no contribution to the UK’s Kyoto commitment or its 2010 CO2 target.  

The severe crises of climate change, in which we have but a short period of time in which to avert catastrophe, requires countries and regions to take a strong individual lead as well as engaging in joint actions and agreements. And, it is now being realised that the seemingly challenging targets being proposed in the Climate Change Bill fall well short of what is required. The Tyndall Centre for Climate Change Research at Manchester University, in its response to the draft Climate Change Bill’s carbon reduction targets, has stated that targets of reducing CO2 by 70% by 2030 and 90% by 2050 would be required to prevent the UK contributing to a temperature rise of 2^OC.

If Wales is to play its full part in combating climate change, we believe that the Welsh Assembly Government should make a commitment to reducing its overall CO2 emissions by 3% each year. This policy ought to be pursued vigorously by means of fully utilising existing devolved powers; using the opportunities provided by the Government of Wales Act 2006 to devolve powers in appropriate areas, such as electricity generation over 50MW; and maximising the potential for emission reductions arising from the Climate Change Bill.

2. Should the emission reduction targets be based on Welsh consumption, or production, or both (i.e should it take into consideration the carbon dioxide generated in Wales [production], or the carbon dioxide emissions that Wales’ residents are responsible for, regardless of their source [consumption])?

DEFRA’s Greenhouse Gas Inventories for England, Scotland, Wales and Northern Ireland: 1990-2005’ shows that, despite the setting of a target to cut UK carbon dioxide emissions by 20% between 1990 and 2010, carbon dioxide emissions generated in Wales  (the 'production’ model of measurement) were just 4% lower than in the base year of 1990. This compared to an overall reduction in the UK of 6.4% during this period. Emissions in Wales in 2005 were, in fact, 1 million tonnes higher than a decade earlier. In July last year, the Assembly’s Member’s Research Service produced a report, 'Carbon Dioxide Emissions in Wales’, which concluded that Wales had the 12^th highest per capita CO2 emissions in the world in 2004.

The predominance of industry in Wales is certainly one explanation for why it has relatively high emissions per capita.

If the 'consumption’ or 'footprint’ model is used, Wales performs far better with emissions slightly lower than the overall UK average. This provides a better picture of Wales’ impact globally in terms of emissions and resource consumption and is a good indicator of sustainability. We believe it should be used in relation to the Sustainable Development remit of the Welsh Assembly.

This 'production’ model is the established way of measuring greenhouse gas emissions at the international, European, UK and Welsh Assembly Government level. We believe it should be retained for this purpose and is, therefore, the most appropriate method of measuring emissions.

Concern about Wales having to carry more than its fair share of industrial emissions could be addressed by a 'weighted’ system that would distribute emissions from large point sources, such as steel works and large power stations, equally throughout the country. Thus all CO2 emissions from large power stations would be totalled and allocated throughout the UK on a per capita basis.

Questions specific to emissions of carbon dioxide from electricity generation

3. What particular challenges does the Welsh Assembly Government face in reducing carbon dioxide emissions from electricity generation and how can these challenges be overcome?

According to DEFRA’s 'Greenhouse Gas Inventories for England, Scotland, Wales and Northern Ireland: 1990-2005’, electricity generation was the by far the largest single source of greenhouse gas emissions in Wales in 2005, accounting for 28% of the total of 50.1 Mt CO2- equivalent. This was more than double the second largest source, iron and steel, which accounted for 13% of the total.

DEFRA Summary of Main Emission Sources for Wales, 2005 (kt CO₂-equivalent)

Electricity generation contributed around 33.7% of the total Welsh carbon dioxide emissions in 2005, which is slightly higher than the UK proportion of 31.1%. More significantly, the DEFRA greenhouse gas inventory report points out that "emissions from electricity generation in Wales have increased by 24.8% compared with a fall of 15.6% in UK emissions between 1990 and 2005” [section 4.2 page 15].

According to data provided in the Renewable Energy Route Map for Wales consultation document, annual electricity consumption in Wales amounts to 22 TWhr with electricity supply exceeding this at 31.5 TWhr. This is made up as follows:

• 23 TWhr from gas and coal-fired stations

• 7 TWhr from Wylfa nuclear power station

• 1.5 TWhr from renewable energy sources

We understand that there is a surplus of electricity in north Wales that is exported while there is a shortage in south Wales requiring a reliance on some imported electricity.

A number of plans to increase electricity generation in south Wales are being approved or proposed that will significantly increase CO₂ emissions. These are:

• Last August, a new 800 MW Combined Cycle Gas Turbine (CCGT) was approved at Uskmouth. Operating at 57% efficiency, it would generate nearly 30% of Wales’ electricity consumption and is expected to emit 2.2 million Tonnes of CO₂ a year.

• A planning application has been submitted for a 2,000MW LNG-powered CCGT power station at Pembroke. If approved, it would emit up to 6 million tonnes of CO₂ a year whilst generating two thirds of Wales’ electricity demand.

• A proposal has been made for a similar sized LNG power station at Milford Haven.

• The upgrading of Aberthaw power station with flue gas desulphurisation equipment will result in an increase in output and an increase in CO₂ emissions from 7m tonnes a year to almost 10m tonnes. A recent FoE Cymru study showed that Aberthaw is Wales’ main polluter in terms of carbon dioxide, nitrogen oxides (NOx) and sulphur dioxide (SO₂) emissions, and the second largest polluter in terms of PM10s.

• A 350 MW biomass power station has been approved at Port Talbot. Although the power station would, in theory, be almost carbon neutral as the trees absorb CO₂ as they grow, its emissions would add to Wales’ total figure.

Thus, as Wales is putting in place ambitious plans and targets to reduce CO₂ emissions, the proposed increases from the electricity generating sector alone are likely to add over 10 million tonnes to the country’s total within five years. As decision making on electricity generating stations over 50MW rests with the Department for Business, Enterprise and Regulatory Reform (DBERR), the situation in Wales certainly presents a major challenge for the Welsh Assembly Government.

We believe it is vital that the Welsh Assembly Government increases pressure on its Westminster colleagues for the devolution of these powers as soon as possible. It seems that Whitehall is hanging onto these powers in order to retain control over decisions on nuclear energy generation in Wales. Should these powers be devolved, the Welsh Assembly Government would be in a position to significantly reduce emissions of CO₂ and pollutants, such as NO_x and SO₂, and  improve efficiency and energy security by insisting on using combined heat and power (CHP) systems. This is one of a number of measures the Welsh Assembly Government could take to overcome the challenge posed by worryingly large amount of emissions from electricity generation.

Combined Heat and Power (CHP)

By using the waste heat in electricity generation, CHP systems can significantly improve the efficiency and reduce emissions from power stations. According to the DTI’s 'UK Energy Sector Indicators (2005)’, UK power stations, on average, use just 38% of the energy in their fuel because of inefficient technologies. Yet, in Denmark, where CHP is common practice, they are generating electricity from coal in a 350MW CHP power station at Odense operating at 93% efficiency [See: http://www.bwe.dk/pdf/case-10%20FV07.pdf ].

The proposed LNG power station at Pembroke would be inefficient and would waste, in the process of generating electricity, heat equivalent to half the electricity demand of Wales. If the energy losses involved in extracting and liquefying the gas in the Middle East, and transporting and re-vaporising the LNG at Milford Haven were taken into account, it is estimated that almost 60% of the energy content of the gas would be wasted in the overall process of using it to generate electricity. Our briefing paper, 'Sustainable Heat Around Milford Haven’, provides details of these energy losses. We attach the paper as Appendix 1. By appropriate siting and optimization of power generation schemes, most of the heat generated could usefully be used to re-gasify the cold LNG imports at the terminals and also to supply heat needs at the Haven’s two oil refineries.

Similarly, the 800MW Uskmouth CCGT power station has been approved only as 'CHP ready’ even though the waste heat could be used locally. Newport could have been a prime location for a CHP scheme. The old steel works site at Llanwern is preparing for major redevelopment so the required hot water pipes could have been laid during the ground work stage. A highly efficient CHP scheme in Newport would have demonstrated global leadership in responding to climate change. Instead, the new power station will waste a third of the gas it uses.

The recently approved 350MW Port Talbot biomass power station is also another missed CHP opportunity, achieving an operating efficiency of just 38%. It would generate about 14% of Welsh electricity demand but the heat wasted could meet the heat requirements of thousands of people.

Meanwhile, on March 16^th, the London Development Agency announced pioneering plans for the UK’s first scheme to harness waste heat from an existing power station. The 400MW of waste heat from the Barking power station is to be harnessed to supply up to 120,000 properties in the Thames Gateway, saving 96,000 tonnes of CO₂ a year.

The UK languishes near the very bottom of the European Union's CHP league table with just 7% of UK electricity being generated by CHP, compared to 30% in the Netherlands and 50% in Denmark.

It is unforgivable that such waste and unnecessary emissions of CO₂ are permitted when the threat posed by climate change is now so stark. It shows a shocking complacency in the face of the greatest threat that civilization has ever faced.

Renewable Energy

We welcome the aim, expressed in the Welsh Assembly Government’s 'Renewable Energy Route Map for Wales’, to generate all of Wales’ electricity from renewable sources by 2025. This is the sort of bold measure that will be required if we are to make our fair contribution to cutting greenhouse gas emissions, and it is very preferable to present proposals for a major expansion in fossil fuel electricity generation in Wales.

Wind Energy

TAN 8 correctly recognises that onshore wind energy offers the most viable way forward at this point in time. Wind energy is both the most cost-effective and technologically the most advanced of the renewable energy options available to us. It can deliver much-needed cuts in CO₂ emissions now. This is why, globally, wind energy capacity increased more than any other renewable power technology in 2007, with an estimated 21 gigawatts (GW) added. This represented a 28% increase over 2006 and is occurring while there is a major expansion in all renewables worldwide in order to meet the challenge of climate change. Renewable electricity generation capacity reached an estimated 240GW worldwide in 2007, an increase of 50% since 2004. Wind power has also become one of the broadest-based renewable technologies, with installations in more than 70 countries. Information in this paragraph has been provided by the Worldwatch Institute’s 'Renewables 2007 Global Status Report’.

We have calculated that present proposals for wind energy development could provide around a quarter of Wales’ electricity demand. The calculations are as follows:

"Wales electricity demand = 22 TWhrs/yr

Onshore wind capacity = 200 MW (already built) plus 800 MW additional target by 2010. At 30% load factor this = 300 MW average annual output

Offshore wind capacity =  North Hoyle 60 MW plus Scarweather 100 MW plus Gwynt y Mor 750 MW = 900 MW in total

35% load factor = 315 MW average annual output

In all, 615 MW from both onshore and offshore wind farms.

In one year, 615 MW average would generate 0.615 x 8.76 = 5.39 TWhrs/yr or 25% of current demand in Wales. This would supply around 800,000 people in Wales.”

Despite the effectiveness of wind energy in providing low carbon electricity, it has faced strong opposition from a minority of people. But, as the Sustainable Development Commission report on wind energy demonstrated, opinion polls consistently show that most people (around 3 to 1) support wind energy. And once wind farms are built and operating, opposition declines as people realise they are not the monsters they were made out to be. Such opposition is not unique to wind energy. From our experience, practically every measure we propose to reduce greenhouse gas emissions triggers a hostile response in one form or another. Examples of this are:

• Wood burning power stations at Newbride-on-Wye and at Llanddewi Velfrey, Pembrokeshire, were opposed and defeated because of concerns about emissions and the transportation of the fuel.

• A proposal to grow rape to produce a bio-fuel in Pembrokeshire was opposed because there would be too many yellow fields

• Applications to install solar panels in conservation areas have been rejected on the grounds of visual pollution

• There has been strong opposition from motorists to higher taxes on gas-guzzling vehicles or to congestion charging.

• A Welsh Assembly Government planning inspector opposed an application by a farmer to erect a single wind turbine on a farm adjacent to the Texaco oil refinery in Pembroke on the grounds of visual intrusion!

• Opposition to low energy light bulbs has been expressed because they contain small amounts of mercury and emit less heat than energy wasteful bulbs.

Opponents of wind energy often complain of subsidies to wind but seem far less concerned about the larger subsidies given to fossil fuels and nuclear power. According to the New Economics Foundation report, 'Up In Smoke' (2004), industrialised countries provide a subsidy of $73 billion a year to their fossil fuel industries. The cost of decommissioning existing nuclear power stations in the UK is now put at over £70 billion. This will have to be funded by UK taxpayers and is in addition to the billions of pounds that nuclear power has received in subsidies since the 1950s.

Burning fossil fuels also imposes a huge financial cost in terms of the environmental and health damage caused. The EU's EXTERNE report in 2001 concluded that the price of electricity generated from coal and oil would have to be doubled if it were to include the costs of damage to the environment and health. DEFRA's consultation on air quality strategy in April 2006 stated that the health impacts of particulate pollution (caused by burning fossil fuels) amounted to £21 billion each year in the UK. These figures don't include the cost of damage caused by climate change. The UK Government estimates that each tonne of CO2 causes £26.50 worth of damage. As Wales emitted 41.7 million tonnes of CO2 in 2005, this caused over £1 billion worth of damage.

It is sometimes alleged that onshore wind energy has been given more support than other forms of renewable energy, such as tidal and wave power. This is incorrect. A presentation at the NASEG meeting, on July 3^rd last year, showed that marine renewables are receiving tens of millions of pounds in direct grant support to help develop the technologies. Onshore wind energy has not received such direct grant support.  In addition, the Energy White Paper has proposed that offshore renewables receive double the ROCs (Renewable Obligation Certificates) that onshore wind energy receives.

Opponents of wind energy also complain that wind energy is intermittent but seem happy to ignore the intermittency of nuclear power. Last October, for instance, it was widely reported that almost half of British Energy's nuclear reactors were currently off line because of technical faults. The previous winter, the company's Hinkley Point and Hunterston nuclear power stations were closed for similar reasons. The issue of intermittency is also addressed in our wind energy fact sheet at:

http://www.foe.co.uk/resource/factsheets/wind_power.pdf

It has been claimed that TAN 8 will mean "wind turbines covering the whole of the country”. As a result of the TAN 8 planning policy, future wind farms in Wales, amounting to 800MW capacity, will be mostly restricted to seven special areas (Strategic Search Areas). These areas amount to 140km² or just 0.68 per cent of the land area of Wales¹.

We attach, as Appendix 2, a 'Wind Energy: 10 Myths’ paper produced by Abergavenny and Crickhowell Friends of the Earth. We are currently updating this and would be happy to present it to the Sustainability Committee in the near future.

Tidal Energy

We are pleased that efforts are being focussed on harnessing the immense tidal energy resources around the Welsh coast but regret that the Severn Barrage appears to be the favoured option of the UK government.

On October 1^st 2007, we published our detailed report on the Severn Barrage. English and Welsh language versions of this report can be found here:

English: www.foe.co.uk/cymru/english/news/severn_barrage_report.html
Cymraeg: www.foe.co.uk/cymru/cymraeg/newyddion/morglawdd_afon_hafren.html

The report concluded that a Severn barrage would block the development of more cost effective, environmentally acceptable and powerful renewable energy schemes in the Severn estuary. It also identified six major reasons why we believe that tidal lagoons would be a better option than the proposed Severn barrage. These are:

• Lagoons would not cause significant damage to an internationally important habitat - the Severn barrage would submerge 60% of the inter-tidal feeding grounds for tens of thousands of birds

• Lagoons could potentially harness more tidal energy from the Severn estuary

• Lagoons would be cheaper

• Lagoons would not impede navigation to Severn Estuary ports, such as Avonmouth and Portbury

• Lagoons could store tidal energy and release it when needed. The Severn barrage’s huge twice-daily pulses of power would not synchronise with the daily variations in grid demand and would need extensive stand-by capacity.

• Lagoons would be compatible with a Shoots barrage near the second Severn crossing, which could provide flood defence and a strategic rail link from London to south Wales avoiding the ageing Severn tunnel.

Our report concludes that a relatively small tidal lagoon demonstration scheme should be built. Lagoon developer, Tidal Electric Ltd, has proposed building the world’s first lagoon scheme in Swansea Bay with private funds, yet the company states that it has had to contend with outright hostility from influential officials within the DTI (now DBERR). In June 2006, a Welsh Affairs Select Committee energy report expressed concern about the DTI’s handling of lagoon technology. We were pleased to hear the Welsh Minister with responsibility for energy, Jane Davidson, state at the launch of the Renewable Energy Route Map consultation at Cwmbran that she would be happy to see the world’s first tidal lagoon built in Wales.

We are represented on the UK government’s Severn Tidal Power Feasibility Study Group and will shortly be submitting to the group our critique of the Sustainable Development Commissions report into tidal power in the UK. We are happy to submit this to the Sustainability Committee’s inquiry also.  

Nuclear Power

We welcome the Welsh Assembly Government’s opposition to new nuclear build in Wales and believe that any new nuclear power stations would be a costly irrelevance that could hamper the battle against climate change.

In November 2007, the leading think, the Institute of Public Policy Research, showed, in its report, '80% Challenge: Delivering a Low Carbon UK’, that the UK could cut its CO2 emissions by 80% by 2050 without building any new nuclear power stations. The renowned Tyndall Centre for Climate Change at Manchester University came to a similar conclusion in its 2006 report, 'Living Within a Carbon Budget’.

Professor Catherine Mitchell, an energy economist at Exeter University, warned in her report, 'New Nuclear Power: Implications for a Sustainable Energy System’, that, "The scale of financial, political and institutional commitments required to build new nuclear power plants will undermine support for new technologies (such as renewable generation) and demand reduction measures, which are vital to achieving a low carbon economy”.

In January of this year, we produced a paper,’ Filling New Labour’s Generating Gap’, that demonstrates that the predicted shortfall in generating capacity of 20GW by 2020 can be met by CHP, consented or under-construction gas-fired power stations and renewable energy. This paper is attached as Appendix 3.

The proposed nuclear expansion programme will only ever cut the UK’s carbon dioxide emissions by 4 per cent. The cost of achieving this reduction would be yet more nuclear waste that will be dangerous for tens of thousands of years, and enhanced risks of terrorism attack, accidents and nuclear proliferation to less stable countries.

Nuclear power has already gobbled up billions of pounds in grants and subsidies, and UK taxpayers now face a bill of over £70 billion to decommission existing nuclear power stations.

The main focus of attention in Wales is the closure of Wylfa nuclear power station in 2010. It is argued that Anglesey Aluminium is dependent on electricity from Wylfa but, as it would be around 2020 before a replacement for Wylfa could be built, other sources of electricity will have to be found. We believe that this electricity could be provided by a range of options, such as tidal energy, offshore wind farms, a gas-fired CHP power station and wood-fired CHP power stations. The seas off Wylfa Head offer one of the best resources for tidal energy in the UK. The decommissioning of Wylfa would ensure that large numbers of staff would be retained while employment opportunities would arise in developing alternative energy options.

Coal

We are concerned that comments are being made predicting a renaissance for the Welsh coal industry before solutions have been found to the considerable environmental problems associated with this dirty fuel.

One of the world’s most respected climate scientists, Dr James Hanson of NASA, stated in a letter to Prime Minister Gordon Brown last year that coal-fired generation is historically responsible for most of the fossil-fuel CO₂ in the atmosphere and about half of all CO₂ emissions globally. He is so concerned about plans for new coal plants in Britain he urged the Prime Minister to reject a new generation of coal-fired power stations, such as the Kingsnorth power station in Kent, which would emit 8 million tonnes of CO₂ a year. The increased use of coal has halted the decline in emissions seen in the 1990s following the 'dash for gas’ and has undermined progress from other sectors in cutting emissions.

The Kingsnorth power station would be built so as to install CCS (carbon capture and storage) when it becomes viable. Unfortunately this might still be some way off, and, as far as Wales is concerned, there would appear to be few if any sites suitable for storing carbon. The most appropriate locations are those on the eastern side of the UK that could use the disused oil and gas wells of the North Sea for carbon storage.

While we have to wean ourselves off fossil fuels as quickly as possible, we cannot do so overnight and will be dependent on coal for some time yet. Climate change dictates that the only acceptable way forward for new coal-fired power stations is if they are CHP and/or CCS. As Wales is already heading for a surplus of electricity generation and is setting a target to generate all its electricity from renewable sources by 2025, there is little likelihood that new coal-fired power stations need to be built in Wales. A strong case could be made, though, for shutting Aberthaw power station and replacing it with coal-fired CHP achieving similar efficiency levels to the one at Odense in Denmark.

As over 70% of the coal used in the UK is imported from countries such as Russia, South Africa and Australia, we believe that Welsh coal mining could be thrown a lifeline if it replaced imported coal. It is vital, though, that all efforts are made to reduce our use of this filthy fuel and to develop much cleaner ways of burning it.

We totally oppose opencast mining because of its adverse impacts on local communities, the natural environment and the landscape. We believe that the Welsh Assembly Government’s decision to give the go-ahead to the large Ffos-y-Fran opencast site just 35 metres away from homes in Merthyr, which is one of the most deprived communities in the UK, is totally incompatible with its commitment to sustainable development and that planning permission ought to be rescinded.

The Welsh Assembly Government is correct to set ambitious targets for generating electricity from renewable energy sources. The crises of climate change demands that we make major reductions in the emission of greenhouse gases from this main source as quickly as possible. It is important to note that, as DEFRA has stated, "emissions from electricity generation in Wales increased by 24.8% between 1990 and 2005”, and that a significant further increase will take place unless action is taken. It is vitally important that the Welsh Assembly Government increases its efforts to devolve decision making on power stations over 50MW to Wales as soon as possible. This would allow us to develop a more effective response to the immense challenge of climate change. A failure to do so will mean that existing and proposed fossil fuel power stations would shatter any attempts to reduce overall emissions from Wales.

As the other questions in this consultation have been ably answered in the submission by our colleagues in Wales Environment Link, we shall not repeat the points they have made.

March 16^th 2008

Notes
1. 'Facilitating Planning For Renewable Energy in Wales: Meeting The Target’ by Ove Arup & Partners Ltd (June 2005) on behalf of the Welsh Assembly Government

Appendix 1

Sustainable Heat around Milford Haven

In the wake of the current construction of two large liquefied natural gas (LNG) import terminals, one or possibly two very large 2 GWe CCGT power stations have been proposed around Milford Haven.

Friends of the Earth Cymru is concerned that very large quantities of waste heat, which could be avoided, would be generated by these CCGTs. As the heat wasted could exceed the energy equivalent of annual electricity consumption in Wales, avoiding such losses would have significant benefits in terms of climate protection, energy security and UK balance of payments.

By appropriate siting and optimization of power generation schemes, most of the heat generated could usefully be used to re-gasify the cold LNG imports at the terminals and also to supply heat needs at the Haven’s two oil refineries.

For theses reasons Friends of the Earth Cymru is calling for a sustainable heat strategy for the Haven area and points out that what happens in the Haven is a 'litmus test’ of UK energy policy.

Current situation and proposed schemes

One of the 2 GWe CCGT power station schemes, currently proposed by RWE npower, would be built on the vacant former Pembroke power station site on the south side of the Haven. The other CCGT, possibly also 2 GWe, could be built by Milford Power adjacent to the new Dragon LNG terminal on the north side of the Haven, directly north of the old Pembroke power station site. A second, larger South Hook LNG terminal is under construction on the north side of the Haven, four miles or so to the west of the Dragon LNG terminal.

Also on the shores of the Haven are two oil refineries, Texaco on the south side about two miles west of the Pembroke power station site, and Total Fina Elf about two miles north east of the South Hook LNG terminal.

The waterway is about a mile wide at this location and there is considered to be no likelihood of hot water pipes being installed under the Haven, from a scheme on the south side, to supply heat needed for 're-gasification’ on the north side.

Heat needs and outputs

The HEAT output from one such new 2 GWe CCGT which would likely be operating at baseload (about 82% load factor) would be in the region of 11.75 TWh/year (2 GWe x 8.76 hours/year x 0.82 load factor x 45/55 = 11.75).

Note that even both the latest and the next-generation 'high efficiency’ CCGT technology is unlikely to operate at higher than 55% electrical efficiency. Higher efficiencies, 60% or more, are sometimes quoted but such percentages are unproven or may represent theoretical test bench output rather than 'gate’ output.

The HEAT need for LNG re-gas at the LNG terminals will be, depending on the level of annual imports, about 4 TWh/year at the South Hook site and 2 TWh/year at the Dragon site. The heat need at the Texaco oil refinery may be around 2 TWh/year and at Total Fina Elf about 1 TWh/year. Overall, the Haven’s heat need amounts to around 9 TWh/year.

The HEAT generated by the proposed RWE npower scheme on the south side would be around 11.75 TWh/year, far in excess of the 2 TWh/year heat need at the Texaco refinery, even if pipes were connected up. The heat generated by a 2 GWe Milford Power scheme adjacent to the Dragon LNG terminal would also be around 11.75 TWh/year but only 2 TWh/year would be needed for re-gas. This figure is based on Milford Power’s previous application estimating a peak re-gas heat need of 250 MWth (FOE estimate : 0.25 peak x 8.76 x 100 = 2.19). The heat need is still relatively small (ie 2 TWh/year needed, 11.75 TWh/year produced).

Four miles to the west of the Dragon LNG site, on the north side, the larger South Hook LNG terminal would be about twice the size of the Dragon terminal and hence twice the annual heat would be needed for re-gas. This would be around 4 TWh/year of heat (2 x 2.19 peak). Currently, there are no proposals to use waste heat from any on-site or off-site power station for re-gas at the Exxon site (despite Exxon's worldwide pro CHP advertising). Some of the imported gas would be burnt to provide heat for re-gas.

Waste heat comparisons

Overall, the combined electrical output of the two 2GWe stations would be in the region of 28.7 TWh/year( 4GWe x 8.76 x 0.82 = 28.7 TWh/year) and the combined heat output would be 23.5 TWh/year (11.75 x 2). Yet only 2 TWh/year would be used for re-gas when 6 TWh/year is needed for re-gas (2 at Dragon and 4 at Exxon) and 3 TWhr/year is needed at the refineries.

In comparison, Wales's annual electricity demand is around 20 TWh/year.

So, the heat waste from two large 2gwe ccgts would be greater than wales's electricity demand - even with heat being used for re-gas at the Dragon terminal and some at Texaco!

The proposed Severn barrage or large tidal lagoons in the Severn Estuary would generate around 17 TWh/year, and the 2010 renewable energy target policy of the Welsh Assembly Government is 4 TWh/year. A 'replacement’ 10GWe new nuclear power station programme would generate 80 TWh/year.

How to avoid wasting heat and imported gas

To effectively utilize the heat generated by any power stations, would require those power stations to be located close to the two LNG terminals and/or refineries and for the size of the schemes to be optimized to match the annual heat need at each of the LNG terminals and refineries.

This would require power stations of capacity of around 300 MWe of CCGT at the Dragon terminal and about 600 MWe of CCGT at the larger South Hook terminal. Such stations would produce around 6.5 TWh/year for a heat need of around 6 TWh/year. At this scale the CCGTs would effectively be 'very good quality' CHP schemes.

Smaller CHP schemes at the refineries, or hot water pipes from a slightly larger South Hook scheme to the Total Fina Elf refinery, would minimize heat waste. Developers may say that it would not be commercially viable to lay hot water pipes that far - about 3 miles. Yet, to not do so would result in additional imported gas being shipped or piped possibly around 3,000 miles, which itself incurs a loss of 20% of the heat value of the gas.

The Parliamentary Under Secretary of State for Wales, Nick Ainger MP, has raised the point about the lack of grid cables to the South Hook site and that the old Pembroke station site still has its grid lines. Again, while this is true, it surely is a relatively minor consideration compared with wasting anything like 11.75 TWh/year of heat (equivalent to half of Wales's electricity demand) if the RWE scheme went ahead.

Friends of the Earth Cymru say that all power schemes should be optimized CHP schemes - scaled to the heat need of the terminals and refineries. This would probably mean an overall generating capacity of around 1.2 GWe around the Haven.

Note also that about 1.2 GWe of capacity around Milford Haven would not overload the south Wales grid which would be stretched if 2 to 4 GW were built. A suggested inter-connector to Ireland, if built, would resolve this grid constraint but the main concern about wasted heat would not be addressed by an inter-connector.

Summary

To minimize heat losses and carbon dioxide emissions from power generation around Milford Haven the proposals for one or possibly two large CCGT power stations should be abandoned. Good quality combined heat and power (CHP) schemes would need to be built adjacent to the two LNG terminals and the two oil refineries, optimized in size to match the annual heat needs of the LNG terminals and the refineries.

Yet, current UK energy policy provides insufficient incentive, despite the significant energy security, emission reduction and balance of payments benefits, to put into effect what would be 'good-quality' CHP plan for the Haven.

Policies in the forthcoming Energy White Paper should incentivise the attainment of such benefits.

March 2007

Appendix 2

Wind power: 10 Myths explained byAbergavenny & Crickhowell Friends of the Earth
Myth 1: Wind produces little power

The facts:

• Denmark produces over 15% of its electricity from wind while Germany produces over 5% of its total  The UK has better wind resources  - in fact, the best in Europe!

• A single 1.8-megawatt turbine can produce enough power for 1,000 homes - and save over 4,000 tonnes of CO2 emissions annually.

• The average wind-farm will pay back the energy used in its manufacture within three to five months - more quickly than coal or nuclear plants (British Wind Energy Association).

Myth 2: Wind is intermittent and therefore unreliable

The facts:

• Wind does have a degree of intermittency. But the UK is the windiest country in Europe. When wind-speeds are too low or too high in one location, other wind-farms are still operating in other parts of the country.

• No energy technology can be relied upon 100%. The National Grid can cope with the intermittency of wind without difficulty. It already operates with enough back-up to manage the instantaneous loss of a large coal-fired or nuclear power station. The amount of additional back-up needed if wind-farms were to generate 15% of the UK’s electricity would be small.

Myth 3: Wind is being promoted at the expense of other renewables

The facts:

• Other renewables technologies such as solar, geothermal and tidal & wave must be developed quickly - the UK has the biggest tidal and wave resources in Europe!

• But wind energy is currently the most available and economically viable technology.

• Global Warming will pass the 'tipping point’ unless radical action is taken now. It would be irresponsible not to use the UK’s abundant wind resources to reduce carbon emissions.

Myth 4: Wind power is expensive

The facts:

• The cost of generating electricity from wind has fallen dramatically over the past few years. Between 1990 and 2002, world wind energy capacity doubled every three years and with every doubling prices fell by 15%

• The average cost of generating electricity from onshore wind is now around  3-4p per kilowatt hour, competitive with new coal (2.5-4.5p) and cheaper than new nuclear (4-7p)

• As gas prices increase and wind power costs fall, wind becomes even more competitive, so much so that some time after 2010 wind should challenge gas as the lowest cost power source.

• Furthermore, the wind is a free and widely available fuel source, therefore once the wind farm is in place, there are no fuel or waste related costs.

Myth 5: Turbines are taking over the countryside

The facts:

• There are at present some 1,733 wind turbines in 136 wind-farms, generating 1,963MW (British Wind Energy Association, May 2006).

• Generating 15% of the UK’s electricity by wind would need substantially more turbines. But they would not 'cover the countryside’ and some would be off-shore.   

• The actual ground area physically covered by wind farms is not great, because land between turbines can still be used for farming or open countryside access.

Myth 6: Wind farms are unpopular

The facts:

• A survey conducted by Mori (November 2005) showed 72% of people supported wind farms, and was the favoured choice of Britons to fill the energy gap in the future.

• A more recent survey commissioned by the DTI (May 2006) found that 81% are in favour of wind power and 62% would be happy to live within 5km (3 miles) of a wind farm.

• Whether you think a wind turbine is attractive or not will always be your personal opinion. Studies regularly show that most people find turbines an interesting feature of the landscape.

Myth 7: Wind farms keep tourists away

The facts:

• A St Andrews University study in Scotland & Ireland (Dec 2005) found that tourists were not put off by the sight of wind-farms. Many even thought wind farms to be a positive addition.

• The UK's first commercial wind farm at Delabole received 350,000 visitors in its first 10 years of operation, while 10,000 visitors a year come to the EcoTech Centre in Swaffham, Norfolk.

• 12,500 visitors visited flagship wind farms around the UK in the 2006 August bank holiday

• A MORI poll in Scotland showed that 80% of tourists would like to visit a wind farm. Wind farms are often asked to provide visitor centres and rights of way to their sites.

Myth 8: Turbines are noisy

The facts:

• With modern turbine designs, mechanical noise from turbines is almost undetectable. It is possible to stand directly under a turbine and hear only the 'swish’ of the blades.

• Low frequency noise is not a problem to people living nearby. A survey commissioned by the DTI in 1997 found that vibration levels 100 metres from turbines are ten times lower that the safety levels required by modern laboratories.

• The author of the Defra Report on Low Frequency Noise and its Effects (2003) says: "I can state quite categorically that there is no significant infrasound from current designs of wind turbines. There will not be any effects from infrasound from the turbines."

Myth 9: Wind farms harm house prices

The facts:

• There is currently no evidence in the UK showing that wind farms impact house prices. However, there is evidence following a comprehensive study by the Scottish Executive that those living nearest to wind farms are their strongest advocates.

• A Knight Frank (Surveyors) study conmissioned by BWEA in 2004 found "there is no empirical evidence linking the development of wind farms with house prices”.

• A Royal Institution of Chartered Surveyors study (2004) found that where house-prices are initially depressed, they recover after wind farms have been up and running for two years.

• A significant minority of surveyors (40%) reported no impact from wind farm developments on residential property values.

Myth 10: Turbine blades threaten bird populations

The facts:

• The available evidence, say RSPB, is that there is no significant hazard to birds, providing that wind-farms are located away from flight-paths of migrating flocks.

• A report for the Swedish State Energy Authority (2005) found that even the risk to migrating birds is slight.

• The impact on wildlife must be kept in context. A paper in Nature, by a group of scientists including one from RSPB, indicated that global warming if unchecked may make 15% to 37% of our planet’s species extinct by 2020.

Appendix 3

Filling New Labour’s 'generating gap’(without nuclear power)

Briefing

January 2008

1 Introduction

1.1 On 19th November 2007 the prime minister Gordon Brown essentially stated in a major media speech that nuclear power supplies 7.5 % of UK energy. It does not of course, its about 3.8 %. The 7.5 % 'total' energy figure includes the thermal losses in the nuclear power stations which end up heating UK coastal waters*. But this classic piece of mis-information by DBERR officals and or closer advisers is one example of a wider campaign of spin and mis-information by some senior civil servants, the nuclear lobby and some witting or unwitting ministers.

1.2 Other ministerial classics are that new nuclear power stations are needed to fill an emerging 'generating gap’, to avoid 'the lights going out’ and to 'reduce dependence on gas from rogue states’.

1.3 A new 10 GW 'replacement' nuclear power programme would generate

between 4 - 5 % of UK energy (final 'useful’ consumption)*. And this inherently

dangerous and polluting technology is simply not needed to fill any so-called

electricity 'generating gap', or avoid 'the lights going out’, or to achieve future

carbon dioxide emission targets, or UK energy security. This briefing explains why.

2 The so-called 'generating gap'

2.1 In a speech on 17th december 2007 the Secretary of State for Business John Hutton MP stated that 30 - 35 GW of power station generating capacity would be needed just to replace that being decommissioned by 2027. He stated that two thirds of this capacity would be decommissioned by 2020. He also announced a major increase in the Government's 2020 offshore wind energy target.

2.2 The amount of electricity that even 35 GW of power stations could generate annually, even at a very high 90% load factor, would be around 276 TWh/year (35 GW x 8.76 x 90% load factor = 276) by 2027. So two thirds by 2020 would be a maximum of 185 TWh/year. Assuming also that electricity demand increases by about 10 % by 2020 (400 x 10% = 40 TWh/year) despite demand-side energy efficiency measures, then the maximum likely output from new capacity needed would be around 225 TWh/year by 2020.

2.3 Similarly by 2027 about 330 TWh/year or so of new generation may be needed, especially if electric vehicles are being purchased in quantity. There would also be a need to have standby capacity for lulls in renewable output, especially offshore wind.

2.4 A new 10 GW 'replacement' nuclear power programme may generate nearly 80 TWh/y (10 GW x 8.76 x 90% load factor) by about 2025, with the first station opening in 2017 at the earliest. Around 5 GW, generating 40 TWh/year, might be operational by 2020, though delays for a variety of reasons, including construction overruns, may result in little operational capacity before 2020.

2.5 Yet, as shown below, new NON nuclear capacity (and its output) either

consented, proposed or possible is capable of exceeding 225 TWh/year by 2020 and in excess of 320 TWh/year by 2027.

2.6 By 2020 new output could comprise :

i) nearly 5 GW of new 'centralised' medium efficiency CCGT gas power stations which have already been consented or are under construction will be supplying around 30 TWh/year (5 GW x 8.76 x 75 % load factor)

ii) additional renewables (excluding biomass fired CHP to avoid double counting) would supply at least 115 TWh/year by 2020 (100 TWh/year from 33 GW offshore wind target alone) - John Hutton's announcement for an additional 25 GW of offshore wind by 2020 announced on 17th December after the nuclear consultation had ended would itself generate around 80 TWh/year (25 GW x 8.76 x 35% load factor) the same as a new 10 GW 'replacement' nuclear programme.

iii) additional 14 GWe of CHP could generate about 90 TWh/year by 2020 (14 GWe x 8.76 x 0.75 load factor) - currently there is about 6 GWe and Government had an 'aspirational' CHP target of 20 GWe by 2020.

2.7 Summing the above outputs amounts to at least 235 TWh/year of output (30 + 115 + 90) by 2020 is achievable, more than the likely maximum need of 225 TWh/year. Between 2020 - 2027 considerable renewable manufacturing capability would be available which, together with more CHP capacity, could then cover the 100 TWh/year or so extra needed to cover 2027 demand (330 TWh/year or more of new output).

2.8 The renewables figure above is a conservative estimate. Considering the EU's renewable energy target of 20% by 2020 (not just electricity) the resource rich UK's renewable energy target should be aimed at 400 TWh/year by 2020 (20% of final consumption of 2,000 TWh/year). So the UK's electricity target really should be aiming for over 200 TWh/year by 2020 which would be over 50% of electricity demand.

2.9 The (additional) 115 TWh/year figure used above, plus say even 40 TWh/year of (additional) biomass within the CHP figure or co-fired in existing coal power stations, plus existing renewables, still falls short of 200 TWh/year by 2020. This would be the minimum mark which should be expected of a 'leading' developed nation with 'global reach'. The figure also excludes the proposed Severn barrage (17 TWh/year) which most environmental groups oppose - neither does it include large scale tidal lagoons (which would likely be environmentally benign at some scale if viable).

2.10 This analysis also excludes any further Government consents for proposed new higher carbon emitting CCGTs (8.5 GW in planning), or coal power stations (eg 1.6 GW at Kingsnorth or 1.6 GW at Tilbury) which are NOT needed. The Thames coal schemes particularly would significantly compromise UK emission targets unless they were built as CHP (to London) AND fitted with CCS if and when viability is demonstrated (2017 - 2020 ?). Several GW of coal-fired city-wide CHP schemes should be considered favourably before CCS is demonstrated to be viable or not.

2.11 Much of the large CHP schemes could be fitted or retrofitted with CCS if it proves viable to address futher emission reduction commitments. Indeed CHP would make CCS much more cost effective compared to electricity-only schemes due to the significant efficiency improvement (ie low carbon heat).

2.12 CHP technologies large and small could be powered by 'carbon-neutral' fuels such as biomass, renewably generated ('green') methane and green hydrocarbons (eg methanol). Significant use of such carbon-neutral fuels in CHP with CCS schemes would result in significant 'carbon-negative' operation. This capability may be very useful in the decades to come depending on climate commitments and carbon price.

2.13 As mentioned the above figures, which are conservative, include a net

increase in electricity demand of about 10% by 2020 due to population rise, new home construction, electric vehicles, etc minus demand-side energy efficiency savings. An even greater rise in demand could be covered by 2027. Before about 2020, concerted energy efficiency programmes may reduce current electricity demand before any significant use of electric vehicles added to electricity demand (while reducing oil demand and primary energy supply).

3 Back-up capacity for large scale renewables

3.1 Large scale renewables, which play a big part of in any likely scenario, will need significant electricity generating 'back-up' in future decades to cover occasional lulls in output due to weather conditions conditions, particularly offshore wind, wave and solar. Some older existing generating capacity could be retained and demand management techniques would contribute. Some existing power stations (coal and 'dash-for-gas' CCGTs) should be retained. Various large scale storage technologies and techniques are also under development.

3.2 CHP schemes could also vary their electricity and heat output whereas nuclear stations are normally operated inflexibly at full output for economic, if not technical reasons. In future decades very large scale renewables (with or without a marginal nuclear contribution) would, for most of each year be supplying more than the daily variations of electricity demand. The excess power would be used to heat water (most UK energy use is for heating and hot water in buildings). Again extensive CHP 'piped-heat' networks (eg the city-wide CHP network in Odense, Denmark), along with hot water storage tanks (large and small), would be highly useful if not necessary to deliver the amount of energy needed to a given location at the time required. As CHP schemes and their long-lasting piped-heat networks are complimentary to renewables in both the short and longer term this is yet another

reason CHP should be built as a matter of priority.

3.3 Several GW of additional continental interconnectors will also be included in major offshore wind schemes (eg Airtricity's proposed 5 GW UK-Netherlands link via a 10 GW offshore windfarm proposal in the southern North Sea). This would add to the 2 GW link to France and the proposed 1 GW 'BritNed' link to the Netherlands. Various storage technologies are under development also. So it is difficult to assess what back-up generating capacity or 'plant-margin' may be necessary beyond 2020.

4 Combined Heat and Power (CHP)

4.1 CHP schemes are needed to efficiently burn sustainable biomass resources and other fuels for 'baseload' electricity supply and to supply hot water for space heating and various consumer uses. Modern CHP technologies and city-wide 'piped-heat' networks can be around 80% or more efficient in fuel use. This is significantly more than about 50% for new electricity-only CCGT schemes and about 45% for new coal/biomass schemes.

4.2 CHP can help 'load-follow' large scale renewables. When renewable output falls below the daily variations in electricity demand CHP electricity output would be turned up, and when renewable output exceeds demand the excess electricity can be used to heat water for storage and distribution on demand as hot water via piped-heat networks to buildings. Typical energy supply to the existing UK housing stock is roughly 4,000 kWh/year of electricity and 16,000 kWh/year heat. CHP fuels could include imported gas, biomass, coal, renewable methane, methane from coal, and synthetic hydrocarbons (eg methanol produced in deserts using plentiful 'concentrated' solar power 'CSP').

4.3 In Denmark about 50 % of electricity generation is from CHP schemes, in the UK it is about 6 %, one of the lowest in Europe. If the UK Government is serious about energy security and reducing gas and oil imports it needs to get serious about CHP which is very fuel-efficient. Yet CHP was hardly mentioned in the recent nuclear consultations and is discriminated against in DBERR's computer (MARKAL) model assumptions.

4.4 Concerted CHP construction could start this year, so preserving UK North Sea and Norwegian gas resources until renewables can take the strain. Such high efficiency, versatile 'multi-fuel' baseload CHP capacity (from large industrial schemes, to 11 kV sub station CHP engines, to micro CHP devices) would need to be built at scale anyway to compliment large scale 'variable' renewables in future decades.

4.5 In October 2007 a DEFRA report 'Analysis for UK Potential for Combined Heat and Power' estimated 123 TWh/year of electricity generating potential (at a 6% discount rate), which would also supply 150 TWh/year of hot water to the heat sector (homes, offices and industry) thereby saving up to 100 TWh/year of Primary Energy Supply (Table 7, page 21). This 100 TWh/year energy saving potential would primarily be gas, reducing import dependency.

4.6 The DEFRA report also estimated a UK CHP potential of 33 GWe (at a 3.5% discount rate) generating 190 TWh/year of electricity and 230 TWh/year of heat. Such high capacity (420 TWh/year or 21 - 27% of possible future UK energy consumption) could become cost-effective at higher discount rates as fuel and carbon prices rise. 33 GWe of CHP potential could, at a build rate of 1.5 GWe per year, be built by around 2030.

4.7 If CHP pipe infrastructure, which may last 100+ years, is supported by a low government discount rate (eg 3.5 - 6% instead of a typical commercial rate of 8 - 12% to acknowledge CHP's energy security, emission and social benefits) then consumer bills may be stabilised or reduced too.

5 Effects of a new nuclear programme

5.1 Up to 2020, all other things being equal in terms of renewables scale up and demand side efficiency, about 1 - 5 GW of new nuclear programme might have been built (generating 8 - 40 TWh/year in 2020) in the Government's pro-nuclear scenario. This would displace at most 6 GWe of CHP by 2020 (6 GWe CHP at 75% load factor = 5 GW nuclear at 90% = 40 TWh/year in 2020). This assumes that Government were not to consent any more medium efficiency CCGTs or several GW of large, high CO2 emission, 'centralised' coal fired power stations (there is as yet no certainty that significant CCS would be viable or fitted).

5.2 So, a 10 GW new nuclear programme would probably only delay the building of about 0 - 6 GWe of CHP capacity before 2020, and probably avoid the building of 40 TWh/year's worth of renewables (eg 12 GW of offshore wind) between 2020 and 2025, rising to 80 TWh/year's worth of renewables (eg 25 GW of offshore wind) by around 2030 as CHP construction catches up.

5.3 Consequently, any differences in overall gas imports between 2010 - 2020, or even gas imports between 2017 - 2020 and beyond would be hard to identify between the Government's nuclear vision and alternative  renewables/CHP scenarios. This is especially so if more CCGT's are consented. If new coal capacity is consented to reduce gas dependency then it too should be coal-fired CHP, and if CCS is demonstrated to be viable (2017 ?) it could then be retro-fitted with CCS.

5.4 There is no certainty that any significant new nuclear capacity would be

operational before 2020. All the new reactor designs under consideration by the UK government are untested prototypes. There are no operational schemes worldwide though one of the new designs (an 'EPR') is under construction in Finland. Consequently, delivery could be subject to various delays including construction. The scheme in Finland is currently reported to be over 2 years behind schedule just 2.5 years into its original 4 year construction programme.

6 National security, ethical and leadership considerations

6.1 In addition to the technical and energy security issues considerable UK political capital would be lost in the 'war on terror'/ 'battle for hearts and minds' due to the national security consequences of the promotion of a new nuclear programme.

6.2 There are foreign policy issues (proliferation, nuclear hypocrisy - in view of Iran) as well as increased vulnerability to terrorism (especially tit-for-tat retaliation following any military strikes on Iran/rogue states by UK friendly US and Israel). Also there are major ethical reasons for avoiding new nuclear build when non-nuclear alternatives are available in terms of long term toxic waste generation.

6.3 Globally nuclear power only generates 3 % of global final energy consumption. To maintain let alone increase this marginal contribution, considering the increase in global energy consumption (IEA forecast 60% by 2030) and limited higher grade uranium resources, would lead to problems. Increased global use of uranium-fueled nuclear technologies would have adverse implications for securing uranium fuel imports as competition for reliable supplies of high grade uranium ores increased, if new deposits were not discovered. If lower grade ores are used then the carbon footprint of the fuel imports could rise substantially due to the additional energy needed for mining and manufacturing the fuel. Such issues would undermine the Government's whole rationale for nuclear power, energy security and emission reductions. Worse, limitations on uranium resources may result in a move to even more dangerous 'breeder' technologies and a 'plutonium economy', or untested and problematic thorium technologies.

6.4 Earth has vast cost-competitive renewable resources, particularly solar power in the sun-belt regions and wind resources in remoter and offshore areas. So the relatively prosperous developed world countries, particularly the UK, should show global leadership by developing and promoting safe and sustainable renewable technologies, not inherently dangerous, complex and polluting nuclear technologies.

7 Longer term considerations

7.1 Ministers have suggested that 40% (20 GW) of 'power' (electricity) might

eventually be generated by nuclear power, presumably some time beyond

2030. Others say up to 30 GW of nuclear capacity might be built. Yet, even '40 %' or 20 GW of nuclear capacity (generating 160 TWh/year) would still only contribute about 8 - 10 % of future UK energy consumption (electricity/vehicle power and heat) *.

7.2 The remaining 90+% of energy would still have to come from indigenous

renewables (particularly offshore wind), imported renewables (eg CSP by HVDC grid links or green methanol), CHP capacity (possibly with CCS) and possibly centralised fossil fuels with CCS.

7.3 Similarly, 30 GW would only supply 12 - 15 %. Yet, even within the next decade innovations and cost reductions in renewable technologies (particularly offshore wind, wave, solar PV and CSP imports) may well render such longer term nuclear visions redundant before any new nuclear power stations were built. Meanwhile, for several decades, there is plenty of offshore wind to be getting on with. The UK has a major offshore wind resource and the Government's recent 33 GW by 2020 target is welcomed. The UK should now invest in developing new offshore wind technologies, for example, the British designed vertical axis multi-megawatt 'aerogenerator' turbine.

8 Summary - filling the so called 'generating gap' - without nuclear power

There is no low-carbon 'generating gap' in any reasonable non nuclear future

energy scenario. Yet ministers repeatedly speak about a 'generating gap' in the media and strongly imply that if nuclear stations were not built that either the 'lights would go out', and or that gas import dependency would be significantly higher, and or climate targets would not be met. Such messages to the public do not withstand scrutiny. Building only renewable and CHP generating capacity from now is the quickest way to reduce gas import dependency, deliver energy security, achieve future CO2 emission targets, and compliment substantial indigenous renewable energy flows in future decades.

* Note on 'final’ energy consumption, 'primary energy supply’ and efficiency :

In 2006, UK Primary Energy Supply (coal, oil, gas, uranium, biomass, etc before thermal conversion and other losses) was about 2,900 TWh/year. After conversion in power stations and other losses UK 'final' (useful) energy consumption was almost exactly 2,000 TWh/year, about 70% of primary supply Concerted efficiency programmes (demand and supply side) and new technologies across all sectors, together with lifestyle changes, may possibly reduce final consumption by 20% towards 1,600 TWh/year (this 'guestimate' allows estimates of % contributions for various future technologies/scenarios to be made in this briefing for comparative purposes) If final energy consumption were to fall by 20% to around 1,600 TWh/year and CHP,rather than centralised generation, was predominant (ie much lower conversion and transmission losses) then, depending on transport sector efficiency, Primary Energy Supply may fall by just over 30% to around 2,000 TWh/year.

Written by Neil Crumpton, energy / nuclear campaigner, Friends of the Earth (England, Wales & Northern Ireland)
January 2008