Our Energy Challenge
Response of the Ramblers’ Association to the UK Government Energy Review
April 2006
1. We welcome this review of UK Government energy policy. It provides a major opportunity for tackling problems of climate change, as caused by carbon emissions. We also hope that it will help to resolve some serious problems in the relationship between UK energy policy and the safeguarding of the British landscape.
Preamble
2. The Ramblers’ Association is a voluntary organisation founded in 1935 whose primary objectives are to act as the representative voice for walkers, and the protection of the outdoor environment and maintenance of its long-term health and sustainability. We have approximately 140,000 individual members as well as the members of affiliated clubs and societies. We cater for all abilities and seek to involve people of all ages, races and creeds in our work. The Association believes that it is the largest single organisation representing walkers in the UK and therefore campaigns to protect the countryside to ensure that it is maintained for all to enjoy.
3. As an environmental organisation, we support the promotion of the sustainable use of energy, and in particular, support energy technologies which are not environmentally damaging. However, given the landscape and visual impact of some renewable technologies, we would support a careful and responsible attitude to their development which takes other environmental issues into consideration, as well as carbon abatement. The views of the Ramblers’ Association in relation to the Review of UK Energy Policy can be summarised as follows:
4. We recognise the leading role that the UK Government has played in drawing international attention to the problems arising from climate change. Equally important is the opportunity within the UK to develop a very wide range of energy generation systems. This needs to be combined with a massive improvement in the way that we use energy, investing in energy efficiency and conservation, as well as in demand reduction. All must be set within a context that recognises the values inherent in the British landscape, ensuring that these are cherished, not despoiled. By changing its current approach the UK Government will be able to demonstrate to many other countries that climate change can be tackled successfully in ways which are sensitive to the widest range of environmental and community interests.
Demand-side reduction and energy efficiency
5. We support recommendations on energy saving and the need to reduce demand on the national grid. We agree that this is essential and policies focussing on energy conservation across all sectors (electricity, heat and transport fuels) is perhaps the most cost effective way of meeting the Government’s obligations to cut green house gas emissions.
6. The UK Government and the Devolved Administrations have a key role in setting Building Regulations. These Regulations should be adjusted to ensure that we have the highest European standards of insulation and energy efficiency in new and refurbished buildings, coupled with inclusion of microgeneration technologies.
Renewable energy technologies
7. We strongly support the increased development of renewable energy systems as part of new generation capacity. Unfortunately present Government policy is excessively focussed on supporting renewables through large scale, land based windfarms. This is leading to the industrialisation of the landscape in many parts of Britain and is eroding public support for the development of renewable energy systems. New incentives are needed to provide an entirely different basis for encouraging wind turbine development, with preference given to small scale developments on land, primarily designed for meeting local energy needs. They should be small in scale and in fields and on roofs, not in the hills, with large scale wind developments only favoured in locations that are well offshore.
8. Increasing the contribution to overall energy supply from renewable technologies is desirable, but care must be taken to avoid focussing on any one technology. A diverse range of technologies is required with more investment needed for microgeneration and biomass technologies, along with offshore and marine technologies. This may also include Combined Heat and Power systems, which can be more efficient than conventional heating systems. In addition to improved financial incentives, there is a strong case for encouraging small-scale developments through redefining the Permitted Development Rights in the planning system.
Bulk Electricity Generation
9. We welcome the further development of carbon capture and storage technologies for removing the carbon dioxide generated by the burning of fossil fuels such as coal and gas. This, combined with the expansion of biomass, hydrogen and tidal generation systems, should provide for the base load generation required in addition to the intermittent energy sources based on wind, solar and wave. However, caution must be exercised in any development of coalfields to avoid leaving a legacy of damaged landscapes through spoil heaps from mining operations.
10. Nuclear power is one of a range of possible energy supply options, but we have a number of concerns including waste management and storage, and radio-active contamination.
Transmission and distribution issues
11. We consider that there is a requirement for a radical reappraisal of what is needed in terms of future national grid development. In particular we feel that there should be more emphasis given to the generation of renewable energy close to centres of demand. Where long distance transmission is required, priorities need to be adjusted to provide for transmission by sub sea cable (from offshore windfarms, wave and tidal systems) to landfalls near where power is required, in order to reduce the impact of large pylons in the countryside.
Future Policy Direction
12. There is a requirement for a UK level forum to be established to discuss the development of energy policy, with representation of all stakeholders, including the full range of environmental interests as well as local community and local authority interest. This forum should have a major role in influencing the development of Government energy policy.
Specific Issues raised by the Energy Review Consultation
Q1. What could the government do on the demand or supply side to ensure that the UK’s long-term goal of reducing carbon emissions is met?
13. We believe that action on the demand side is the way forward for a sustainable future. There needs to be a long-term focus on energy saving. Increasing demand, year on year, will require more energy generators to produce power for that increased demand. This may make emissions reduction more difficult to achieve.
14. Demand reduction will require active management as there have been anecdotal reports of people who take energy saving measures indulging in “comfort-taking” by turning up their heating, leaving lights on, etc. because they perceive that they are saving money, therefore they can now afford to use more power. There is evidence that major utilities may inadvertently encourage this, for example, there is a company promoting new, energy-efficient condensing boilers, then undoing the benefits of energy efficiency by informing potential customers that they can enjoy plenty of hot water around the clock, so they can have as many hot baths as they like! This sort of marketing approach is unhelpful if carbon abatement is the issue. Government must therefore take an active role in effective demand reduction measures.
15. Increasing reliance on renewable energy sources will help to reduce greenhouse gas emissions, but currently attention is focussed upon on-shore wind as the Renewables Obligation is promoting the lowest-cost renewable technology, irrespective of its merits or demerits. Pursuing this strategy will result in increasing numbers of very tall wind turbines on hills, predominantly in Scotland, Wales and the north and south-west of England.
16. We are extremely concerned about the visual impact on some of our most scenic areas if this course of action is pursued. The size of modern wind turbine generators makes it very difficult to accommodate them into the landscape, and our landscape is one of our major national assets. In addition, increased transmission capacity will then be needed to transport this power to centres of demand when these wind turbines are generating electricity.
17. Planning laws in the UK generally afford protection to the rural landscape from domestic or commercial developments. Damaging upland landscapes through extensive heavy engineering projects for a short-term effect must be regarded as inappropriate as upland habitats are often sensitive to change and slow to recover, displaying a lasting legacy of visual scars.
18. It is inevitable that some large commercial renewable energy developments will be required to contribute low-carbon electricity generation to meet Government targets. These can be based more on offshore renewable energy development, through wind, wave or tidal provisions. Offshore wind turbines are more efficient at generating electricity than onshore turbine developments, and the visual impact is much reduced if installations are sited well offshore. Such off-shore developments must be subject to an Environmental Impact Assessment (EIA) to avoid potentially damaging environmental impacts.
19. There is an inability of some renewable technologies, like onshore wind, to deliver reliable and predictable quantities of power on demand due to dependence on the vagaries of the weather. This technology may replace electricity produced by high-carbon means on a kilowatt for kilowatt basis when the wind is blowing within the required parameters for turbine operation, but will require conventional generation to supply power when turbines are unable to operate. Conventional fossil fuel generators fitted with carbon capture and sequestration technology must therefore be an essential part of the electricity generating mix.
20. With regard to transport there needs to be more investment and support for sustainable transport initiatives in preference to increasing road capacity and domestic aviation developments. In addition, there is a requirement to improve the provision and quality of routes for walking and cycling to offer alternatives to motorised transport for short distance journeys. Reducing the fossil carbon content of transport fuel and increasing the fuel efficiency of vehicles is necessary, but it is not enough on its own, and links must be made with other government departments and agencies across the transport sector to offer alternative lower-carbon means of travelling.
Q2. With the UK becoming a net energy importer....What steps should the government take to develop our market framework for delivering reliable energy supplies?
21. Renewable energy technologies which deliver more ‘firm’ generation potential (generation with a high degree of predictability and therefore reliability) need much more support and investment. The Renewables Obligation needs to be radically changed to encourage a more diverse range of technologies to be developed and to reduce over-dependence on any one renewable technology.
Q3. Particular considerations that should apply to nuclear...including long-term liabilities and waste management.
22. The Ramblers’ Association’s position has always been that of acknowledging that nuclear power is one of a range of possible energy supply options, but that we have a number of concerns including waste management and storage, and radio-active contamination.
Q4. Considerations that should apply to carbon abatement and other low-carbon technologies?
23. Each low-carbon energy technology has its own range of potential impacts, environmentally, socially and economically. Over-emphasis on any one technology will proportionately increase the impacts of this form of energy generation, whether the direct impact from generation, or the ancillary impacts from fuel supply or waste management. An energy strategy is required that identifies an energy mix required to meet emission reduction targets, and minimise potentially adverse impacts from energy generation. This is an important measure which should address all sectors, not merely electricity generation.
24. If pursuing a “clean coal” option as an essential part of the generating mix, then caution must be exercised in developing coal extraction unless adequate protection is guaranteed against potential adverse environmental impacts to landscape, biodiversity and social amenity including public access. This particularly concerns open cast extraction, which may have severe impacts both within and well outside the operational boundary for prolonged duration, therefore sensitive working practice with adequate reinstatement and aftercare needs to be guaranteed through planning guidance.
25. An increase in biomass and biofuel production could bring many benefits, but there are difficulties associated with this which will need careful management; short rotation coppice, for example, raises questions on environmental and landscape grounds about large-scale monocultures. Woody biomass initiatives would benefit from coming under forestry guidelines and accreditation to alleviate potential adverse impacts.
Q5. Further steps...toward meeting the government’s goal that every home is adequately and affordably heated.
26. Revision of the standards within Building Regulations is essential in order to reduce the emissions from new-build and refurbished buildings for decades to come. The highest European standards in insulation and energy efficiency, including design for passive solar gain, are needed now in order to demonstrate the UK commitment to tackling carbon emissions. There is an opportunity to incorporate renewable microgeneration technologies in new build housing, such as ground-source heat pumps, solar technologies, and micro-wind turbines. Removal of barriers for microgenerators selling surplus electricity to the national grid must be a priority in order to help stimulate uptake. Smart metering which also indicates to consumers how much power they are using at any one time may help in reducing the demand.
Comments on other issues
Implications for transmission and distribution networks in electricity and gas.
27. Realignment of energy generation throughout the country will inevitably involve changes to the electricity transmission and distribution networks. There would be advantages in undertaking a Strategic Environmental Assessment of potential network changes to make clear the impacts associated with accommodating an increasing amount of renewable energy generators, both onshore and offshore. There is sense in promoting a policy of ‘local generation for local demand’ as this will reduce need for long-distance transmission lines and associated loss of power through transmitting electricity over long distances.
28. Where new long-distance transmission has to be provided it may best be served by connecting energy sources that supply substantial amounts of power in as reliable and continuous a way as possible. The benefits of reliable power supply would go some way to offset environmental impacts associated with powerlines. Consideration should be given to sub-sea connections for marine and offshore generators, taking power close to where it is needed, not through new overland connections. Undergrounding of overland connections would be beneficial where there would be a visual impact on the landscape, and where habitats would not be sensitive to disruption. Similar principles should apply to new gas pipelines if required.
The need for a strategic view
29. To remove uncertainty in the electricity market about how society should meet its energy needs, a strategic plan for renewable energy development is needed in order to identify how much wind based renewable energy is likely to be required in a future suite of renewable technologies and to what extent this is to be based on offshore or onshore wind turbine development. The plan should include, in relation to onshore development, the contribution expected from turbines located on private and public buildings, located around farm and croft buildings and from small scale community based developments. The effects of necessary changes to electricity transmission and distribution networks would be a component of this strategic look at generating and moving electricity around.
30. A national forum to discuss the development of renewable energy would ensure that a strategic policy is well received, with representation of all stakeholders, including the full range of environmental interests as well as local community and local authority interests.