Response to Our Energy Challenge: DTI Consultation, April 2006
 

About Scientists for Global Responsibility

Scientists for Global Responsibility (SGR) is an independent UK membership organisation of approximately 850 science, design and technology professionals. We work to ensure that science, design and technology contribute to social justice, environmental sustainability and the reduction of conflict. The issues raised by energy policy and as outlined in the consultation document obviously have strong links with these concerns.

Summary

Our main views and recommendations are:

• The government’s medium term aim in tackling climate change (being on track in 2020 towards a 60% reduction in greenhouse gas emissions by 2050) could be met through strong policies and measures to rapidly expand: diverse renewable energy sources (at range of scales); combined heat and power (CHP) systems (at a range of scales); real-time demand management systems for electricity; other cost-effective energy efficiency measures; and wider measures to reduce energy demand. To meet longer term climate commitments, other low-carbon technologies (eg carbon capture and storage) may be needed depending especially on the success of efforts to reduce energy demand. We do not see a need for nuclear power.
• Much higher priority should be given to energy conservation and efficiency in buildings (especially in existing buildings), road transport and aviation. The government should also enact strong policies to curb aviation greenhouse gas emissions (domestically and internationally) and prevent them undermining other improvements.
• Development of renewable energy sources and other low carbon technologies should be a much higher priority in government funding. At the moment a large proportion of government spending on R&D goes on military projects. We believe that diversion of funding and expertise from military activities to research, development and exploitation of sustainable energy technologies would lead to a real increase in security.
• UK energy policy should aim to encourage means of energy production which can be used globally with minimum risks and which would encourage countries which are rapidly developing to do so in ways which do not produce overwhelming amounts of greenhouse gases, and which reduce the pressures on the supplies of most limited fossil fuels.
• There are major uncertainties and serious long term risks associated with the economics of nuclear power, radioactive waste disposal, security of nuclear facilities and the nuclear fuel cycle. These, together with consideration of the alternatives, lead us to strongly advise against a new programme of nuclear power.
• As countries like China and India grow economically, there will be increasing competition for all limited resources, particularly energy resources. This is likely to drive up prices and will increase the potential for international conflict over these resources. The government must ensure that the infrastructure installed will move the UK towards greater self sufficiency to improve energy security.
• The proportion of renewable transport fuels required by the RTFO and the EU directive on transport fuels should be increased, and incentives given for the introduction of biofuels from cellulosics which could give greater output for a given energy input and land area than present liquid biofuels and which can be made from waste materials.
• Regarding carbon capture and storage (CCS) the government should commission independent and transparent assessments of the long term security of CO2 storage in relevant geological formations. If the risks are shown to be low, CCS should be considered as part of the UK longer term energy mix, after the maximum exploitation of energy efficiency measures and renewables. This should include coal-fuelled CCS systems, and where appropriate, incorporation in CHP systems.
• Involvement of the public in achieving a low carbon future is vital, and providing education and information to support this is a priority. This is particularly important in view of some lifestyle changes (eg in respect of unlimited low-cost flying) that are likely to be needed.

Main Response

This response begins with comment on the broad goals of UK energy policy, and then covers the specific questions raised in the consultation document followed by comments on the four other specific areas mentioned. Finally, it gives a view on some of the wider issues raised by the consultation document.

NB This response was largely written before the publication of the New Climate Change Programme (March 2006). We agree with the main points in this programme, but many of the proposed actions need to be undertaken on a larger scale. We particularly welcome the emphasis on involving the public in efforts to save energy.

Energy Policy Goals

We agree with three of the goals for energy policy set out in the 2003 Energy White Paper - maintaining the reliability of energy supplies, ensuring that every home can be affordably heated and achieving substantial reductions in CO2 emissions. However, in view of the recent indications on the speed of climate change, more rapid reductions in greenhouse gas emissions than the present UK targets may be needed.

We have reservations on the goal “To promote competitive markets in the UK and beyond, helping to raise the rate of sustainable economic growth and to improve our productivity”. It is not clear that competitive markets can always deliver the environmental and energy security goals which have to be considered over a long time-frame. Also, indefinite economic growth, at least as conventionally measured in terms of GDP, is unlikely to be compatible with long-term sustainability. Hence, energy policy should be specified in similar terms to the government’s sustainable development strategy, ie as having as one of its goals a strong, stable, sustainable economy. While we believe a high quality of life is compatible with greatly reduced greenhouse gas emissions, indefinite growth of GDP especially where an increasing proportion of economic activity is in road transport and aviation is highly unlikely to be sustainable.

Consultation Questions

Question 1. What more could the government do to on the demand or supply side for energy to ensure that the UK’s long term goal of reducing carbon emissions is met?

Q 1.1 Demand side

We believe the most urgent area for the government to tackle is to reduce energy demand, both by measures promoting energy conservation (ie reducing energy output demand) and energy efficiency (ie reducing primary energy input for a given level of energy service).

Q 1.1.1 Transport

Transport is a particular problem area where energy consumption and CO2 emissions are rising. The government should introduce policies that carry out the following.

• Promote genuinely integrated transport, so journeys can be easily made using the most appropriate transport mode or modes, providing readily accessible information.
• Plan land use to ensure facilities are convenient for centres of population and accessible by public transport.
• Encourage more tele-working and tele-conferencing
• Create more efficient rail links: a high speed rail route from south east to northern England and Scotland to make rail travel competitive with air travel on journeys up to 600 - 800km
• Create a North-South rail freight corridor (using underused existing lines where possible) to transfer more heavy freight onto the railways.
• Support urban public transport systems (buses, guided buses, trams, light rail) including unconventional eg the ULTra automated taxi system [1], first commercial application of this is at Heathrow airport.
• Ensure that where congestion charges are introduced, they do not reduce the incentive for more economical vehicles, for example if they were to be accompanied by a reduction in fuel duty.
• Ensure that speed limits are enforced - some time ago, the Association of Chief Police Officers said publicly that they would not normally prosecute drivers travelling at speeds up to 85mph - it is wrong for ACPO to decide not to enforce a law decided by parliament. The fuel consumption and CO2 emissions of cars at 85mph is significantly greater than at 70mph.
• Make the EU agreements with vehicle manufacturers on fuel efficiency and CO2 emissions mandatory and progressively more stringent, recognising that CO2 emissions of ~ 90gm/km could be achieved for European medium sized cars with developments over the next few years [2].
• Adopt policies which discourage the growth of air travel and cut back the plans for airport expansion. Studies by the Tyndall Centre at Manchester University indicate that if international aviation using UK airports are included, the UK’s total greenhouse gas emissions have increased since 1990 [3].
• Ensure aviation pays tax on its activities (pressing the International Civil Aviation Organisation and other relevant bodies to permit taxation of aviation fuel) to remove aviations unfair fiscal advantages. Noting that the radiative forcing of CO2 emissions at typical flying altitudes are up to three more times that of CO2 emissions at ground level, promote agreements which ensure the aviation industry bears the cost of these externalities. While continuing to press for aviation emissions to be included in the EU emissions trading scheme, recognise that if current predictions of global aviation growth were to occur, in three or four decades, aviation would use nearly all the atmosphere’s carrying capacity for greenhouse gases, so emissions trading alone has its limits. To ensure that appropriate charges and constraints can be levied on aviation, oppose any section in any “Open skies” agreement between the EU and the USA which would limit the ability of countries to take such action.
• In international negotiations, press for international aviation to be included in setting limits to countries’ greenhouse gas emissions under UNFCCC treaties to follow Kyoto.
• Improve people’s local and regional environments, to reduce the urge for ever more frequent and longer leisure journeys

Q 1.1.2 Residential

In this sector, the government should introduce policies that carry out the following. (There is some overlap in these recommendations with supply side measures.)

• Continue to increase the energy efficiency regulations for new buildings and ensure that upgrades of existing buildings include substantial improvements to efficiency. Incorporate requirements in the Building Regulations Part L that were omitted after completion of consultation relating to consequential improvements (to compensate for greater energy use due to building extensions), and impose requirements on conservatories at a lower size cut off than the present 30m².
• There have been many reports that buildings as constructed do not match the design intent (for example, insulation is often effectively bypassed by air flows where insulation does not provide a continuous boundary, and air tightness is often below standard. Therefore, place rigorous requirements on local authorities to ensure building regulations are met in practice.
• Ensure regulations take account of possible changes in climate over the life of the building. Thermal mass to even out temperatures between night and day is likely to be beneficial. To reduce the embodied energy in conventional bricks and blockwork, unfired clay blocks should be considered.
• Ensure that local authorities use fully powers in the Housing Health and Safety rating System (which comes into effect in April) and the Decent Homes standards to raise the energy efficiency of the huge stock of existing homes, much of which is very inefficient and is taking a long time to improve. Use these powers to make it mandatory that when a dwelling is sold, all cost effective energy efficiency measures are installed (eg full loft insulation, draught proofing, cavity wall insulation where applicable) and to make large scale improvements on housing of the lowest energy efficiency standards. Major improvements to old houses can be much cheaper if done on a large scale - in particular, external cladding of a large number of non-cavity wall houses, particularly terraces, in an area would be much cheaper than treating individual houses. This could minimise the demolition of very inefficient older houses which has been proposed, and save the embodied energy in making new bricks, blocks and concrete, as well as produce less disruption to residents and communities.
• In the private rented sector, which is a major problem as benefits from energy efficiency measures may not be recouped directly by the party paying for them, mandatory standards should be imposed for the energy efficiency of such properties, failing which the landlord would have to pay the tenant any cost for heating to achieve a reasonable temperature above that for an adequately insulated home.
• As a basic planning requirement, the orientation of new houses should be such that passive solar gains are optimised. Mandate the fitting of solar hot water panels on all new housing, unless there are specific reasons not to on particular buildings.
• On large new housing developments, require that the infrastructure to enable district heating from Combined Heat and Power (CHP) or other low-carbon sources to be installed (later, if not at the time of building).
• Ensure grant schemes and programmes for domestic renewable energy technologies/ microgeneration are expanded in terms of funding, timescale and geographical coverage. The current piecemeal support has led to some grant schemes being vastly oversubscribed and many smaller companies struggling.
• Make high standards of energy efficiency on appliances mandatory
• Publicise the major advances in low energy lights (CFLs) in terms of light quality, compactness and reduced cost. The promotion by one utility of very low priced CFLs is a good example aimed at increasing the public’s awareness of the merits of the latest CFLs.
• Make use of further options as recommended in studies such as “The 40% House” [4] which show that huge energy savings can be made in energy use in domestic buildings.

Q 1.1.3 Industry

Use the climate change levy to help to ensure that the technologies which have potential for significant energy savings are taken up, for example much more efficient electric motor drives particularly for pumps and fans by use of variable speed controls, and process integration to maximise heat recovery.

Q 1.1.4 Overall savings

By 2020, using the more cost effective measures in the “The 40% House” study and from other assessments (primarily much better insulation standards, efficient heating systems, more efficient lighting and appliances, micro-CHP and medium size CHP, solar hot water) and applying similar measures to buildings in the service sector, and from information available from industry on electric motors etc, cost effective savings of about 13MTe of carbon emissions per year are possible.

Q 1.2 Supply side

Q 1.2.1 Electricity generation

Through the renewables obligation and other mechanisms, the installation of a wide variety of renewable energy sources and CHP systems should be strongly promoted. A recent paper by the Sustainable Development Commission (SDC) [5] has provided a useful summary of analyses of low carbon pathways for the UK, especially highlighting the potential of a variety of renewable energy sources.

Some arguments have been put forward that the variable output of some renewable sources of electricity would severely limit the proportion of installed capacity that could be accommodated on the electricity grid system. Studies by the CEGB some time ago showed that the grid could accommodate up to about 20% of the generating capacity from variable renewables (eg wind) without significant problems. More recent studies have shown that introduction of a variety of renewable energy types plus some micro-generation and CHP on a range of scales would allow the electricity grid system to cater for systems with variable output up to a considerably greater total proportion of the electrical installed capacity. (The UK is particularly well placed to exploit tidal power, which, although variable, is fully predictable). The ability to cope with variable outputs could be increased further by the use of real time demand management where loads which can be interrupted for a time without problems (eg some heating and cooling loads with a long response time can be remotely or automatically switched off if there is an imbalance between supply and demand on the grid).

Micro-generation – especially using renewable energy technologies – should be given much greater support (see Q1.1.2 above).

There is also a strong need for the government to provide much better support for R&D into renewable energy technologies. Funds and expertise could be diverted from, for example, the currently very large military R&D programmes. According to Office of Science and Technology figures [6], military programmes receive nearly one-third of total government funds devoted to R&D - one hundred times more than that spent on all energy R&D.

If after such a wide mix of renewables and CHP has been fully exploited, there remains a need for further low carbon emission electricity sources not dependent on gas (for which we will be dependent on imports from potentially unstable sources, and which should be reserved as far as possible for heating purposes), then cleaner coal power stations (using gasification and/or carbon capture and storage, CCS) should be considered (see Q4 below).

Q 1.2.2 Transport

The proportion of bio-fuels for transport required by the EU directive and the renewable transport fuel obligation (RTFO) should be increased. The potential for biofuels should be viewed in a European context, given that the Kyoto Protocol target is for an EU “bubble” and the huge amount of additional productive potential brought in by the Central and Eastern European accession countries. The regulations should be made to ensure that all suitable set-aside area can be used for production of biofuels (whether for transport, heating or power production). Measures to increase biofuel use should exclude sources which endanger bio-diversity or food production in vulnerable countries. Regulations to ensure vehicles can use an increasing proportion of ethanol or bio-diesel should be introduced - noting for example that all major US manufacturers sell petrol vehicles that will run on 85% ethanol (E85), and that some manufacturers have introduced cars able to run on E85 in Europe. Sweden is aiming to move to a position where all road transport is powered from bio-fuels

The energy ratio of some currently used bio-fuels (derived from sugars, starches or oils) is not very favourable, so governments should give major support to programmes to develop liquid biofuels from cellulosics (eg the woody or fibrous part of plants) which can significantly increase the energy yield per hectare and improve the energy ratio, and also can make use of many waste products. Recently announced agreements between vehicle manufacturers and oil companies in association with chemical companies in North America and Europe show the huge potential - for example that cellulose ethanol largely from waste products from growing corn (maize) could meet 30% of North American gasoline consumption [7], and there are similar projects for bio-diesel [8]. It can be inferred from studies [9] that in many circumstances, biofuels can be competitive with petroleum based transport fuels at present crude oil prices.

While increased fossil fuel prices may provide an incentive within the UK towards a lower carbon economy, globally, there could be effects which go the other way. For example, the production of oil from tar sands in Canada is expanding with the present relatively high price of oil. This process is environmentally damaging and very energy inefficient (large amounts of gas being used in the extraction process) and thus has a high carbon footprint if CCS (see Q4 below) is not used. Similarly the Chinese are considering producing liquid transport fuels from coal, which in production releases large amounts of CO2 (again, if CCS is not used). The UK should aim to be a leader in the development of low emissions transport fuels and ultra efficient transport modes at a cost which diminishes the incentive for high carbon alternatives to oil and gas.

The UK government should monitor progress in developments of hydrogen as a transport fuel. However while in the long term, hydrogen may become a viable transport fuel, it must be recognised there are still major technological and practical problems to be resolved, and the benefits in terms of conservation of scarce fuels and greenhouse gas emissions depend very much on the energy source for producing the hydrogen. Some studies have indicated that making hydrogen from gas (seen as the most likely short term process in the USA) for use in fuel cell vehicles may not lead to significant overall energy savings or greenhouse gas reductions [10], at least if CCS is not used in the conversion process. Methanol derived from biomass used with on-board reformers on fuel cell vehicles to avoid the very difficult problems of on vehicle storage of hydrogen is a possible option. While hydrogen made by electrolysis could be a means of storing energy from variable renewables, we do not see such a surplus of renewables to make this a likely option before 2030.

Question 2. With the UK becoming a net energy importer and with big investments to be made over the next twenty years in generating capacity and networks, what further steps, if any, should the government take to develop our market framework for delivering reliable energy supplies? In particular we invite views on the implications of increased dependence on gas imports.

Q 2.1 Market framework

Competitive markets alone are unlikely be the best way of delivering an mix of generation and transmission facilities to meet national security and environmental goals over the very long timeframe relevant to major infrastructure projects. The tendency for commercial organisations will be to go for plant which can deliver a pay-back over a relatively short timescale and with minimal risk. Thus, combined cycle gas turbine (CCGT) power plants which are relatively low in capital cost appear favourable to commercial organisations in the short term, but these do not address the longer term strategic problems. Recent experience of huge fluctuations in wholesale gas prices (increasing by a factor of four over not much more than a day) shows that the market did not produce adequate gas storage in the UK. The government needs to develop mechanisms and structures to ensure that generating capacity and networks reflect the need for diversity, security and environmental constraints.

Q 2.2 Dependence on gas

Many expert analysts of the oil and gas industries globally believe that we are very close to the peak of oil production and will reach the global peak of gas production within about 15 years. Given the huge increase in demand from rapidly developing economies like India and China which can be supplied from the Russian and central Asian sources of gas, a large escalation of the price of gas can be expected. We believe the gas prices given in the tables in Annex C of the consultation document are quite speculative and likely to be too low for the period given (up to 2020) and even more so for the long term. The government should be prepared to give guarantees of price support to renewables and other acceptable non-gas low carbon electricity sources over a much longer timescale than the current renewables obligation. Only with a degree of certainty for an adequate timescale will the investment be made in a variety of technologies. The level of support should recognise, as well as the need to reduce greenhouse gas emissions, the benefits to the UK of energy security and to the balance of payments (which is likely to become of ever greater importance in a more competitive world).

The consultation document (p37) mentions the need for active diplomacy to help ensure continued and uninterrupted supplies of oil and gas from other countries. It must be observed that some foreign policy decisions in the last few years have resulted in antagonising the populations of many oil producing countries. Reducing dependence on limited supplies of oil and gas would help to reduce the causes of conflict, and this must be a high priority in government policy.

The expansion of combined heat and power (CHP) using different fuels should be a priority in reducing dependence on gas. While we agree with the current projects to diversify the sources for gas imports to the UK and in increasing the amount of gas storage capacity, gas should be seen as far as possible as a heating fuel rather than as a major fraction of the electricity generating mix, other than in CHP. Coal power stations utilising gasification and/or carbon capture and storage as well as being an alternative to gas in electricity generation could also provide heat if built as CHP plants supplying district heating on a large scale. Such power plants are likely to be more flexible in operation (able to match output with demand) than nuclear power stations which are used to best effect on base load, and the ability to store large quantities of coal make it more feasible to adjust output to suit seasonal changes in demand than for gas. Coal can be sourced from many countries and is less limited in energy reserves than other fossil fuels, and the ability to hold large stocks gives some security against possible supply interruptions.

Question 3. The energy white paper left open the option of nuclear new build. Are there particular consideration that should apply to nuclear as the government re-examines the issues bearing on new build, including long-term liabilities and waste management? If so, what are these, and how should the government address them?

The recent report from the Sustainable Development Commission (SDC) [11] highlighted the significant shortcomings associated with nuclear power and argued that other energy options were superior. We broadly agree with this. Here, we highlight our main concerns in particular regarding long term liabilities, waste management, and security.

Q 3.1 Nuclear long term liabilities and waste management

Regarding costs, an important principle is that the government should not directly or indirectly subsidise nuclear power. After fifty years of use, it is time this energy source stopped receiving financial or in-kind support from the state. However the unique characteristics of nuclear power mean that it is extremely hard to carry this out in practice. Ultimately, if the go-ahead for more nuclear power stations were given, the government would be obliged to underwrite risks associated with safety, security and long term waste management and hence be ready to bail out the industry if serious problems occur. Indeed the government has repeatedly had to do this throughout the history of the UK nuclear industry. The SDC report highlights this problem and argues that this leads to a real risk of the nuclear industry being over-optimistic in its economic assessments especially for the long term. Consequently such assessments should be treated with extreme caution.

The Royal Commission on Environmental Pollution stated in 1976 that no new nuclear programme should be started until the issues of radioactive waste disposal had been resolved, and this was reiterated in its 2000 report [12]. There remain significant issues both on the siting of any repository for intermediate level waste and on the final fate of high level waste, and the Chair of the Committee on Radioactive Waste Management which is due to report in the near future has indicated his committee will not fully resolve them.

For high level waste, a convincing assessment showing how very long lived nuclides behave and might migrate would be needed before any particular final disposal route could be considered as acceptable. In the long term, a means of transmuting the very long lived nuclides into fission products with half lives for which engineered storage could be reasonably assured might be developed. Such actinide “partitioning and transmutation” was studied in a number of countries some time ago, and there seems to be some revived interest in the USA now, but any total system of suitable reactors and fuel reprocessing would be some decades away, and such a fuel cycle could increase the risk of plutonium diversion.

In assessments of economic costs that will be borne in the distant future, these costs are financially “discounted” to the present time. Even at quite low discount rates, this process leads to a large reduction in the apparent costs of long term waste management and decommissioning - so that these costs are also virtually discounted in the everyday use of the term. The cost of long term liabilities will depend on the costs of energy, non-corroding metals and skilled technical effort required for final disposal, and these are difficult to assess for the very long term but are likely to rise in real terms. Even if a nuclear generating utility is made to pay into a fund for long term liabilities, in practice, the government will in effect underwrite the risks.

Q 3.2 Security issues

Nuclear proliferation and fissile materials diversion are important issues that need to be considered. Arguably the most important consequence of building new nuclear power stations in the UK is that nuclear power in “advanced” countries makes it much more difficult to persuade other countries which might be considered to have nuclear weapons ambitions not to develop their own nuclear power programme as a stepping stone. The current case of Iran is a clear example. The UK could help reduce the risks of proliferation and fissile material diversion by strengthening the Nuclear Non-Proliferation Treaty and the International Atomic Energy Agency by, along with other nuclear weapons states, fulfilling the obligations under the NPT to undertake disarmament of its own nuclear weapons.

Diversion of fissile material in the UK to non-state groups does not seem very likely, given the much easier targets of poorly safeguarded materials in the former Soviet Union. However, ceasing reprocessing in the THORP facility at Sellafield would be a useful precautionary step: there is no requirement for reprocessing in any new reactor programme. Negotiating a rapid end to contracts with Japan which involve long distance transport of plutonium would also reduce risks of diversion.

The security of reactors and other nuclear facilities and nuclear fuel transport in the face of terrorist threats must now be considered as a serious risk. While the first priority should be to greatly upgrade the security of Sellafield and other existing nuclear plants, further nuclear plants would increase this risk. These issues are discussed in more detail in a recent paper published by the Oxford Research Group [13] as well as in the SDC report mentioned earlier.

Q 3.3 Energy and carbon emission balance for nuclear power

Many articles on nuclear power have erroneously referred to it as carbon free (including the consultation document, on p56 it quotes the 2003 White Paper referring to nuclear as a “source of carbon free electricity”, although the carbon profile is recognised on p64). Although a relatively low carbon source of energy (at least while reasonably rich uranium ores are available), energy (with associated CO2 emissions) is used in the construction of nuclear reactors, in the enrichment of uranium, in eventual decommissioning and radioactive waste disposal, and in the process of uranium extraction for the ore. The current estimate of global uranium supply at reasonable costs and concentrations equivalent to 50 years at present levels of nuclear energy generation (plus, in the UK, some more fissile material from decommissioned weapons and nuclear plants). Unless further high grade resources are found, given the large increase in nuclear generation proposed by many countries (the World Nuclear Association [14] “reference case” for 2030 is an increase of installed capacity of about 50% relative to 2005), the actual time before uranium becomes scarce could be much less. As high grade ores become depleted, more energy is needed to extract the uranium from poorer ores, this energy being associated with its own carbon emissions. Given that any reactor for which planning were to start now would be expected to still be in operation in over fifty years time, there is concern that the total carbon emissions could be problematic. A number of countries are again looking at ‘fast’ (Generation IV) reactors as a way of greatly extending the fissile material base. However, commercialisation of such reactors (which is likely to decades in the future) with the currently conceived plutonium fuel cycle would greatly increase the risk of proliferation and diversion. While all means of producing energy require some energy input, many renewables (eg wind energy) have been shown to have very favourable energy ratios. Given the long lead time for any nuclear construction programme, major efforts at energy conservation and renewables would produce carbon savings sooner.

Question 4. Are there particular considerations that should apply to carbon abatement and other low carbon technologies?


 

Q 4.1 Efficiency improvements and carbon capture and storage

Carbon abatement technologies are generally understood to include increasing the efficiency of fossil fuel energy systems and carbon capture and storage (CCS).

Seeking improvements in the efficiency of fossil fuel electricity generation must be a high priority, together with a major expansion in the use of CHP on a scale much larger than currently proposed in the UK. This has been discussed earlier.

Concern has been expressed about CCS, not least because it is an ‘end of pipe’ technology for tackling carbon emissions rather than one which prevents the emissions in the first place. However given the need to make stringent cuts in greenhouse gas emissions, CCS should be looked at carefully, and with the major problems of rapidly diminishing gas reserves, CCS using coal as a fuel could be particularly significant. The disadvantage of CCS, that it reduces the overall efficiency of energy conversion, is less significant if it makes the use of coal possible (coal being the fossil fuel with by far the largest energy reserves) with much reduced CO2 emissions. The UK should commission rigorous investigations by independent geologists and other professionals into the long term security of CO2 storage in different geological formations. The UK should be fully involved in developing safety criteria and any legal framework for CCS. This is in line with the government’s 2005 Carbon Abatement Technology strategy, but there should be particular emphasis on assessments of the long term security of carbon storage being open to independent scrutiny. If proven acceptable, CCS should be seen as potentially part of the UK’s energy mix.

There are huge coal resources in many parts of the world, significantly including India and China, which with their rapidly developing economies, plan to build large numbers of coal fired power stations. If this happens without CCS, any attempt by the UK and other EU countries to reduce emissions would be seriously undermined. The UK’s involvement in CCS technology could help ensure the responsible use of CCS by countries with rapidly developing economies planning to use large amounts of coal. The UK has expertise in some of the technologies involved in CCS, and could benefit by our industries involvement in global markets.

Question 5. What further steps should be taken towards meeting the government’s goals for ensuring that every home is adequately and affordably heated?

5.1 Home energy efficiency priorities

The appalling energy efficiency standards in many homes and the number of excess winter deaths in the UK is a national disgrace. Expanding programmes like “Warm Front” to increase the energy efficiency of homes particularly for vulnerable groups should be a top priority. It should be possible to “roll up” winter fuel payments to fund energy efficiency improvements.

We believe that it is inevitable that fuel costs will continue to rise. There must be financial support for people on low incomes via the benefits or pensions systems to ensure that their income net of fuel payments is adequate.

Comments on issues (specifically mentioned on p7 of consultation document)

Ci The long term potential of energy efficiency measures in the transport, residential, business and public sectors, and how best to achieve that potential

A number of measures have been mentioned in the response to Q1 above. In areas where even cost effective measures do not appear to be taken up on a wide scale, a combination of education, legislation and regulation should be used to drive up efficiency. Increasing awareness of the need to conserve energy should be a top priority. Energy issues should be an essential part of the schools curriculum. Even simple things which would have been normal a generation ago like putting on more clothes when it is cold, and turning down thermostats in rooms not in use need to be encouraged as part of an energy conscious culture.

Insistence on full competition in energy supply could be a factor in inhibiting the growth of Energy Service Companies (ESCo’s) which offer to provide a given level of service (eg a given level of heating comfort in a home) rather than selling gas or electricity. ESCo’s have an incentive to install energy efficiency measure to optimise their costs, but they seem incompatible with consumers being able to switch suppliers at short notice. This factor could also affect the ability to provide district heating. The government should develop a framework which would encourage energy service provision and not inhibit the spread of district heating where this is appropriate.

Cii Implications in the medium and long term for the transmission and distribution networks of significant new build in the gas and electricity generation infrastructure

On the electricity network, there will be a need for accommodating more embedded generation from smaller scale renewable energy and CHP plants, from geographically widely dispersed wind energy and high voltage transmission from coastal areas where marine energy can be generated. Given that there is likely to be a higher proportion of variable renewable generation on the grid, more favourable pricing structures are needed for customers with equipment which can accept power interruptions (controlled remotely) for a moderate length of time, eg heating (and in some cases, cooling) by heat pumps combined with a good degree of heat storage capacity, fridge-freezers etc) This could reduce the need for spinning reserve (generators kept spinning but not generating power able to immediately pick up load in case of a power/demand mismatch) which uses some energy.

The technology being developed for storage of electricity on a significant scale, Regenesys, which was being developed by a British utility has been sold to a Canadian company VRB [15] when the utility was taken over by a German company. In view of the potential benefits of such energy storage systems, particularly on a network with significant variable generating capacity, the UK should keep up to date with developments.

Ciii Opportunities for working with other countries on our energy policy goals

In negotiations within the UNFCCC for a post Kyoto framework the UK should push for an agreement based on the principle of “Contraction and Convergence” developed by the Global Commons Institute in the UK [16]. We believe that this concept together with carefully regulated emissions trading, would be a framework which is both equable and effective and should be acceptable to countries at all different stages of development.

We should work with other countries to the greatest extent possible on appropriate technology developments. However, noting the technology agreement between the USA, Australia, S Korea, Japan, India and China specifically put technology as the solution to limiting greenhouse gas emissions, without a framework to cap emissions, the UK should make it clear that a suitable international framework under the UNFCCC is essential to ensure that even where carbon limiting technologies are more expensive, they will be adopted to the extent necessary to limit climate change. If such a framework were agreed by a large majority of countries, provisions under World Trading Organisation rules against unfair trading advantages could make it possible to impose sanctions on countries which fail to act within such a framework. Under international law, countries which suffer major problems from climate change could claim damages from countries or organisations which emit excessive greenhouse gases.

Technological developments giving more sustainable energy solutions have a large export potential - both to developed countries and developing countries. This can bring economic benefits to the UK. Where appropriate, the technology should be given to poorer countries as part of the global effort against climate change.

Civ Potential measures to help bring forward technologies to replace fossil fuels in transport and heat generation in the medium and long term.

Some comments on the potential for alternative fuels for transport have been made in section Q 1.2.2

For heating, the use of combined heat and power (although not strictly non-fossil fuel) on a much larger scale would help. The potential for heat transport in large quantities over relatively long distances should be investigated. Earlier studies in the USA [17] showed there to be no technical problems (up to 50% of the population could be served, in a country with much lower population density than the UK), the deciding factor being economics. The percentage heat loss and energy needed for circulating hot water per kilometre of piping is very much less on large diameter “trunk” transmission pipes than smaller distribution pipework. With gas prices likely to rise significantly, the balance of costs may move in favour of large scale heat distribution from power stations.

The full potential of biofuels for heating and for CHP projects should be exploited. New housing should maximise passive solar heating, with care taken to avoid overheating in hot weather. Solar hot water panels should be fitted on every new building, and retrofitting should be done on a large scale.

General comments on issues raised by the consultation document

Energy policy is an area where the government should be aiming for fully “joined up thinking”. For example, every time a local post office or hospital is closed, this leads to more travel. Education policies should aim for every school to deliver high quality education to reduce the incentive for parents to take children to more distant schools (usually by car). The health benefits of making walking and cycling more user-friendly would be considerable, and the cost savings to the NHS of eliminating cold, damp homes significant. Absence of affordable housing near to peoples work causes many people to commute over large distances. Such factors need to be viewed in an overall context when allocating government funding.

The size of reduction in greenhouse gas emissions needed to limit the risk of dangerous climate change should be regularly reviewed, and the relative risks of different means of achieving any necessary further reductions in emissions need to be assessed in light of the most up-to-date information.

There will be a large expansion of demand for skills at all levels to make the transformation of our energy infrastructure and improve the efficiency with which energy is used. Renewable energy and energy efficiency technologies are more labour intensive than fossil and nuclear technologies, so offer employment benefits. In a number of areas, they also offer the UK export opportunities.

In the last year there has been a large increase in public awareness of energy and climate change issues. The government should build on this to gain support for measures which may not be popular but which are necessary to meet greenhouse gas reduction targets - for example in relation to the siting of wind farms or increased costs of car and air travel.

Much of the main body of this response has been about technical issues. However, ultimately, there needs to be an appraisal of what makes for a high quality of life. It is clear from a number of studies that a good quality of life does not correlate closely with the usual economic measure of standard of living, GDP per head [18]. Policies over the long term should aim for human fulfilment, emphasising the needs for time for personal interactions, for fulfilling work and for leisure activities which do not require ever increasing travel.

References

1. ULTra (Urban Light Transport) system as discussed in: Anon (2003). Driverless taxis win enthusiastic reception in Cardiff trial runs. Professional Engineering. 29 January.
2. Anon (2006). PSA says diesel hybrid is economy breakthrough. Automotive Engineer. February.
3. Anderson, A (2006). Growth Scenarios for EU and UK aviation - contradictions with climate policy. Tyndall Centre. www.tyndall.ac.uk
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5. Sustainable Development Commission (2006). Reducing CO2 – nuclear and the alternatives. www.sd-commission.org.uk
6. Office of Science and Technology (2005). SET Statistics. Table 3.8. www.ost.gov.uk/setstats
7. Anon (2006). Shell and VW to look into cellulose biofuels. Automotive Engineer. January.
8. Second generation biofuels - heavy focus on biomass-to-liquid www.greencarcongress.com/europe/index.html
9. Grassi, G (2000). Bioethanol - industrial world perspective. Renewable Energy World. May/June.
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11. Sustainable Development Commission (2006). The role of nuclear power in a low carbon economy. SDC position paper. www.sd-commission.org.uk
12. Royal Commission on Environmental Pollution (2000). Energy – the changing climate. 22nd report. www.rcep.org.uk
13. Barnaby (2005). Security and nuclear power. Oxford Research Group. www.oxfordresearchgroup.org.uk
14. World Nuclear Association (2005). The new economics of nuclear power. www.world-nuclear.org
15. VRB; www.vrbpower.com
16. Global Commons Institute; www.gci.org.uk
17. Karkhack J. Long distance transmission of hot water for district heating. US Dept of Energy report BNL24823. www.osti.gov/energycitations/servlets/purl/6647111-eiUxmt/6647111.pdf
18. Layard R (2005). Happiness - lessons from a new science. Allen Lane (publishers).