Dear Sir or Madam,
Consultation Response - Renewable Energy Strategy
I am writing to present the LARAC response to the Renewable Energy Strategy Consultation, which is contained below, and I thank you for the opportunity to respond to the above consultation.
The comments below are sent on behalf of the Local Authority Recycling Advisory Committee (LARAC). LARAC is an association of well over 400 local authorities across England, Scotland Wales and Northern Irelandwhose waste management and recycling professionals’ co-ordinate and operate waste management services. Membership is drawn from all types of authority including statutory Waste Collection (WCA), Waste Disposal (WDA) and Unitary.
Overall LARAC welcomes the proposals supporting renewable energy generation.LARAC generally acknowledges the waste hierarchy as a guiding principle, with preference given to closed loop recycling when technically feasible over energy from waste. Variations from this principlemay be accepted after an environmental analysis, including energy efficiencies, carbon efficiencies and emissions shows that incineration is a better option. Which waste management process is the best practicable environmental option for a Local Authority is dependent on many factors, and although LARAC agrees energy generating opportunities should be considered, it would not support an overly prescriptive strategy. LARAC also draws attention to the fact that waste minimisation, including re-use, can generate significant energy and resource savings, and should be strongly encouraged.Overleaf are our detailed comments as requested in the consultation.
If you have any queries on this response or would like to discuss the matter further then please contact me on 01786 850326 or .
Yours faithfully,
Karin Helwig
LARAC Policy Team
Consultation Response – Renewable Energy Strategy
Chapter 1 Renewables and the Energy and Climate Challenge
Q1 How might we design policies to meet the 2020 Renewable Energy Targets that give enough certainty to businesses but allow flexibility to change the level of ambition for a sector or the level of financial incentive as new information emerges?
Policies must be designed that leave no doubt about what is considered to be Renewable Energy, about what conditions must be satisfied (for example concerning efficiency of conversion of renewable material or waste into energy, standards that must be met and certification of sources); and the minimum price/value of carbon. The Government must establish a base-line above which further policies and instruments may provide for additional incentives as new technologies emerge or better information becomes available, but which do not increase the level of risk to organizations investing in renewable technologies and processes in the near future.
Q2 To what extent should we be open to the idea of meeting some of our renewable energy target through deployment in other countries?
This should be a short-term measure only, and linked to international agreements setting targets for greenhouse gas reductions. Policies must have the long term intention and effect (after 2015 at the latest) of making the UK independent on measures implemented elsewhere in the World to achieve targets for reductions in emissions of greenhouse gasses.
Chapter 2 Saving Energy
Q3 In the light of the EU renewable energy target, where should we focus further action on energy efficiency and what, if any, additional, policies or measures would deliver the most cost-effective savings?
LARAC would draw attention to waste minimisation, both in production processes and in the household, as a way to save energy and resources.
Chapter 3 Centralised Electricity
Q4 Are our assessments of the potential of different renewable electricity technologies correct?
LARAC would like to point out paragraph 3.2.10 on biomass is incorrect, and finds it lacking in detail. It lists “sewage gas (the biodegradable portion of municipal solid waste),…”. LARAC suggests that sewage gas is not biomass but biogas and would like to see the distinction made. Clearly the section in brackets does not describe sewage gas. LARAC finds it important to distinguish between the different processes, as well as the different feedstocks, and feels the more detailed analysis given in Chapter 7 is not adequately represented in this paragraph.
LARAC would like to comment that Chapter 3.3 -3.7 in particular are focussed on wind energy. It is not always clear whether renewable generation in general, or wind energy in particular is meant. The issues covered, planning, community benefits, and regulatory frameworks respectively, are relevant to other renewable energy projects as well but are insufficiently covered for installations other than wind. It should also be acknowledged that the constraint covered in 3.6, of limitations in the electricity transmission network, does not generally apply to energy from waste, which can be generated much closer to conurbations. The Renewable Energy Strategy must also address the necessary development of infrastructure to transmit energy as heat (for example hot water) as well as electricity.
Q5 What more could the Government or other parties do to enable the planning system to facilitate renewable deployment?
Clear guidance is required to explain what criteria are to be applied for projects to classify as “Projects for Renewable Energy” and as such benefit from a favourable planning regime. For certain waste management projects the production of energy is not a primary objective, albeit an intergrated one. In paragraph 3.3.3, it is stated that …”the time taken to reach decisions [on renewables projects] is comparable with other proposals accompanied by an EIA (…) such as for waste management”…; this statement does not acknowledge that modern waste management projects may also be renewable energy projects.
Waste is often produced in areas where electricity and heat are also required. Planning guidance could be further used to increase awareness that waste management installations with energy generation in these areas may save transport fuel and optimise the utilisation of heat.
Q6What more could the Government or other parties do to ensure community support for new renewable generation?
Paragraphs 3.4.2 - 3.4.4 are specific to wind energy. LARAC would like to see these paragraphs extended to waste management plants with energy generation, as such installations are frequently met by communities with the same negative perceptions as wind farms. LARAC would also welcome similar measures to those that have been made, and are further proposed, for wind energy, including a good practice ‘toolkit’ on community benefits, research into options for community ownership of energy from waste (in particular wood waste), and financial benefits for the community including community energy assets.
Q7 What more could the Government or other parties do to reduce the constraints on renewable wind power deployment arising from [other regulatory frameworks}?
LARAC does not wish to comment on this question, but would welcome a similar analysis of regulatory frameworks for energy generation though waste management.
Q8 Taking into account decisions already taken on the offshore transmission regime … grid issues
This question is not relevant to LARAC
Q9 What more could the Government or other parties do to reduce supply chain constraints on new renewables deployment?
In relation to energy from waste, policies that generally reduce business risk will help address supply chain constraints (refer to Q1)
Q10 Do you agree with our analysis on the importance of retaining the Renewables Obligation as our prime support mechanism for centralised renewable energy?
LARAC broadly agrees with the analysis.
Q11 What changes, if any, should we make to the RO in the light of the EU2020 renewable energy target?
LARAC supports the changes as proposed, including the extension beyond 2027, the increase removal of the cap, the introduction of banding and the improved stability of the ROC price. With regard to banding, LARAC suggests that the guiding principle needs to be the actual environmental benefit of the technology. Innovative technologies should receive additional support, but not necessarily through higher ROC banding - see further comments e.g. under Q35.
Q12 What if any changes are needed to the current electricity market regime to ensure that the proposed increase in renewables generation does not undermine security of electricity supplies, and how can greater flexibility and responsiveness be encouraged on the demand side?
LARAC does not feel qualified to comment on this point.
Chapter 4 Heat
Q13 Assuming financial support measures are in place, what more could the Government do to realise the full potential of renewable combined heat and power?
LARAC considers that, as plant will need to be installed close to heat demand, both public perceptions and the planning regime will be important factors in realising the potential of renewable CHP, especially in relation to residential developments. Further measures to this effect have been made under Q 5-7.
Q14 Are our assessments of the potential of renewable heat deployment correct?
LARAC does not feel qualified to comment on the assessment. It would, however, suggest that alongside micro-generation and large-scale plant, community-scale renewable heat generation should be considered.
Q15 Have we captured the key features of a Renewable Heat Incentive and a Renewable Heat Obligation as they would apply to the heat sector correctly? Would both of these schemes be workable and are there alternative ways of structuring the schemes to ensure they can operate effectively?
& Q16 Do you agree with our assessment that a Renewable Heat Incentive would work better in the heat market?
LARAC welcomes the proposals to introduce an RHI or RHO scheme and has no strong preference for either one.
Q17 What more could the Government or other parties do to encourage renewable heat deployment with regard to
1. Awareness raising
Small, local demonstration installations could be considered for domestic and community scale equipment
2. Air quality
Financial support such as the RHI or RHO should only be made available for installations with comply with certain environmental criteria, including efficiency and emissions.
3. Building Regulations / Planning
No comments
4. Anything else
- Recognize that the distribution of heat will entail substantial capital expenditure on new infrastructure – in many cases, the creation of a new utility - and develop policies that will ensure that projects are supported and business risks for investors reduced.
- Local Authorities could play a facilitating role in helping to identify new developments that could be linked into new heat distribution infrastructure
- Incentives for feedstock suppliers may be required, such as support for the drying installations for wood chips, to ensure the local feedstock is made available.
Q18 How far should the Government go in focusing on areas off the gas grid as offering the most potential for renewable heat technologies?
The development of new infrastructure for distributing heat will be sufficiently challenging anywhere that it will be unhelpful to limit it further to areas that aren’t connected to the gas grid.
Chapter 5 Distributed Energy
Q19 - Q23
These questions are not relevant to LARAC.
Chapter 6 Transport
Q24 How can we best incentivise renewable and low-carbon transport in a sustainable and cost effective way?
LARAC would welcome any measures leading to increased use of cooking oil as a feedstock for transport fuel, but in particular those that lead to local processing and use of such oil. A number of Community Enterprises have cooking oil processing facilities in the Scottish island communities. These communities tend to suffer relatively high levels of fuel-poverty. The projects are highly sustainable, saving transport of the waste oils, transport of fossil fuels, as well as the fossil fuels replaced, whilst providing relief from fuel poverty. LARAC would like to see additional support for such projects, whereby the total environmental benefits should be the guiding principle for the level of support.
Q25 - Q26 on Electric Vehicles
Not relevant to LARAC.
Chapter 7 Bioenergy
Q27 How can we best ensure our use of biomass is sustainable?
Standards and a system of certification must be agreed as early as possible. LARAC would suggest that CHP processes would be adequately incentivised through a Renewable Heat Incentive, and would therefore not require higher banding for ROCs than similar processes without CHP.
In relation to waste, the biologically active component of waste streams should be monitored to ensure that both the potential and the benefit of energy from waste is correctly assessed.
LARAC deems that overall environmental performance should be the guiding principle when incentivising or rewarding processes and technologies. This could include carbon efficiencies as well as energy efficiencies, whereby the transport of feedstock to the plant should be taken into account.
Q28 How do you see the market for biomass developing to 2020? What are the implications for imports and longer term prices and costs?
The availability of biomass from MSW sources, including mixed waste,and source-separated food and wood waste, is dependent on the cost of separate collection, the availability of markets and reprocessors, gatefees and price levels.
Q29 Should the government take further regulatory measures to discourage biomass waste, including food waste, from going to landfill? If so, which types? What, if any, other measures should be taken to encourage its use to generate bioenergy?
The Government should consider a long term measure of prohibiting the landfilling of biodegradable waste. In the shorter term LARAC would like to see regulatory measures such as the Landfill Allowance Trading Scheme extended to businesses, in particular the catering and construction sectors.
Q30 What more could the Government or other parties do to help to ensure the provision of sufficient Waste Incineration Directive-compliant combustion capacity to burn available waste wood alongside other biomass, and what else might constrain the development of this capacity?
Other than in small scale installations, waste wood should not be burnt in plants that aren’t highly efficient and designed to generate CHP. The capacity to burn waste wood is constrained mainly by planning issues and the capital costs of infrastructure needed to distribute heat. The Government should give priority to developing “end of waste” criteria and standards that enable fuels derived from wastes to be defined as products that don’t need to utilised in a WID-compliant plant.
Q31 What further actions will improve supply chain efficiency, consumer confidence and sustainable growth of the biomass supply chain?
LARAC has no further suggestions.
Q32 What barriers exist to the cost-effective deployment of anaerobic digestion, biogas and the use of biomethane injected directly into the gas grid, and what are the options to address them?
LARAC feels that the requirements for scrubbing should be set according to the expected ratio of biogas to natural gas. If only small percentages of biogas are present in the mix, the level of impurities in that biogas can be higher without having an adverse effect. New standards for mains gas should be established as quickly as possible taking this into account.
The further development of industry standards and markets for other products of AD and MBT processes would also aid the deployment of biogas.
Q33What action could we take to make biomass communications more effective to both improve public awareness and help to address acceptability issues, and how should this be delivered?
LARAC refers to its comments under Q6. It would also urge for a clear, consistent terminology to be deployed, to minimise confusion over biomass, biofuel, green waste, food waste, waste wood, forestry residue etc. Explanation of such terms in a Glossary of Terms would be helpful, particularly when communicating with the general public.
Q34 Are there issues constraining biomass supply and use other than sustainability, supply chain and information issues?
LARAC is not aware of further issues, other than planning as covered in previous chapters.
Chapter 8 Innovation
Q35 How can we adapt the Renewables Obligation to ensure that is effectively supports emerging as well as existing renewable technologies? Are there more effective ways of achieving this?
As ROC benefits are only available once the plant is producing energy, a certain risk remains with the developer as the output of new technologies may not be predicted accurately. R&D andCapital Grant funding are therefore appropriate forms of additional support.
Q36 Is there evidence that specific emerging renewable and associated technologies are not receiving an appropriate form of support?
& Q37 Are there barriers to the development of renewable and associated technologies that are not addressed by current of proposed support mechanisms?
LARAC has no comments on these issues.
Chapter 9 Business Benefits
Q38 What more could the Government or other parties do to ensure that the UK secures the maximum business and employment benefits?
LARAC’s only comment on this issue is that the Community Recycling Sector has managed some successful woodfuel and biodiesel projects, which have brought associated employment benefits.
Chapter 10 Wider Impacts
Q39 Do you agree with our analysis of the likely impacts of the proposed increase in renewable deployment on:
a. carbon dioxide emissions
b. the local environment
c. security of supply
d. the energy market
e. fuel poverty
f. the energy market
g. the economy
h. any other wider issues that we should be considering?
LARAC broadly agrees with the analysis in this Chapter and has no specific comments.
Chapter 11 Delivering the Target
Q40 What more could the Government or other parties do to ensure the UK meets the EU renewable energy targets?
In the role for Local Authorities in paragraph 11.3.2, acknowledgement should be made of the Local Authorities role in Waste Management.
Q41 Do you agree with our overall approach to developing a UK Renewable Energy Strategy?
LARAC refers to its comments on the covering page to this response.
LARAC, PO Box 28, Knighton, LD8 2WA
t.01544 267860 f.01544 267860 e.