Thursday, 31st December 2009
Energy Efficiency Action Plan for Scotland Consultation
Introduction
Energy is rightly recognised by both the Scottish Government and the European Union as a key sector to boost economic potential and to increase productivity and competitiveness. The EU climate change and renewable energy package adopted in December 2008 set an ambitious target for cutting European greenhouse gas emissions by at least 20% of 1990 levels, increasing the use of renewable energy sources to 20% of Europe’s total energy production, while cutting energy production by 20% of projected 2020 levels by improving energy efficiency. With exactly a decade to achieve these goals, the proposed action plan is an exceptional opportunity for Scotland’s energy needs and ambitions.
The new energy plan for Scotland needs to include a comprehensive mix of proposals which complement our climate change targets. This can best be achieved by focusing on energy efficiency and reducing CO2 emissions by encouraging investment into new research and development, as well as creating a new market for energy efficient products, processes and services in Scotland.
Low-carbon alternatives
a) Marine energy production
Scotland’s current energy mix of 50% coal and gas, 26% nuclear and 24% renewables including hydropower, leaves little room to displace our over-reliance on high-CO2 emitting coal and gas sources of energy. We need to explore alternatives to onshore windpower, which, in the current regrettable absence of new nuclear plant, requires base-load backup provided mostly by oil and gas. There needs to be a determined effort to move towards offshore wind, wave and tidal energy production, thus developing Scotland’s marine energy potential. However, the successful exploitation of marine energy is currently perhaps as much as two decades away and needs to be sufficiently encouraged by a new subsidy regime.
b) Planning and zoning for renewables
As an energy-rich country, Scotland has vast renewable energy resources and significant potential for their development. EU Directive 2009/28/EC, as adopted in April 2009, gives a further impetus for developing renewable energy resources by setting mandatory national targets for renewable energy share, supporting co-operation between member states and third countries and creating a sustainability regime for biofuels.
However, the construction of non-carbon-emitting renewable projects, such as windfarms, has to take into account the natural environmental and ecosystem services dimension and preserve our unique landscape for future generations. The Scottish Government must work with Scotland’s local authorities to co-ordinate the zoned planning of renewable energy projects throughout the country, clearly designating those sites where renewable projects would be welcomed and equally clearly indicating those sites where no planning applications would be entertained. The lack of such centralised and co-ordinated planning currently has led to a wave of ad hoc applications, particularly for windfarms, many of which are focused on entirely inappropriate sites, either due to landscape impact, or due to the disruption or destruction of ecosystem services like peat bogs and forestry.
Industrial-scale development on sensitive, slow-growing and unique environments is wholly inappropriate. Scotland’s distinctive peatland reserves, for example, with carbon storage capacity greater than tropical rainforests, must be preserved and protected, not earmarked for windfarm development.
The inappropriate siting of renewable projects creates a crucial threat to Scotland’s biodiversity and ecosystem services. EU legislation foresees that all renewable energy development must comply with the following:
- SEA Directive
- EIA Directive
- Habitats and Birds Directives
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In this regard, renewable energy development should be carried out in a sustainable way that does not threaten biodiversity or sensitive areas of environmental importance.
Scotland’s ecosystem would be best protected through a balanced spatial planning strategy for siting renewable projects, avoiding fragile biodiversity, rich ecosystems, forestry and peatlands. A full cycle assessment of the impacts of a planned development should be used to measure the energy productivity of a project and help to develop Scotland’s renewable energy potential through a pragmatic and sustainable approach.
c) Nuclear
A new energy mix for Scotland can not, at any cost, exclude nuclear power. As a traditional net exporter of energy, Scotland may, for the first time in history, be facing an energy gap and the need, ironically, to import nuclear generated electricity from England. Nuclear energy currently generates 16% of the world’s electricity needs and 32% of electricity in Europe. Nuclear power is one of the lowest carbon emitting energy sources, unmatched not only by coal and gas, but also hydro and wind power. New plants have the capacity to deliver in time to meet the EU wide greenhouse gas reduction targets by 2020.
The nuclear sector in Scotland currently employs a workforce of 4,600 and supports a further 9,200 jobs indirectly. It is central to the local economy in a number of regions. The Scottish Government’s opposition to nuclear power plants in Scotland runs counter to the UK Government’s approval for up to ten new nuclear plants in England and Wales. In Scotland, 26% of electricity is currently provided by nuclear power. The new Energy Efficiency Action plan needs to recognise nuclear energy’s contribution to a low-carbon energy mix and set a process towards the long-term storage of nuclear waste.
Conclusion
Scotland’s enormous natural energy resources in coal and gas and immense renewable energy potential, have a key role to play in developing economic growth and increasing competitiveness, while meeting ambitious CO2 reduction targets. The Energy Efficiency Action plan needs to address these issues from an environmentally sustainable perspective through a spatial planning strategy for renewable energy development, a life-cycle assessment of impacts and better enforcement of environmental controls in line with EU guidelines. The immense marine resources around Scotland’s coast offer significant potential and should be encouraged by a new subsidy regime.
Nuclear power is amongst the lowest carbon emitting and sustainable energy power sources, currently supporting local economies and a skilled work-force in Scotland. Ambitious EU climate change and renewable targets can best be achieved through supporting this source and focusing on a process for nuclear waste management in Scotland. A balanced and innovative combination of clean coal, natural gas, renewable and nuclear energy offers the only sustainable energy mix for Scotland today and in the future.
