Inquiry into Feed-in Tariff Arrangements
and Barriers to Distributed Generation
Submission number:
DRFT-187
Name of participant:
Andrew Lang
Date received:
18 June 2012
Number of Earlier
Submissions:
0
Number of Pages:
2
Comments:
If you are experiencing difficulty accessing this submission please email
feedintariff@vcec.vic.gov.au or phone on 03 9092 5800
Comment on Draft Inquiry into distributed generation
Andrew Lang
World Bioenergy Association, vice president board & member for AustralasiaOceania
Convenor- The Wood Energy Group
Member - Central Highlands Agribusiness Forum
Summary
The structure and content of the report is useful, and the data has to be assumed to be
accurate, but there are two major areas of concern that should be addressed.
Firstly, that constantly throughout the report there is confusion in use of the terms
‘energy’ and ‘electricity’.
‘Energy’ includes all forms of energy, and particularly heat energy, transport fuels
(chemical energy) and electrical energy. However in this report it is constantly used as
being synonymous with ‘electricity’, and in almost every case where ‘energy’ is used
here it is in reference to electrical energy or electricity.
This constant error is a matter of scientific illiteracy and it should not be seen in a
report at this level (or anywhere else), and must be corrected. Any alert VCE Physics
student should be able to put the writers of this report straight on this matter.
Secondly, there is a bias or assumption that the main forms of distributed energy in
Victoria are solar PV and wind, with only solar PV seen as the source of smaller scale
electricity (apart possibly from one mention of small-hydro).
In fact, in Table 1. the contribution of biomass has been split three ways and a forth
existing bioenergy source (combustible biomass to energy) is ignored. Generally
ignored is the potential for small-scale and medium-scale contribution of biomass as
is the case across Europe and increasingly in North America and other regions
(including India, China, Brazil, Russia and the former soviet countries). Across these
countries and regions are many examples of use of straw, woody biomass and
combustible non-recyclable municipal wastes for energy production, including of
electricity, at all scales from 50 kW up to over 200 MW-e.
Black liquor, sewage gas, biowaste, landfill gas are all within the overall category of
biomass (along with industry biogas production and woody and agricultural residues),
and in fact biomass in Victoria is producing approximately as much electricity as
wind annually. Across Australia Biomass is only second to hydro in production of
electricity.
The use of capacities for the renewable energy sector is a very confusing choice for
most civilians (and is often misused by groups wanting to makes statistics sound
better for solar PV and wind) and this form is not used as the main figure for
reference or comparison in countries like Germany. There the comparisons between
different forms of renewable energy, and for the contribution of the renewable
electricity sector particularly would be by megawatt-hours MWh (or GWh) of
electricity produced over the year.
So electricity production from large wind turbines in Victoria averages less than 35%
and normally is about 30% of rated capacity, while for household solar PV production
is usually only about 20% of capacity over the year, and in some areas down towards
15%. To use the capacity figure alone without mentioning this issue could be seen as
a deception on the reading public.
Thirdly there are a number of issues or technologies simply not mentioned in this
report, and so some important terms are not included in the glossary. These include
the option for
 biogas production from the large amount of putrescible wastes presently going
to landfill, or otherwise not utilised (ie cow manure and dairy wash-down
water)
 use of combustible wastes and other biomass
 co-firing biomass with fossil fuels
 small electricity generating systems of down to 1 kW capacity utilising
biomass or combustible waste, including gasification, and the developing area
of heat engines, small ORC turbines and stirling engines
So in the glossary there is no entry for bioenergy, biomass, biogas, electricity (vs
energy), energy (vs electricity), or gasification.
While the entry for ‘renewable energy’ needs to be looked at in the light of the
comments I have made, and perhaps there needs to be a ‘renewable electricity’ entry.
In actuality the biomass available in Victoria has the potential to be producing over
20% of current electricity needs, up to 50% of heat energy needs and over 30% of
transport fuels needs. In light of this the real questions are –
1. Why is this report so dominated by issues of solar PV and wind (non-demand
forms of renewable electricity that do not displace baseload generation, and
particularly in the case of solar PV are definitely not cost-competitive).
2. Why has solar PV been so artificially supported in this state when it is not an
on-demand form of electricity (and so does not effectively reduce need for
fossil fueled electricity generation).
3. Conversely, why have the bioenergy technologies not been recognised for
their ability to produce on-demand electricity (and heat and transport fuels)
that is at least as cost-competitive with on-shore wind (on a levelised cost
basis) while being on-demand, resulting in far more job creation, and utilising
wastes and residues that otherwise are mostly free-burned or go into landfill
with GHG emissions.
4. Why has Victoria not developed a stimulus to energy generation that includes
recognition of, or values, production of low emission (ie non-fossil fuel) heat
and transport fuels.
5. Why is the primary drive and rationale for feed-in-tariffs not based on
primarily on stimulus of systems than genuinely reduce need for energy
generated in some cost-effective and cost competitive way: i.e., the various
on-demand forms of renewable energy – geothermal heat pumps, small hydro
and biomass and waste to energy.