SEPA’s Energy position statement
Contents
Summary
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SEPA’s energy position statements
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1 Purpose and scope
1.1 Challenges and opportunities
1.2 Why has SEPA developed a statement on energy?
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2 SEPA’s energy remit
2.1 SEPA’s duties
2.2 Other roles
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3 Guiding energy principles
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4 Energy hierarchy
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SEPA’s energy guidance
5.1 Energy demand minimisation
5.2 Energy efficiency
5.3 Renewable generation
5.4 Low carbon non-renewable energy and resource recovery
5.5 Non-renewable energy
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6 Storage, grid and infrastructure
6.1 Background
6.2 The way forward
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7 Conclusion
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Appendix A: Background information
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SEPA’s Energy position statement
Summary
Energy is fundamental to the economy, and a substantial proportion of carbon emissions from human activities
ultimately arise from energy demand. The challenge now is to shift the economy to a low carbon future, which
requires a significant change in how society considers energy. Energy and climate change remain intrinsically
linked while the energy system is still so reliant upon non-renewable fuels. There is an opportunity to change
this by reducing demand, improving efficiency, finding and supporting sustainable low carbon1 technologies
and ensuring that energy and resources are recovered. SEPA seeks to advise, influence, regulate and monitor the
impacts that changes in energy supply, transmission and consumption have on the environment.
Within its emerging strategy on Scotland’s Low Carbon Economy, the Scottish Government recognises that
maintaining and enhancing environmental quality is as important as securing long term economic and social
benefits. SEPA’s energy statement is a step towards delivering clear and effective advice on the environmental
challenges that will drive forward the transition to a low carbon future.
SEPA’s energy position statement outlines its remit, facilitating effective and consistent engagement with
the government, other public bodies and agencies, in helping to deliver a lower carbon energy future. SEPA’s
approach can be distilled into the following general principles.
SEPA will:
•support and encourage a reduction in the demand for energy;
•support the use of environmentally sensitive renewable energy and other low carbon compliant technologies
where appropriately scaled, located and mitigated;
•encourage a diversity of energy sources that integrate energy supply and demand, especially supporting
efficient use of surplus heat, and heat from renewable sources;
•support technology research and the development, demonstration, environmental assessment and
commercialisation of new clean technologies;
•engage early with stakeholders to ensure transparent decision making through promotion and provision of
clear and accessible information;
•seek to inform and influence decisions made now, so that they do not unduly lock Scotland into a higher than
necessary carbon future, and support policy and legislative certainty to reduce project risk;
•consider the life cycle of a development as the basis for decision making, using life cycle and carbon
accounting approaches;
•encourage culture change to enable people and society to play an important role in reducing energy demand,
to improve the efficient use of energy, to improve skills and to encourage innovation.
SEPA’s remit and the importance of decarbonising the energy system mean delivering a low carbon economy in
Scotland will play an increasingly important role within the public sector.
SEPA’s energy position statements
SEPA has developed position statements that are outlined below. These are ordered according to their position
in an energy hierarchy, which is a framework to guide energy decision making towards more sustainable options.
SEPA believes that an energy hierarchy provides a useful approach to considering and making robust energy
decisions.
L ow carbon refers not just to carbon dioxide emissions, but includes the range of GHG emissions, e.g. the six main greenhouse gases are
Carbon Dioxide (CO2), Methane (CH4), Nitrous Oxide (N2O), Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs), Sulphur Hexafluoride (SF6)
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SEPA’s Energy position statement
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Position statement 1: energy hierarchy2
SEPA is proposing an energy hierarchy to enable a consistent approach to the complexities of the energy field.
SEPA believes this should be adopted widely to enable a consistent and transparent approach3.
SEPA supports the development of renewable energy production where it contributes to tackling climate
change, to supporting local, secure supply and where it provides economic benefits commensurate with any
environmental impact.
Position statement 2: generator location and scale
SEPA believes that electricity generating installations should be appropriately located and scaled, to avoid
adverse offsite impacts, minimise energy losses through heat recovery and use, to minimise greenhouse gas
emissions and optimise energy productivity, considering both individual and cumulative impacts.
Support for renewables should be set within a policy framework that acts to optimise the environmental benefits
of energy developments and to avoid unintended adverse consequences, wherever those may be. Displacement
of food production and other land use changes such as deforestation can lead to unsustainable production of
bioenergy fuels.
Position statement 3: sustainability of renewable energy generation
Demand for energy from all renewable sources should not place undue pressures on ecosystems domestically
or overseas. This includes bioenergy fuels, which should not create additional pressures on ecosystems overseas
or compete with the demand for agricultural space in the UK to produce food. Sustainability standards for
bioenergy should be developed and internationally agreed, addressing the unintended adverse environmental
consequences of some energy developments. Bioenergy fuels should comply with these standards, including the
global 2010 target on biodiversity loss and any post-2010 target, and demonstrate compliance with greenhouse
gas saving targets and sustainability standards based on full life cycle assessment.
Nuclear energy is an intermediate technology that uses non-renewable fuels to generate energy with lower
carbon emissions. Uranium is carbon intensive and finite and there are outstanding concerns regarding the other
environmental consequences of nuclear energy.
Position statement 4: storage and disposal of radioactive wastes
SEPA believes nuclear power to be a lower carbon energy source and works to support delivery of Scottish
Government policies relating to nuclear power. SEPA believes that our regulatory framework for the keeping and
use of radioactive substances and the accumulation and disposal of radioactive wastes is robust and protects
both the environment and human health.
There are intermediate technologies that enable use of non-renewable fuels to generate energy with lower
carbon emissions. These technological approaches reduce emissions of CO2, adapting existing systems and
processes to be less damaging to the climate. Decisions made now should not lock Scotland into a higher than
necessary carbon future4.
Position statement 5: carbon capture and heat readiness
SEPA supports the government programme for demonstrating carbon capture and storage (CCS) to test and
assess the potential contribution of this technology at a commercial scale. SEPA believes it is essential that
the planned UK CCS demonstration projects are designed to provide data and scientific outputs that will
further the development of the technology and improve public understanding. New coal-fired power stations
must demonstrate carbon capture, transport and storage from the first day of their operation, and should also
be able to demonstrate heat recovery readiness5. Large scale gas and biomass thermal plants are required to
be carbon capture ready, and should also seek to have heat recovery, a suitable heat plan in line with SEPA’s
guidance outlined in the thermal treatment of waste guidelines. riginal source of reference energy hierarchies drawn from institute of mechanical engineers Energy Hierarchy and the John Muir Trust
O
http://www.jmt.org/policy-energy-conservation.asp
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SEPA first suggested development of an energy hierarchy in its response to Performance and Innovation Unit (PIU) energy review in 2001.
4
Bernice Lee, Ilian Iliev and Felix Preston (2009) Who Owns Our Low Carbon Future? Intellectual Property and Energy Technologies, A
Chatham House Report, September 2009.
5
www.sepa.org.uk/climate_change/solutions/carbon_capture_and_storage.aspx
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SEPA’s Energy position statement
1 Purpose and scope
This statement sets out SEPA’s overall approach to energy. It considers energy generation, transmission and
consumption – both renewable and non-renewable – and their environmental consequences. It also outlines how
SEPA contributes to both existing and future challenges as we move to a lower carbon future. By reading this
document, you should be able to:
•understand SEPA’s role with regard to energy;
•understand SEPA’s view of the key energy issues and the actions it is taking;
•understand what SEPA believes is required to achieve a sustainable energy future.
1.1 Challenges and opportunities
Scotland has excellent energy resources – with oil and gas reserves in the North Sea, wind, wave, hydro and tidal
resources and a well-supplied power generation market with a broad mix of generation technologies and fuel
sources. Scotland has sufficient wave and tidal resources to meet one fifth of the UK’s total electricity demand6,
while the offshore renewable energy industry in the UK as a whole, using less than a third of the total available
resource, could generate electricity equivalent to 1 billion barrels of oil annually. This would match North Sea oil
and gas production and result in carbon dioxide savings of 1.1 billion tonnes by 20507.
Harnessing these resources has environmental consequences, which vary according to the energy form,
technology used, location and scale of the development, and the mitigation and management employed.
Scotland is also well supplied with industry, research and academic expertise and, in some cases, is at the
forefront of innovation and technological development. Scotland’s excellent engineering and manufacturing
capabilities place it in a strong position to grasp future opportunities and address future challenges. Appendix
A provides background information illustrating the scale of the challenge for Scotland to achieve a low carbon
energy future.
Climate change is already happening in Scotland. Left unchecked, it is projected to cause severe damage to our
environment, economy and people. SEPA is therefore looking to develop new thinking to protect the environment
while supporting sustainable economic growth, through identifying ways to use resources more wisely, adapting
to climate change, and supporting the development of low carbon energy solutions.
The UK Climate Change Committee published its advice to Scottish Ministers in 2010, on issues relating to the
climate change targets. ‘Scotland’s path to a low carbon economy’ sets out the committee’s advice on how
Scotland can reduce emissions of all greenhouse gases by the Government target of 42% by 2020. It also provides
advice on the inclusion of aviation and shipping emissions and the use of carbon credits in Scotland, as well as on
economic and social impacts of meeting the targets8.
Within its emerging strategy on Scotland’s Low Carbon Economy, the Scottish Government recognises that
maintaining and enhancing environmental quality is an important factor in securing long term economic and
social benefits. Environmental Regulation will be a positive driver in supporting the transition to a Low Carbon
Economy and SEPA has a role to support industry in preparing for the effective implementation of more stringent
environmental standards which will be required in future years. SEPA’s energy statement is a step towards
delivering clear and effective advice on the environmental challenges that will drive forward the transition to a
low carbon future.
1.2 Why has SEPA developed a statement on energy?
SEPA has a core remit to protect and improve the environment, recognising the serious threat posed by climate
change. Solving the problem of climate change cannot be done without addressing fundamental questions of
sustainability and environmental impacts within the energy system. SEPA has developed this statement to clarify
its interaction with the Scottish Government and other key stakeholders, and to create clarity for its own staff.
Source: The Crown Estate
Source: www.offshorevaluation.org
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http://www.theccc.org.uk/reports/scottish-report
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SEPA’s Energy position statement
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2 SEPA’s energy remit
2.1 SEPA’s duties
SEPA’s main role is to protect the environment and human health by regulating activities that can cause
pollution. We do this by monitoring the quality of Scotland’s air, land and water, and by influencing others’
considerations about the environment. SEPA has a pivotal role in delivering climate change priorities – through
a combination of regulating, informing and influencing – in order to drive Scotland into a lower carbon future.
SEPA also has an interest in the environmental consequences of energy decisions, and regulates or acts as a
statutory consultee for major energy developments.
According to data from the Department for Energy and Climate Change (DECC), SEPA directly regulates over
7900MW of installed electricity generation capacity. There are a further 2600MW of installed hydro capacity,
including pumped storage, that SEPA licenses. SEPA is also a statutory consultee, and has been involved with
over 1000MW of onshore wind developments. Moreover, SEPA provides a wide range of advice and information
and seeks to influence decision makers – both unilaterally and through membership of groups such as the 2020
Climate Group9.
SEPA has direct duties arising from specific legislation and general duties or responsibilities under the
Environment Act 1995. These include an interest in land use and the built environment, and addressing climate
change. Specifically:
•SEPA regulates many of the environmental impacts resulting from energy generation, transmission and
consumption, in order to minimise environmental impacts and prevent harm to human health10.
•SEPA is a statutory consultee for development plans, many planning applications, and those applications that
under Sections 36 and 37 of the Electricity Act 1989 require environmental impact assessment.
•SEPA is a designated consultation authority for Strategic Environmental Assessment (SEA) under the
Environmental Assessment (Scotland) Act 2005 and through the Environmental Assessment of Plans and
Programmes (Scotland) Regulations 2004.
•SEPA permits larger power plants and industrial processes under the Pollution Prevention and Control Regime.
•SEPA regulates water activities, including abstraction for hydro power and for cooling water under the Water
Environment (Controlled Activities) (Scotland) Regulations 2005.
•SEPA monitors impacts on soil, water quality and biodiversity.
•SEPA is the competent authority for the EU Emissions Trading System (EU-ETS) in Scotland, issuing permits to
eligible installations and checking that they comply with the system’s operational rules. SEPA also administers
the Carbon Reduction Commitment (CRC) Energy Efficiency Scheme in Scotland and administers Scotland’s
carbon unit account through the Climate Change (Scotland) Act 2009: Carbon Accounting (Scotland)
Regulations 2010.
•SEPA has a statutory duty to protect the environment and human health from the effects of waste
management and disposal. SEPA’s powers range from waste data reporting to enforcing European compliance
schemes. SEPA regulates waste activities – including re-use, recovery and recycling of waste – to reduce the
requirement for virgin materials in manufacturing and production. SEPA also regulates energy recovery from
waste through anaerobic digestion or other waste management processes.
•SEPA has been influential through its development of policies and guidance, such as SEPA’s thermal treatment
of waste guidelines, and SEPA’s interim planning statement on energy and climate change statement. SEPA
seeks to inform and influence policies domestically and internationally.
•SEPA regulates the disposal of radioactive waste from nuclear power stations and other premises under the
Radioactive Substances Act 1993 (as amended).
http://2020climategroup.org.uk/whoweare.php
Refer to Appendix A, section A1.4, for further information
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SEPA’s Energy position statement
2.2 Other roles
These are areas and issues where SEPA does not have a direct regulatory locus, but where it seeks to influence the
decisions and approach and direction of others for the purpose of furthering its core aims and objectives.
•SEPA provides advice and information to industry, business and the public.
•SEPA engages with key stakeholders to influence policy making and sits on business led groups to provide
advice and guidance, such as the Forum for Renewable Energy Development in Scotland (FREDS) and the 2020
Climate Group.
•SEPA promotes and rewards best practice on projects that seek to improve business resource efficiency – for
example the Vision in Business Awards (VIBES).
•SEPA aims to lead by example by managing its own impacts on the environment and energy consumption by
reducing energy demand from business travel and improving building energy performance.
SEPA’s Energy position statement
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3 Guiding energy principles
SEPA’s implementation of its energy remit can be distilled into the following general principles.
SEPA will:
•support and encourage a reduction in the demand for energy;
•support the use of environmentally sensitive renewable energy and other low carbon compliant
technologies, where appropriately scaled, located and mitigated;
•encourage a diversity of energy sources, and developments that integrate energy supply and demand,
especially supporting efficient use of surplus heat, and heat from renewable sources;
•support technology research and the development, demonstration, environmental assessment and
commercialisation of new clean technologies;
•engage early with stakeholders to ensure transparent decision making through promotion and
provision of clear and accessible information.
•seek to inform and influence decisions made now, so that they do not unduly lock Scotland into
a higher than necessary carbon future, and support policy and legislative certainty to reduce
project risk;
•consider the life cycle of a development as the basis for decision making, using life cycle and carbon
accounting approaches;
•encourage culture change to enable people and society to play an important role in reducing energy
demand, to improve the efficient use of energy, to improve skills and to encourage innovation.
The above principles outline SEPA’s high level strategic approach and, over time, will be translated into guidance
or specific documents addressing their practical application. To do this effectively, policy integration and the
avoidance of contradiction are essential. Policy developments such as Scotland’s zero waste plan and the creation
of Zero Waste Scotland are examples of this joined up approach.
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SEPA’s Energy position statement
4 Energy hierarchy
An energy hierarchy offers an effective framework to guide energy policy and decision making. It is possible
to apply the principles that underpin the waste hierarchy – ‘reduce, reuse, recycle, and recover’ – to energy. As
commonly devised, an energy hierarchy is primarily driven by carbon intensity and resource use. The Scottish
Government has made reference to such a hierarchy, stating: “Key elements of the strategy for achieving a
substantial reduction in emissions are energy conservation measures and greater energy efficiency, making the
most of Scotland’s renewable energy potential and encouraging power and heat generation from clean, low
carbon sources.”11
SEPA has used this logical approach to lay out its energy principles, outlined below. Further information on each
tier of the hierarchy is in Section 5, or click on the diagram to go straight to the relevant section.
It should be noted that a lower tier of the hierarchy may, in some cases, be acceptable.
Figure 1: Energy hierarchy
More sustainable
Energy demand minimisation
Energy efficiency
Renewable generation
Low carbon
non-renewable energy and resource recovery
Less sustainable
Non-renewable
energy
The first priority is to reduce the amount of energy used by minimising the demand, then increase the efficiency
of any systems that use energy, as outlined in the Scottish Government’s energy efficiency action plan12. When
all achievable methods of reduction are in place, it is then appropriate to consider how to generate energy
from renewable sources, then take a waste product and redirect it to replace a raw material (ie reuse). Once all
practical methods to reuse energy are in place, it then becomes appropriate to take an output, such as excess
process heat, that needs to be processed or treated in some form before it can replace a raw material or fuel
(ie recycling). Recovery of energy such as heat and or materials such as carbon is followed by non renewable
generation.
The hierarchical approach has also been illustrated by consultants McKinsey & Co, in developing their carbon
abatement cost curves. Figure 2 below shows the wide range in costs from different abatement measures.
Generally, it shows that measures corresponding to the upper sections of the hierarchy – conservation and
efficiency – are placed on the lower left of the cost curves and are therefore the more cost-effective carbon
abatement options, whilst the less cost-effective measures on the right of the cost curve correspond generally
to the lower tiers of the energy hierarchy. The McKinsey report clearly identifies a need to work on developing
effective carbon abatement approaches in Scotland.
11
Paragraph 48 of the National Planning Framework 2
http://www.scotland.gov.uk/Publications/2010/10/07142301/0
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SEPA’s Energy position statement
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The Scottish Government’s Council of Economic Advisors considered the McKinsey report, and identified that,
“many emissions reduction measures that have a negative cost are still not being taken up, and some that
are being pursued are likely to be extremely costly”13. SEPA supports the council’s wish to see an equivalent
abatement cost curve of the various energy options commissioned for Scotland. This method assists in ensuring
that environmental and economic considerations are given an appropriate weighting, with environmental goals
considered in parallel with targets for economic growth.
Figure 2: Cost of abatement for 202014
The cost curve in Figure 2 shows the maximum technical potential. However, the likelihood of capturing
that potential depends on implementation, which may be less than optimal. To illustrate what that would
mean practically, McKinsey constructed a scenario of ‘reduced implementation’, assuming a 20% reduction in
implementation for most measures from the full technical potential.15 This illustrates the risk of not implementing
the full potential of measures to meeting the required reduction targets.
First Annual Report of the Council of Economic Advisers: December 2008
Source: McKinsey UK: http://www.mckinsey.com/clientservice/ccsi/pdf/CBI_Climate_Change_Report_2007_McKinsey_appendix.pdf
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Further information on the reduced implementation is available from
http://www.mckinsey.com/clientservice/sustainability/pdf/CBI_Climate_Change_Report_2007_McKinsey_appendix.pdf
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SEPA’s Energy position statement
5 SEPA’s energy guidance
This section highlights SEPA’s remit and guidance on each stage of the hierarchy noted above. Each tier of the
hierarchy is defined, the main environmental impacts outlined, and SEPA’s remit and objectives are set out.
5.1 Energy demand minimisation
5.1.1 Definition
This is the reduction of unnecessary energy demand, through design and installation of low or no energy
systems. It can also include ‘smart’ systems that manage and inform about peak demands, reducing the need for
additional installed generating capacity. Small changes in behaviour – such as switching lights and appliances
off when they are not being used – can contribute to energy demand minimisation and good engineering and
design are key to ensure systems are easy to switch off and require minimal external energy, eg using solar
gain. Effective policy measures should be targeted at where the greatest savings can be achieved. This process
is made considerably easier through engineering solutions such as smart meters, informed by research such as
the abatement cost curves above (see Figure 2). Energy conservation can also take place in very high energy
consuming processes: avoidance of waste or scrap, and lean production processes16 all contribute to energy and
resource conservation.
Within a domestic or commercial environment, reduction means reducing the amount of energy needed by the
occupants of buildings, while still maintaining their living conditions. Much can be achieved through passive
design17. Energy use can also be reduced through careful planning of our towns and cities. Locating community
facilities, services, retail and jobs close to homes will help reduce the need for car journeys18. Reducing
unnecessary energy use is a priority for both existing and new buildings and activities, highlighting a need for
sensible planning and zoning, and appropriate buildings standards. There is both an environmental and economic
imperative, as unnecessary energy use directly equates to unnecessary expenditure.
Minimising the need to travel, through the use of virtual systems and improvements in technology, will also
enable energy demand minimisation and facilitate a move away from non-renewable transport fuels, to efficient
use of lower carbon and renewable electricity19.
5.1.2 Environmental aspects of energy demand minimisation
All energy transformation and consumption has the potential to cause environmental impacts. Specifically,
combustion of fuels contributes to air and water pollution, and to climate change. Any reduction in energy
demand can reduce the impact of generation and transmission, although fixed energy producing assets, eg power
stations, do have efficiency curves which can be difficult to improve over their lifetime
5.1.3 SEPA’s approach
SEPA seeks to influence and regulate to encourage energy conservation.
Planning: SEPA seeks to influence land use and development planning, as it has a critical role to play in
contributing towards Scotland’s climate change and energy priorities. Not least, planning has a crucial role
to play in promoting a pattern of development which helps to reduce Scotland’s greenhouse gas emissions
and facilitates adaptation to climate change. More detail is available in SEPA’s Interim Position Statement on
Planning, Energy and Climate Change.20
‘Lean’ is a set of tools and practices used to eliminate waste and inefficiency from production systems—reducing costs, improving quality and
reliability, and speeding up cycle times. Toyota Motor pioneered lean practices. Recently, lean techniques have moved from manufacturing
plants to operations of all kinds. The goal is to improve the organisation’s performance on the operating metrics that make a competitive
difference, by drawing employees into the hunt to eliminate unneeded activities and other forms of operational waste. See McKinsey & Co
for more information.
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Passive design is the most significant GHG abatement measure in the building sector, but is the least ingrained in modern building
techniques. It focuses on reducing a building’s energy consumption for heating and cooling by optimising insulation, ventilation, orientation
and shade. See McKinsey p65.
18
An adaptation of Von Thunen’s theory of land use.
19
See Department for transport ‘Smarter Choices’.
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Full details of SEPA’s planning work can be found at http://www.sepa.org.uk/planning.aspx
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SEPA’s Energy position statement
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Advice: SEPA seeks to advise industry and businesses on how to improve energy and resource efficiency, and also
seeks to influence others in developing policies that minimise energy demand.
Regulation: SEPA has an indirect regulatory impact on energy conservation. The way in which SEPA implements
its duties will have an impact on energy demands: eg impacting on energy use for end-of-pipe treatment. SEPA
seeks to influence the development of policies and regulations that consider the impact on energy demand. There
are specific energy considerations under several regulatory regimes, covering both process industry regulation and
the water environment21. The Carbon Reduction Commitment Energy Efficiency Scheme is a set of regulations
designed to encourage reducing energy use22.
Leading by example: SEPA works to improve its own energy performance, through a certified environmental
management system. It provides a bike-to-work scheme, to encourage the reduction of energy demand from
transport. More information can be found at the greening SEPA website.
Monitoring and reporting: SEPA reports on the state of the environment, highlighting the impacts of energy
demand and climate change and using this information to inform and influence others.
5.1.4 The way forward
The planning system needs to deliver lower energy demand settlements, and planning authorities should be
supported and encouraged to deliver these. Meanwhile Government policies should be designed to ensure that:
•building standards result in better insulation of new buildings, including homes, with improved energy
management systems;
•greater support is given for retrofitting insulation and dealing with hard-to-treat homes, including exploring
ways to defray the upfront capital costs of delivering transformational levels of home insulation.23
Energy audits of the public sector should be implemented to include demand reduction initiatives in areas such
as street lighting and to inform and improve public procurement standards.
Transport infrastructure developments and policies should consider reducing the need to travel within their
conceptual framework, minimising the need for non-renewable transport fuels and the local and global
environmental impacts that these create.
5.2 Energy efficiency
5.2.1 Definition
This can be defined as maximising the productivity of energy consumed. In most instances, this means
the demand for energy will eventually reduce as efficiency improves. However, it can also result in greater
productivity from the same energy demand, enabling more work to be done with the same energy input. Energy
efficiency improvements are often achieved through technical measures, eg by reducing frictional losses,
improving the conversion efficiency of a thermal combustion process, or reducing heat loss from a building.
Efficiency can be applied on both the demand side and supply side of energy provision – from improving the
efficiency of a television right through to improving that of a power station.
5.2.2 Environmental aspects of energy efficiency
Like energy conservation, energy efficiency should reduce the environmental impacts on air quality, water,
climate change, or waste generation. Energy efficiency reduces emissions of associated air pollutants and
greenhouse gases, although the relationship is not necessarily linear. Specifically, energy efficiency will improve
energy productivity, meaning that the level of environmental impact per unit of work done should decrease, even
if this is not an absolute decrease. Energy efficiency and economic performance are therefore complementary –
together they result in more productive, less wasteful and more sustainable systems.
http://www.sepa.org.uk/customer_information.aspx
See Appendix A for further information.
23
Proposal supported by recommendations of the First Annual Report of the Council of Economic Advisers: December 2008
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SEPA’s Energy position statement
5.2.3 SEPA’s approach
SEPA seeks to encourage energy efficiency and improve energy productivity, and supports the Scottish
Government’s energy efficiency action plan, published in 2010.
Planning: SEPA uses its planning role to seek to influence land use, development planning, and the consideration
of energy efficiency in infrastructure developments, where appropriate (including within major transport, water
and sewerage systems).
Advice: SEPA seeks to advise industry and businesses on how they can minimise waste and improve energy and
resource efficiency. The organisation also strives for other organisations to develop policies to improve energy
efficiency, realising resource efficiency benefits that can enhance the profitability of operators. Further details of
SEPA’s business advice can be found on our website24.
Regulation: A number of different mechanisms encourage and regulate energy efficiency. Climate change
agreements (between industry sectors and the Government), the EU Emissions Trading System and Carbon
Reduction Commitment Energy Efficiency Scheme, are the main instruments. SEPA has the power under the
Pollution Prevention and Control (PPC) regime to ensure that Part A installations or mobile plants are operated
in such a way that energy is used efficiently – subject to those other instruments, already mentioned, which take
precedence.25
SEPA is the regulator in Scotland for the greenhouse gas emissions trading system26 and implements the EU
Emissions Trading System on a UK level. The permitting system controls emissions of CO2 from certain listed
activities. Operators are allocated allowances and must surrender one allowance for each tonne of CO2 emitted,
after which any unused allowances may then be sold on the open market. The economic incentive to improve
energy efficiency, and thus reduce the need for allowances, will increase when operators are required to buy all
their allowances.
SEPA is also the administrator in Scotland for the Carbon Reduction Commitment (CRC) Energy Efficiency
Scheme, which came into effect on 1 April 201027. The CRC scheme relates to greenhouse gases and it applies to
direct and indirect emissions from supplies of electricity, gas and fuel by public bodies and undertakings.
Leading by example: SEPA works to improve its own energy efficiency through an environmental management
system, certified to ISO14001.
Monitoring and reporting: SEPA monitors and reports on the state of the environment, highlighting the
impacts of energy demand and climate change on the environment and using this information to inform and
influence others.
5.2.4 The way forward
Energy efficiency must be improved through better building design and construction, improving insulation, and
the installation of energy efficient appliances. This should also consider transport – the need to travel, the mode
of travel and the potential alternatives.
Policies need to encourage greater development of Combined Heat and Power (CHP) at different scales. CHP
allows more of the energy contained within a fuel to be used (both as heat and electricity) than would be
possible if the fuel was used for electricity generation alone. CHP reuses the waste heat resulting from electricity
generation as a resource to replace the need for primary energy fuels to make heat separately. Greater use of
CHP technology should be supported by thermal master planning28 and mapping, which involves the careful
planning and location of heat users to ensure that waste heat from one user can be reused in other processes and
buildings. Maximising the energy efficiency of thermal treatment facilities through heat recovery should be a key
consideration in site allocation29. The Scottish Government’s renewable heat plan contributes to achieving this,
and will be supported by the Scottish Government’s energy efficiency action plan in delivering lower carbon and
renewable heat through co-ordinated and integrated policy.
http://www.sepa.org.uk/customer_information/netregs.aspx
SEPA has the power under the Pollution Prevention and Control (Scotland) Regulations 2000 (PPC) to set conditions in Permits to ensure
that Part A installations or mobile plant are operated in such a way that energy is used efficiently.
26
Under the Greenhouse Gas Emissions Trading Scheme Regulations 2005.
27
CRC applies to direct and indirect emissions from supplies of electricity, gas and fuel by public bodies and undertakings. It is central to the
UK’s strategy for improving energy efficiency and reducing CO2 emissions.
28
See http://www.sustainablecities.org.uk/energy/portfolio/thermal-masterplanning/ as an example of thermal master planning.
29
This is supported by SEPA’s Thermal Treatment of Waste Guidelines.
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SEPA’s Energy position statement
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SEPA supports the development of a prioritised research, development and demonstration and commercialisation
strategy to support environmental and clean technologies and innovation in new low carbon energy solutions as
part of greening the Scottish economy and exploiting the emerging global market opportunities. This will relate
to and support the Scottish Government’s low carbon economic strategy.30
5.3 Renewable generation
5.3.1 Definition
This can be defined as supplying energy from sources that are inexhaustible or replaceable with new growth, and
should follow efficiency and demand minimisation within the whole energy system. Efficient and sustainable
energy provision is not, however, just about resource availability. It must also take account of wider issues such as
affordability, societal acceptability, environmental impact, and security of supply.
The consideration of these issues encourages a diverse approach to generating renewable energy. This is
particularly relevant to the UK, which has a wealth of different renewable energy sources available on land and
around its shores, but where an overemphasis on any one source could have unacceptable impacts31.
Typical renewable generation sources include wind (onshore and offshore), wave and tidal, hydro, bioenergy, and
geothermal. These can operate at very different scales, and can also have different spatial impacts and intensities.
5.3.2 Environmental aspects of renewable energy
Renewable energy technologies are diverse and therefore have the potential to create a range of environmental
impacts. These impacts can occur at different stages within the life cycle of a project – whether in construction,
operation or decommissioning. Examples of environmental aspects impacted by renewables are major
construction activities and significant disturbance of the land. For example, onshore wind farms and hydro
schemes can unlock and emit carbon stored in peat, while biomass burning can lead to local air quality impacts
(especially emission of fine particles). All developments can have varying impacts on water quality and quantity,
biodiversity, unintended climate impacts from unsustainable renewable fuels, and noise and vibration.
5.3.3 SEPA’s approach
SEPA’s aim to protect and improve the environment and human health means that it has a direct remit to
regulate and control many renewable generation technologies.
Advising and influencing: SEPA has been working with the Scottish Government to inform and support its
development of several policy documents that will play a significant role in the renewable energy sector. SEPA
has informed development of the Scottish Government’s low carbon economic strategy, its renewables action
plan and linked renewable heat action plan, and also the energy efficiency action plan.
SEPA has worked with partners to help ensure that air quality and human health are protected in biomass
developments, ensuring that appropriate measures are being taken to limit the emission of harmful substances
into the environment.
SEPA is a statutory consultee for development plans, many planning applications, and those applications
under Sections 36 and 37 of the Electricity Act 1989 that require environmental impact assessment. It is also
a designated consultation authority for strategic environmental assessment. There are currently a number of
significant renewable energy developments progressing through the planning system that SEPA has been engaged
with, and these are likely to increase in coming years.
Regulating: SEPA permits and regulates many renewable generation operations and monitors their effects on the
environment, including:
•licensing hydroelectricity activities under the Controlled Activities Regulations (CAR) regime. Determining
a licence application includes assessing whether the benefits of the scheme are proportionate to the
environmental impacts;
http://www.scotland.gov.uk/Topics/Business-Industry/Energy/Action/lowcarbon
http://www.sdi.co.uk/Key%20Industries/Energy/Sectors/Renewable%20Technologies.aspx
30
31
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SEPA’s Energy position statement
•regulating large scale thermal electricity generation, including regulation of biomass electricity generation
under PPC. Operators must achieve the emissions limit values specified in their permits and must ensure that
they use the best available techniques to minimise emissions;
•regulating waste management activities which frequently interact with construction phases of many
renewable energy projects;
•working closely with partners in marine licensing and monitoring.
SEPA is in discussion with the Scottish Government with respect to our role in assessing the carbon impacts of
renewable energy developments. Importantly, SEPA also monitors the environment and uses the information
collected to identify the impacts of development, thus informing policy and regulation in the future.
5.3.4 The way forward
SEPA supports the development of renewable energy production, where it contributes to tackling climate change,
and supports local, secure supply where it provides economic benefits – commensurate with any environmental
impact, provided that this is within the context of reducing overall energy demand through increased efficiency.
Public support for renewables should be set within a policy framework that seeks, as a priority, to reduce energy
demand and improve energy efficiency, and that acts to optimise the environmental benefits of the energy
developments. This might be achieved through a life cycle approach for assessing the wide range of factors, both
positive and negative. This would include assessment of carbon impacts. These should seek to avoid unintended
adverse consequences of developments, and should aim to minimise overall carbon emissions.
SEPA supports the recovery of energy from appropriate types of waste materials, including waste biomass from
forestry, agriculture, sewage sludge and unrecyclable plastics. Recovery should be encouraged in order to limit
the pressure for dedicated biomass feedstock production, provided that the waste management hierarchy is being
adhered to.32
5.4 Low carbon non-renewable energy and resource recovery
5.4.1 Definition
This can be defined as using non-renewable fuels to generate usable energy from lower carbon sources, such as
uranium, or technological solutions to prevent emission of CO2, and also the recovery of energy resources from
residual wastes. These tend to be intermediate technologies, using and adapting existing systems and processes to
be less damaging to the climate. Finite natural resources such as oil, coal, gas and uranium provide the majority
of global and UK energy supply. Our transport systems, buildings and power generation infrastructure are all
largely dependent on the continued supply of these resources, so the transition to an energy system that is fully
renewable will take time. Nuclear energy, in the form of the fission of uranium, is one such existing low carbon
source of electrical energy. Uranium is finite and there are significant outstanding concerns regarding the other
environmental consequences of nuclear energy. In addition, the development of carbon capture and storage (CCS)
has the potential to mitigate CO2 emissions from thermal electricity generation.
Low carbon non-renewable energy also includes pumped storage hydro, which cannot be considered renewable
until the source of the electricity used to pump the water is also renewable.
Resource recovery includes recovering energy from waste. In SEPA’s view, this should only be considered for
residual wastes that cannot be reused and for energy resources that have already been lost within the initial
system. It must also be done efficiently, and this is outlined in more detail in SEPA’s thermal treatment of waste
guidelines33.
This is supported by SEPA’s Thermal treatment of waste guidelines
SEPA’s Thermal treatment of waste guidelines
32
33
SEPA’s Energy position statement
15
5.4.2 Environmental aspects of low carbon non-renewable energy and resource recovery
Thermal generation using fossil fuels, even in power stations fitted with CCS, will emit some carbon dioxide and
other pollutants to atmosphere. It is also less electrically efficient, as there is an energy penalty from abatement
equipment and compression.
The recovery of energy and resources from residual waste is preferable to either its disposal on land or the use of
non-renewable resources for energy generation. There are potential environmental impacts through emissions to
air, land and water, and any combustion will result in emissions of carbon dioxide and other substances.
5.4.3 SEPA’s approach
SEPA has a role in regulating low carbon non-renewables and considering the potential environmental impacts of
energy decisions, and it is within its remit to reduce these impacts. Raising awareness of environmental problems
and solutions is the first step to promoting respect for the environment. SEPA has an important role to play in
educating and encouraging behavioural changes in Scotland’s response to climate change34.
Over and above the roles outlined previously, SEPA has a role in regulating existing and new power stations:
•SEPA regulates the operators of energy generation installations under the Pollution Prevention and Control
(PPC) regime. Proposed amendments to legislation make it likely that carbon capture processes will become
an activity listed under Schedule 1 of the PPC (Scotland) Regulations 2000 (as amended). Operators must
achieve emissions and operational standards and use best available techniques to prevent or, where that is not
possible, minimise emissions according to European standards.
•The Water Environment (Controlled Activities) (Scotland) Regulations 2005 (CAR) require operators of
activities likely to have an impact on water to be authorised by SEPA. Such activities include abstractions,
impoundments, discharges liable to cause pollution, and engineering activities. Guidance on CAR is available
at: www.sepa.org.uk/water/water_regulation.aspx
•SEPA is a statutory consultee on the environmental impact assessment (EIA) conducted for major planning
applications, including applications for consent submitted under the Electricity Act 1989. SEPA engages in the
EIA and planning processes at an early stage in order to address potential environmental issues. Guidance is
available on interaction with the planning process and on specific environmental issues, including an interim
position statement on planning, energy and climate change and planning guidance on SEPA-regulated sites
and processes.
•SEPA reviews air quality management plans and ensures that emissions from regulated installations do not
contribute to exceedances of the UK air quality standards.
•SEPA will provide advice to the Scottish Government as to whether a proposed power station has met the
requirements of the carbon capture readiness guidance provided by the Scottish Government. Plans must
demonstrate that there is adequate space for carbon capture and that there are no barriers to retrofitting
carbon capture equipment in the future.
•In the case of coal-fired power stations, SEPA will provide advice to the Scottish Government as to whether
the applicant has submitted technically feasible plans for a carbon capture unit that is sufficient to cover the
minimum size requirement of at least 300MWe net capacity of the power station, and whether the remaining
capacity of the power station can also be considered ‘capture ready’.
•SEPA regulates waste activities, including reuse, recovery and recycling of waste to reduce the requirement
for virgin materials and energy in manufacturing and production. SEPA also regulates energy recovery from
waste through anaerobic digestion or other waste management processes.
•SEPA is the competent authority for the EU Emissions Trading System (EU ETS) in Scotland. Permits are issued
to eligible installations and SEPA ensures that operators comply with the system’s operational rules. CO2
captured and stored will be considered as ‘not emitted’ under the system.
A Climate Change Plan for SEPA (2008) http://www.sepa.org.uk/idoc.ashx?docid=df8f23f4-25cf-4b1b-8d30-3dd6eb7b0b15&version=-1
34
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SEPA’s Energy position statement
•Currently CO2 is not classified as a ‘dangerous substance’ for the purpose of the Control of Major Accident
Hazards Regulations 1999 (as amended) (COMAH). However, on a precautionary basis, the Health and Safety
Executive (HSE) recommends that early adopters of CCS can best meet their general duties under the Health
and Safety at Work Act by applying the principles of COMAH when designing, constructing and operating
their capture and compression installations. In Scotland, SEPA and the HSE have responsibility for enforcing
the COMAH regulations: SEPA is responsible for environmental issues and the HSE for health and safety issues,
with each regulator leading in their respective field. SEPA and the HSE consult with each other when both
environmental and human health and safety are potentially affected by an installation.
•The introduction of new chemicals to power stations (such as amines) to enable carbon capture has the
potential to bring installations not previously subject to the COMAH regulations within the scope of that
regime.
•SEPA is responsible for regulating the storage and use of radioactive substances and the accumulation and
disposal of radioactive wastes. SEPA uses its powers under the Radioactive Substances Act 1993 (as amended)
to minimise the impact, on both human health and the environment, of radioactive material and waste35.
•SEPA seeks to ensure that resource and energy recovery operations are appropriately located, designed and
operated, through deployment of regulatory, planning and monitoring roles.
•SEPA seeks to influence planning decisions to ensure that all energy and resource recovery installations
are appropriately located and scaled to avoid impacting upon human health and the environment, and to
optimise the potential benefits from such activities – for example through heat recovery and district heating.
A good example is the Lerwick district heating scheme.
•SEPA regulates energy from waste activities under the PPC regulations. Further information is available in the
thermal treatment of waste guidelines32.
5.4.4 The way forward
SEPA supports the policy that new-build power stations should not be permitted to operate without
implementation of suitable CO2 abatement in the future. For the purposes of this document, ‘power stations’
refers to thermal power stations fuelled by coal, oil, gas or biomass. To assess whether or not carbon capture
and storage (CCS) schemes will prove to be a viable method for reducing CO2 emissions to the atmosphere,
SEPA supports the aim of the UK Government to deliver four CCS demonstration plants. These will provide an
opportunity to develop CCS technology on an operational scale.
SEPA is keen to see demonstration CCS projects rolled-out in Scotland as soon as possible. These will inform our
understanding of the economic and technical feasibility of commercial-scale CCS technology.
SEPA is keen to see more Government-led research that considers the impacts of low levels of CO2 leakage from
storage areas on the surrounding ecosystem and further Government-led research into the environmental and
health and safety risks of transporting dense phase/supercritical CO2. For additional information see SEPA’s
published position statement on Carbon Capture and Storage.
SEPA’s role in planning imposes a responsibility on the organisation to comment on both the policies and the
proposals relating to the thermal treatment of waste. SEPA is keen to engage with Local Authorities at an early
stage in the preparation of development plans to explore opportunities for the favourable co-location of thermal
treatment of waste plants and end users.
SEPA would also encourage planning authorities, funders and developers to engage with SEPA at an early stage,
to identify opportunities for synergistic developments that will maximise the efficiency and operational value of
energy from waste facilities, such as combined heat and power and district heating.
The inherent energy value and carbon benefits of using appropriate waste materials for energy generation
should contribute to both energy security and climate change. Further information can be found in the Scottish
Government’s zero waste plan.
Decisions made now should not lock Scotland into a higher than necessary carbon future36.
For further information please see http://www.sepa.org.uk/radioactive_substances/what_we_do.aspx
Bernice Lee, Ilian Iliev and Felix Preston (2009) Who Owns Our Low Carbon Future? Intellectual Property and Energy Technologies, A
Chatham House Report, September 2009.
35
36
SEPA’s Energy position statement
17
5.5 Non-renewable energy
5.5.1 Definition
This can be defined as generation of usable energy from non-renewable sources without carbon abatement or
resource recovery activities. These are existing proven sources of energy supply, which often include coal, oil and
gas. Whilst these approaches may be understandable or even economic at present, they have unsustainable local
and global impacts, and have questionable security of supply in the medium term, hence the low position of nonrenewable energy in the energy hierarchy.
5.5.2 Environmental aspects of non-renewable energy
Combustion of fossil fuels releases substances, including carbon dioxide, into the atmosphere, which have local
and global environmental and health impacts. Thermal electricity generation also depletes finite resources and
uses water resources in the process, due to the abstraction of water for coolant purposes and the subsequent
return of the cooling water to the water environment. There is significant risk of pollution to all environmental
media, and the process produces wastes that must be stored or disposed of.
5.5.3 SEPA’s approach
SEPA regulates thermal electricity generating installations under the Pollution Prevention and Control (PPC)
regime. Operators must achieve emissions limit values specified in their permits and must ensure that they use
the best available techniques to prevent or, where that is not possible, minimise emissions to the environment.
SEPA also has duties regarding local air quality management and ensures that regulated operators do not exceed
the UK air quality standards, which protect human health. SEPA is also a statutory consultee on major planning
applications.
5.5.4 The way forward
•New energy developments should seek to demonstrate that environmentally damaging practices are balanced
by clear social or other benefits that outweigh the environmental damage.
•SEPA would like to see consideration and inclusion of CO2 performance standards and mitigation within best
available technique reference documents.
•SEPA seeks a review of EU environmental policy and regulatory instruments to ensure a fit with the climate
change agenda, and to identify conflicting areas and methodologies to facilitate decisions to be made on
these.
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SEPA’s Energy position statement
6 Storage, grid and infrastructure
6.1 Background
Increasing the contribution of intermittent renewable generation – such as wind energy – to the grid requires
grid changes and augmentation. The physical location and scale of renewables means that energy storage and
enhanced grid interconnection will be necessary to balance the grid and provide reliable peak demand supplies.
This must be supported by smart systems that provide the capability to limit peak demands37. This reduces
the need to rely on conventional, responsive installed capacity – as typically used in gas-fired power stations.
Reducing this reliance on backup generation capacity is central to both true energy security and a lower carbon
future.
SEPA welcomes the Scottish Government’s commitment to commissioning research on the potential for energy
storage in Scotland as a means of supporting renewable energy deployment. The work will consider the available
technologies and timescales for development38.
6.2 The way forward
SEPA seeks an integrated and holistic view of energy infrastructure needs that considers energy in all its forms,
including heat infrastructure, to enable the range of different sources, scales and methods of generation.
SEPA has been involved with the development of Scotland’s low carbon economic strategy and supports
development of low carbon environmental and clean technologies sector. With numerous new energy
technologies under development – from the burgeoning offshore wind and marine energy sector, to novel
techniques such as marine biomass and osmotic pressure generation – SEPA will seek to engage early to
proactively support, advise and assist in delivering environmentally appropriate low carbon energy solutions.
S uch smart systems include modernised electricity grid with larger capacity and the ability to manage greater fluctuations in supply, while
maintaining security of supply. This larger, smarter grid, together with other elements of the new electricity system, such as smart meters,
microgeneration of electricity by individuals and businesses, smart appliances and electric vehicles, will also offer consumers a whole set of
new opportunities for greater control over and choice in how they use electricity. See DECC.
38
Scottish Government Renewables Action Plan 2009
37
SEPA’s Energy position statement
19
7 Conclusion
This statement has sought to outline SEPA’s role within the broad-ranging energy arena. It has set out SEPA’s
main functions and purposes and highlighted areas of focus for future work. The importance of reducing impacts
on the climate must not be downplayed: this is a serious threat and SEPA will contribute to meet the Scottish
Government’s targets on climate change through the delivery of its duties and powers and through leading by
example in its own internal environmental performance. Energy, climate change and the quality of Scotland’s
environment remain intrinsically linked while the energy system is still so reliant upon non-renewable fuels. There
is an opportunity to change this, however, by reducing demand, improving efficiency, finding and supporting
sustainable lower carbon technologies and ensuring that energy and resources are recovered. A successful
transition to a low carbon economy will require us to harness Scotland’s environmental resources within
environmental limits. SEPA will therefore play a central role in advising, influencing, regulating and monitoring
the environmental impacts of changes in Scotland’s energy supply, transmission and consumption, ensuring the
continuing health and improvement of our environment that is vital to long term sustainable economic growth.
20
SEPA’s Energy position statement
Appendix A: Background information
A1 Background and context
The following section provides contextual background information on energy production and consumption in
Scotland, as well as information on electricity generation.
A1.1 Energy in Scotland
The overall picture of energy flows in Scotland is outlined in Figure A1 below, produced for the Scottish
Government as part of its Scottish energy study series.
Figure A1: Energy flows in Scotland in terawatt hours(TWh)39 40
The input contributions of fuels to the overall primary energy supply are spread across different sources, with
the largest demand proportion from natural gas, then oil, with coal and nuclear providing approximately equal
contribution to total energy demand. The small remainder is from renewables. Natural gas, oil (especially for
transport) and electricity are the predominant forms of energy supplied/delivered to end-users in Scotland.
However, coal and nuclear fuel also make significant contributions via electricity generation.
In terms of energy demand, the main end-use sectors in Scotland are, in decreasing order of energy consumption,
domestic, transport, industry and services, as shown in Figure A2.
A1.1.1 Electricity generation
The data below in Table A1 outline the sources of electricity generation in Scotland. Figure A3 illustrates the
installed capacity in Scotland from different electricity sources. This illustrates that Scotland relies upon multiple
energy sources for its electricity, dominated by nuclear, coal and gas, but with a growing proportion coming from
renewables. The proportion generated by renewable sources has doubled between 2000 and 2008; a trend set to
continue and accelerate in the next decade.
1TWh = 1 million million watt-hours.
Scottish Energy Study: Volume 1: Energy in Scotland: Supply and Demand
39
40
SEPA’s Energy position statement
21
Scotland’s installed generation base consists of a broad mix of generation technologies and fuel types. Power is
supplied by a combination of large base-load plants, including nuclear, coal and gas-fired units, hydro generation,
both conventional hydro and pumped storage, and a number of other renewable sources.
Figure A2: The electricity generation mix in Scotland, 201041
0.1 GW
2.4 GW
2.1 GW
Nuclear
Gas
Coal
0.7 GW
1.8 GW
1.3 GW
Hydro - conventional
Hydro - pumped
Wind and other renewables
Oil
Total installed generation
capacity of 12.1 GW
3.6 GW
Scotland’s electricity industries typically produce a surplus of generation output and this is exported into
wider electricity markets in England, Wales, and Northern Ireland. The interaction of the Scottish and other
UK networks therefore plays an important role in system balancing and supply security north of the border.
Although power flows are predominantly north to south, flows in the opposite direction also occur and are likely
to be of increasing importance as the grid is augmented and potentially extended to other connections. Grid
interconnection is essential in enabling lower carbon intermittent sources to play an increasing role.
Figure A3: Sectoral energy split in 200242
34%
29%
Domestic
Industry
Services
Transport
16%
21%
Table A1 provides historical data on the composition of the Scottish electricity sector disaggregated by the
different forms of generating technology.
The figures show the marked increase in the use of renewable energy sources for electricity generation. This
growth has largely been driven by a rapid increase in on-shore wind farms, as Table A1 shows. According to
the Scottish Government, by October 2008 the amount of installed capacity in Scotland from renewables had
reached just over 3GW, with a further 5.5GW of plant consented (not necessarily constructed).43
Source: Wood Mackenzie, Scotland’s Generation Advantage, 2009.
Source: Scottish Energy Study 2006
43
http://www.scotland.gov.uk/Topics/Statistics/Browse/Environment/seso/sesoSubSearch/Q/SID/98
41
42
22
SEPA’s Energy position statement
Table A1: Electricity generated by different power sources (GigaWatt hours)
2000
2001
2002
2003
2004
2005
2006
2007
2008
Nuclear
16,918
18,097
15,828
18,394
18,013
18,681
14,141
12,344
15,079
Coal*
16,624
15,408
14,861
14,566
13,080
12,158
17,560
13,877
11,767
Gas and oil
11,275
10,898
13,244
12,059
12,226
11,270
12,401
12,430
12,984
613
534
622
670
786
643
1,184
1,198
1,091
4,665
3,738
4,455
2,902
4,475
4,613
4,225
4,697
4,714
217
245
406
449
848
1,281
2,023
2,644
3,330
Landfill gas
69
109
157
228
339
395
424
487
502
Other biofuels**
21
110
80
146
170
197
291
392
445
45430
44937
44555
45689
44105
42752
45286
39849
40921
4972
4202
5098
3725
5832
6486
6963
8220
8991
Hydroelectric (pumped)
Hydroelectric (natural)
Wind and wave
Total non-renewables
Total renewables
Total energy consumption
50402
49139
49653
49414
49937
49238
52249
48069
49912
% of total gross
consumption from
non-renewables
90.14%
91.45%
89.73%
92.46%
88.32%
86.83%
86.67%
82.90%
81.99%
% of total gross
consumption from
renewables
9.86%
8.55%
10.27%
7.54%
11.68%
13.17%
13.33%
17.10%
18.01%
2007
2008
*Coal includes a small quantity of non-renewable wastes
**Other biofuels includes biofuels co-fired with fossil fuels
Figure A4: Scottish electricity generation by source44
Scottish Electricity generation by source
60,000
GigaWatt hours
50,000
40,000
30,000
20,000
10,000
0
2000
2001
2002
Nuclear
Hydroelectric (natural)
2003
2004
2005
2006
Year
Coal
Gas and oil
Wind and wave
Landfill gas
Hydroelectric (pumped)
Other biofuels
According to Renewable UK45, “no energy technology can be relied upon 100% of the time”. The load factor of
electricity generating plant is the ratio (as a percentage) of the net amount of electricity generated by a power
plant compared to the net amount which it could have generated if it were operating at its net output capacity.
This is detailed in Table A2. Different energy technologies have different load factors; no individual power plant
is always available to supply electricity. All power stations have periods when they are unavailable – whether for
routine maintenance or for unexpected reasons. As wind is variable, the probability that it will not be available at
any particular time is higher. Wind energy has a lower load factor than many other technologies, as shown in the
table, but this is compared to the maximum power the turbine can give out, not its average.
Source: Scottish Government and UK Department for Business, Enterprise and Regulatory Reform.
http://www.bwea.com/energy/rely.html
44
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SEPA’s Energy position statement
23
Table A2: Electricity load factors46
Energy technology
Load factor
Sewage gas
90%
Farmyard waste
90%
Energy crops
85%
Landfill gas
70-90%
Combined cycle gas turbine (CCGT)
70-85%
Waste combustion
60-90%
Coal
65-85%
Nuclear power
65-85%
Hydro
30-50%
Wind energy
25-40%
Wave power
25%
A1.2 Employment and socio-economic benefits of energy
According to statistics from the Scottish Government, there are around 160,000 workers in the energy sector in
Scotland (approximately 6-7% of the workforce), with some 145,000 of these in the oil and gas sector (around
30,000 of which are offshore) spread between around 2,000 firms, and upwards of 12,000 employees in the major
power generation companies in Scotland47.
In terms of renewable energy technologies, current members of the industry’s main trade association employ
around 2,600 people in Scotland48. Of this total, nearly 1,100 are employed in wind energy, 620 in hydro, 190 in
wave and tidal and 150 in micro-generation49.
A1.3 Energy and the environment
Energy generation, transmission and consumption have environmental consequences, impacting on the air, water,
land and natural heritage of Scotland, and emissions of greenhouse gasses impact on the global climate. SEPA’s
main role is to protect and improve the environment; it regulates activities that can cause pollution and monitors
the quality of Scotland’s air, land and water. Energy impacts include atmospheric pollution that is harmful
to health and ecosystems; water pollution, in terms of emission of substances and heat, affecting freshwater
and marine systems, and alteration of natural regimes and hydrology; consumption of finite natural resources;
production of wastes and associated odour; and land impacts.
A1.3.1 Energy and Climate Change
“…to fix climate change, we need to sort out a new way of getting energy. The climate problem is mostly an
energy problem,” David JC MacKay 2008.50
Consumption of certain fuels (eg coal or gas) for energy production results in the emission of carbon dioxide
(CO2), which contributes to climate change. The Scottish climate change programme has a number of
initiatives in place aimed at reducing the emissions of CO2, and other greenhouse gases. SEPA has a key role in
implementing and regulating some of the initiatives that aim to deliver these emission reductions. These include
being the regulator in Scotland for the European Union emissions trading system (EU ETS) under the Greenhouse
Gas Emissions Trading Scheme Regulations 2005, and the administrator for the carbon reduction commitment
energy efficiency scheme and being empowered to include energy efficiency conditions in permits for part A
installations or mobile plant under the Pollution Prevention and Control Regulations (PPC).
http://www.bwea.com/energy/rely.html
Scottish Government. (2009) www.scotlandistheplace.com, industry factsheet. Scottish Government.
47
Scottish Renewables. (2007) Scottish Renewables Economics Impact Report. Scottish Renewables.
49
Scottish Renewables. (2007) Scottish Renewables Economics Impact Report, p8. Scottish Renewables
50
David JC MacKay 2008 Sustainable Energy — without the hot air, Version 3.5.2. November 3, 2008. www.withouthotair.com
46
46
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SEPA’s Energy position statement
Table A3: Scotland’s greenhouse gas net emissions by sector, 200651
Baseline
(1990-95)
Mt CO 2e
22.31
2006
Mt CO 2e
23.91
Change
(baseline to
2006)
Mt CO 2e
1.60
Transport
11.18
12.69
1.51
Business and
industry
12.60
8.06
Sector
Energy supply
Change
(baseline to
% of
2006)
Scottish net
% emissions 2006
7.2%
40.5%
% of
UK
2006
10
13.5%
21.5%
9
-4.54
-36.1%
13.6%
7
Agriculture
9.65
7.88
-1.77
-18.4%
13.3%
16
Residential
7.87
7.49
-0.39
-4.9%
12.7%
9
Waste
management
5.77
2.52
-3.25
-56.3%
4.3%
11
Public
1.31
0.99
-0.32
-24.1%
1.7%
9
Land use change
All sectors
-2.52
-4.49
-1.97
78.4%*
-7.6%
226
68.17
59.04
-9.12
-13.4%
100.0%
9%
*Denotes positive increase as a net sink.
In 2006 Scotland emitted 59.04 million tonnes of CO2 equivalent52, largely resulting from the production and
consumption of energy53. Emissions reductions have been achieved in numerous ways, including a reduction
through energy efficiency improvements. These have been offset to a significant degree, however, by increases
from greater use of fuel for transport. An important feature is the change in the mix of different fuels used by
end consumers and by producers to generate electricity at Scotland’s power stations. Figure A4 below shows the
observed trends in Scottish greenhouse gas emissions from 1990 to 2005. The red line shows the level of ambition
set by the 80% reduction in Scottish greenhouse gas emissions (relative to 1990 emission levels) by 2050, as
set by the Climate Change (Scotland) Act 2009. Research has concluded that Scottish electricity production is
currently responsible for around 14 Mt of CO254. Other significant emitters are industry, residential, agriculture
and transport.
It is worth noting that CO2 is also emitted from activities other than the generation and use of energy. In
particular, it is emitted by a range of natural processes and from various land-use activities, especially from
disturbances to peaty soils.55
A1.4 Policy and legislative energy and climate change drivers
There are numerous policy and legislative drivers relating to energy at different levels: international, European,
UK and Scottish. Those of principal interest to SEPA, due to their environmental focus, are summarised below.
Source: AEA Energy and Environment http://www.scotland.gov.uk/Publications/2009/06/17154101/5
Carbon dioxide equivalency is a quantity that describes, for a given mixture and amount of greenhouse gas, the amount of CO2 that
would have the same global warming potential (GWP), when measured over a specified timescale (generally, 100 years). The carbon dioxide
equivalency for a gas is obtained by multiplying the mass and the GWP of the gas. http://en.wikipedia.org/wiki/Carbon_dioxide_equivalent
53
Scottish Greenhouse Gas Emissions 2007
54
Scottish Government. (2008) Mitigating Against Climate Change in Scotland, p12.
http://www.scotland.gov.uk/Resource/Doc/245862/0069408.pdf
55
Source: http://www.scotland.gov.uk/Publications/2008/09/08110631/10
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SEPA’s Energy position statement
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Figure A5: Net Scottish greenhouse gas emissions56
Key: CO2 (Carbon Dioxide), CH4 (Methane), N2O (Nitrous Oxide), HFCs (Hydrofluorocarbons),
PFCs (Perfluorocarbons), SF6 (Sulphur Hexafluoride)
A1.4.1 International
Several international drivers for action are summarised below. These have informed EU and domestic policies.
Largely these relate to climate change and form the highest level policy drivers for SEPA’s engagement with
energy issues.
•United Nations Framework Convention on Climate Change (UNFCCC), an early climate change convention,
considering actions to reduce global warming and to cope with whatever temperature increases are
inevitable. More recently, a number of nations approved an addition to the treaty: the Kyoto Protocol, which
has more powerful (and legally binding) measures. The Copenhagen Accord, agreed in December 2009, was
informed by the research of the Intergovernmental Panel on Climate Change.
•The central feature of the Kyoto Protocol is its requirement that countries limit or reduce their greenhouse
gas emissions. By setting such targets, emission reductions took on economic value. To help countries meet
their emission targets, and to encourage the private sector and developing countries to contribute to emission
reduction efforts, negotiators of the protocol agreed to three market-based mechanisms: emissions trading,
the clean development mechanism and joint implementation.
A1.4.2 European
International agreements and member states’ priorities drive development of EU policies and legislation that in
turn drive energy and environmental action.
•National Emissions Ceilings Directive (NECD) sets upper limits for each member state for the total emissions
in 2010 of the four pollutants responsible for acidification, eutrophication and ground-level ozone pollution:
sulphur dioxide, nitrogen oxides, volatile organic compounds and ammonia.
•Large Combustion Plant Directive (LCPD) applies to combustion plants with a rated thermal input equal to
or greater than 50 MW, irrespective of the type of fuel used (solid, liquid or gaseous). Its purpose is to limit
the amount of sulphur dioxide, nitrogen oxides and dust emitted from large combustion plants each year. It
encourages the combined production of heat and electricity (cogeneration).
S cottish Government. (2008) Mitigating Against Climate Change in Scotland, p6.
http://www.scotland.gov.uk/Resource/Doc/244863/0068651.pdf
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SEPA’s Energy position statement
•Ambient Air Quality and Cleaner Air for Europe Directive (AAQD): The merging of most of existing legislation
into a single directive (except for the fourth daughter directive) with no change to existing air quality
objectives.
•New air quality objectives for particles measuring 2.5 µm or less (PM2.5) including the limit value and
exposure-related objectives.
•Exposure concentration obligation and exposure reduction target.
•The possibility to discount natural sources of pollution when assessing compliance against limit values.
•The possibility of time extensions of three years for particles measuring 10µm or less (PM10), or up to five
years for NO2 and benzene for complying with limit values, based on conditions and the assessment by the
European Commission.
•Climate Change and Energy Package (CCEP): In 2008 the European Commission agreed proposals to deliver on
the European Union’s commitments to tackle climate change and promote renewable energy up to 2020 and
beyond, aiming to make the EU a low-carbon economy with increased energy security. The EU is committed
to reducing its overall emissions to at least 20% below 1990 levels by 2020, and is ready to scale up this
reduction to as much as 30% under a new global climate change agreement when other developed countries
make comparable efforts. It has also set itself the target of increasing the share of renewables in energy use
to 20% by 2020. Expansion of emissions trading was a central part of this package.
•Phase three of the EU Emissions Trading System (EUETS) (2013 to 2020) requires electricity generators in
all but a small number of member states to buy all their emissions permits at auction. This is intended to
stimulate the development of low-carbon electricity generation.
•Industrial Emissions Directive (IED) recasts seven existing directives related to industrial emissions into a single
clear legislative instrument. The recast includes the IPPC Directive, the Large Combustion Plants Directive, the
Waste Incineration Directive, the Solvents Emissions Directive and three directives on Titanium Dioxide.
•Water Framework Directive (WFD): This came into force in 2000 and is the most substantial piece of EU water
legislation to date. It intends to safeguard and improve water quality and looks at the condition of biota in
the water and other chemical and morphological factors in order to determine ecological quality. The WFD
requires all inland and coastal waters to reach ‘good’ status by 2027 at the latest. Member states will do this
by establishing a river basin district structure within which environmental objectives will be set, including
ecological targets for surface waters. The requirements set out in the WFD apply to all surface freshwater
bodies (such as lakes, streams and rivers), groundwater, groundwater dependent ecosystems, estuaries and
coastal waters. ‘Coastal water’ means water (other than groundwater) within the area extending landward
from the three mile limit, up to the limit of the highest tide. As well as improving the ecological health of
inland and coastal waters and preventing further deterioration, the WFD also hopes to encourage more
sustainable use of water as a natural resource.
A1.4.3 UK
The UK Committee on Climate Change57 is an independent body established under the Climate Change Act to
advise the UK Government and devolved administrations on setting carbon budgets, and to report to Parliament
on the progress made in reducing greenhouse gas emissions. It recommended the need to decarbonise electricity
supply by 2030 as, without changes in energy supply, the UK will not meet climate targets. Further information
on the main UK policy and legislative instruments can be found on the Department for Energy and Climate
Change website.58
UK Low Carbon Transition Plan: notes that: “In 2008 the UK imported about 25% of the gas that it used.
Projections suggest that by 2020 this could rise to around 60%. But with the measures in this plan, especially
those which help to decarbonise our electricity supplies and increase our heat efficiency, we can reduce this to
45%.”
http://www.theccc.org.uk/
http://www.decc.gov.uk/en/content/cms/what_we_do/lc_uk/lc_uk.aspx
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A1.4.4 Scotland
The Scottish Government has stated that its: “clear focus is to increase sustainable economic growth and to
raise economic performance, while at the same time reducing our impact on the planet.”59 The Climate Change
Scotland Act 2009 includes targets for Scotland to cut its emission of greenhouse gases by at least 42% by 2020
and at least 80% by 2050. A number of different policy and legislative instruments contribute to these targets.
More information is available from the Scottish Government on:
•Climate Change actions
•Energy actions
http://www.scotland.gov.uk/Topics/Environment/climatechange/scotlands-action
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