SC(3) CR-E9

Sustainability Committee

Inquiry into Carbon Reduction in Wales: Electricity Generation (including renewable energy)

Response from Wales Environment Link

Wales Environment Link (WEL) is a network for environmental non-governmental organisations in Wales, most of whom have an all-Wales remit. WEL is officially designated the intermediary body between the government and environmental non-governmental organisations in Wales. Our vision is to increase the effectiveness of the sector in its ability to protect and improve the environment through facilitating and articulating the voice of the sector.

How WEL has come to agree this response

The production of consultation responses within the WEL network is an inclusive and comprehensive process. Whilst WEL recognises that all consultation responses must be given equal treatment, we would ask the Committee to note WEL’s protocol for writing consultation responses, as well as the number of organisations that have signed up to this response.

1. WEL’s Energy and Transport Working Group met to discuss and agree common positions within the group.

2. Attendees were asked to contribute to drafting the response.

3. Co-ordinator circulated first draft around WEL members via email, members provided comments and suggested improvements to wording.

4. Any point over which there was disagreement was further discussed via email.

5. A second draft was sent around the relevant WEL e-groups and Council, inviting further comments and sign-up.

6. The final draft was circulated to WEL Council and relevant e-groups offering a final chance to sign up.

WEL is pleased to be given this opportunity to respond to the consultation document of the Assembly Sustainability Committee concerning carbon emissions reduction by energy generation.

NB. On the 13th of March at the Climate Change Commission meeting, the Welsh Assembly Government presented figures that may answer some of WEL's questions below. WEL will now need to consider these figures in detail. Assembly Members will hear this announcement from the Minister at Plenary on the 8^th of April.

General questions

1a) Is the proposed 3 per cent annual reduction target by 2011 'in areas of devolved competence' sufficient to enable Wales to make its full contribution to meeting UK-wide targets?

This question is phrased with reference to the aim set out in the section 'Tackling climate change’ in One Wales (June 2007), to achieve 'annual carbon-equivalent emission reductions of 3% per year by 2011 in areas of devolved competence’.  It raises the following issues:

• What are the WAG 'areas of devolved competence’?
• Which are the UK-wide targets to be met?
• What is meant by Wales’ 'full contribution’ to these targets?

Taking each of these issues in turn:

Areas of devolved competence

One Wales says that specific sectoral targets will be set for each of the residential, public and transport areas, while WAG will 'work with’ the heavy industry and power generation sectors to reduce their respective emissions. It is unclear just how much 'competence’ WAG currently has to manage directly carbon emission reductions, even within the three sectors suggested in One Wales.  Powers of exhortation do not equate to 'competence’.

At an immediate level, the Assembly Government should be asked both to define the 'areas of competence’ within which it is empowered to act, and to clarify what it believes it can do to deliver on the 3% target within these areas. Additionally, the Assembly Government must both examine urgently its current scope for influencing downwards carbon emissions from Wales-based sources, and also identify areas for extending, in particular, its powers to regulate energy use in homes, businesses and transport through an appropriate Legislative Competence Order or Orders.  

Schedule 5, Part 1, of the Government of Wales Act 2006 lists the policy Fields for which primary legislative powers in the form of Measures could be sought by means of Legislative Competence Orders. Of particular relevance to this consultation, Schedule 5 lists agriculture, economic development, environment, highways and transport, and housing as being within the potential legislative remit of the Assembly.  No exceptions or restrictions are listed.

Schedule 7 of the Act, however, lists exceptions to those Matters for which such legislative competence could be sought, but only with reference to Acts of the Assembly under section 103 et seq. Exceptions listed having relevance to this consultation on carbon emissions include:

• Generation, transmission and supply of electricity, apart from pollution.
• Energy conservation, apart from the encouragement of energy efficiency otherwise than by prohibition or regulation.
• Oil and gas, apart from pollution.
• Road freight transport services…
• Regulation of use of motor vehicles and trailers on roads…
• Provision and regulation of railway services, apart from financial assistance, which (a) does not relate to the carriage of goods…
• Aviation, air transport, airports and aerodromes, apart from (a) financial assistance to providers or proposed providers of air transport services or airport facilities or services, (b) strategies by the Welsh Ministers or local or other public authorities about provision of air services…

According to Schedule 7, therefore, significant public policy areas relating to carbon emission reduction are outside even the potential 'devolved competence’ of the Assembly Government; (although there is no similar restriction in the provisions of Schedule 5).  Moreover, of course, much private sector activity in general, including industry and the household sector, lies beyond the Assembly Government’s legislative or regulatory remit.

However, a lack of powers must not become an excuse for Wales not to reduce carbon emissions. Joint working with the UK Government in non-devolved areas, including areas of competence that are likely to remain at the UK level, should be urgently sought and reported upon. Delivering the requirements of the Climate Change Bill, once enacted in 2008, will test the resources of the Assembly Government and its sharing of responsibilities with Westminster.

UK-wide targets

The UK-wide targets to which the One Wales emissions reduction target might be expected to relate include:

• CO₂ emissions reduction of 20% by 2010 from the UNFCCC baseline year of 1990 (domestic UK Government target).
• Greenhouse gas emissions reduction target of 12.5% by 2010 from 1990 (Kyoto Protocol target within the EU 'basket’ reduction of 8%).
• Climate Change Bill provisional targets of 26/32% by 2020 from 1990 and of 60% by 2050 from 1990.
• Defra have now said that there will be a statutory review of the 2050 target, with the Committee on Climate Change to advise as to whether to amend to 80%.
• EU CO₂ emissions reduction of 20% by 2020 from 1990, rising to 30% with broader global participation.

The One Wales emissions target clearly fails on two fronts: the restriction to 'areas of devolved competence’ - 3% of only a part of total Welsh emissions, rather than of all Welsh emissions; and the commitment only to 'aim to achieve’ - not even to 'deliver’ - by 2011, thus only an aspiration and, of course, missing the 2010 UK/Kyoto target dates.

The findings of the IPCC 4^th Assessment Report (2007) show that urgent action is required to limit emissions to the 400ppm atmospheric concentration of CO₂ thought necessary to avoid breaking the crucial 2°C threshold. Permitting CO₂ levels to rise to 550ppm would, according to the IPCC, result in average global surface temperature increases in excess of 3C, possibly leading to runaway global warming from natural processes, including massive releases of stored methane. It is therefore essential that a continuous decrease in emissions begins immediately and progresses continuously.

With regard to the 2020 and 2050 UK and EU CO₂ targets, clearly the One Wales target cannot deliver on its own. Firstly, emissions reductions will be required from all sectors of the Welsh economy and society, extending well beyond the limited competence of the Assembly Government; and secondly, Wales will need to deliver at least a 20% CO₂ emissions reduction from current levels in just 13 years - or nine years if from a baseline of 2011.  

Wales-based CO₂ emissions in  2005 were 3.7% lower than for the base year of 1990,  having risen significantly between 2002 and 2004. These recent increases, of course, had largely been driven by rising emissions from heavy industry in Wales, and they point up the seemingly unmanageable task faced by WAG, at least with existing policies.

Full contribution

Whether the Assembly Government target will prove 'sufficient’ to enable Wales to make its 'full contribution’ to UK emissions targets has been answered in the negative above.  

This conclusion is made on the basis that Wales should be required to contribute to emissions reduction pro rata to its share of the UK population. However, while Wales accounts for around 5% of the UK population, it contributes 7% of CO₂ emissions, which, in turn, is the result of Wales having a disproportionately large heavy industrial base and being a net exporter to England of electricity generated from carbon-emitting fossil fuel sources.

A further consideration is the low per capita GDP of Wales compared to most regions of England, especially London and the South-East, suggesting the possibility of lower direct household and transport emissions per capita. This circumstance might suggest a lower reduction target for Wales, relative to share of UK population, balanced by a higher target for the wealthier regions of England (on the 'contraction and convergence’ model of emissions reduction). This issue is considered further in answer to question 2 below.

1b) If not, what targets should be put in place?

General scientific opinion now believes that the necessary CO₂ emission reduction target for the UK and other industrialised countries by 2050 should be 80% and not 60%. Wales is coming late to the task of cutting carbon emissions, but practical ways forward are available under current areas of competence, and should be acted upon with urgency.

While we have welcomed the commitment to targets of a kind, the restriction to 'areas of devolved competence’ represents only a part of total Welsh emissions. In addition, the date by which this is to be achieved, 2011 misses the opportunity to contribute to the 2010 UK / Kyoto targets and for every year we delay, makes the annual cut necessary, to reach an 80% reduction by 2050, increasingly more challenging.

With respect to the complexities of devolution, WEL believes that Climate Change poses such a serious threat to people and biodiversity in Wales and around the world, that a bilateral agreement must be reached with the UK Government so that this targeted reduction of at least 3% per annum can apply to the Welsh economy as a whole, with both Governments working towards this agenda.

WEL advocates:

• Wales making a fair contribution towards the international effort to stay below 2ºC warming;
• Delivering a reduction in CO₂ emissions of at least 80% by 2050, which equates to at least a 3% cut each year - starting now and in all sectors (not just those specified in One Wales);
• Specific annual targets in each sector should be at least 3%, and more wherever possible.

2. Should the emission reduction target be based on Welsh consumption, or production, or both (i.e. should it take into consideration the carbon dioxide generated in Wales (production), or the carbon dioxide emissions that Wales' residents are responsible for, regardless of their source (consumption)?

National or country emissions of CO₂ and other greenhouse gases are conventionally measured from sources within the territory concerned; this is how the UNFCCC, EU, UK and WAG have measured carbon emissions. For international comparative purposes, therefore, Wales should continue to measure emissions - and set targets - with reference to Wales-based sources, i.e. the 'production’ approach.

However, the alternative 'consumption’, or footprint, approach provides a measure that is more relevant to sustainability, since it gives a truer expression of the impact of human activity in Wales on global carbon emissions, including net global resource consumption.  This measure is certainly relevant to the SD Scheme and, noting the net 'export of emissions’ from Wales associated with the outputs of heavy industry and energy generation, gives a more accurate picture of Wales’ contribution to overall UK carbon emissions.

The 'production’ model shows per capita CO₂ emissions for Wales 40% higher than for the UK as a whole, while the 'consumption’ or footprint model shows Welsh emissions slightly lower than for the UK overall. Consumption of Welsh-produced steel and fossil fuel electricity outside Wales needs to fall in order to bring down total Wales-sourced emissions while, conversely, a reduced Welsh footprint (through reduced consumption of products or lower use of energy in transporting them) will bring down CO₂ emissions globally.

Both models for measuring Welsh CO₂ emissions, therefore, have value, and data for each should be collected and used, as appropriate: the 'production’ model should be used in relation to externally agreed target levels, while the 'consumption’ model should be used to inform the SD Scheme and Action Plan.

Questions specific to carbon reduction from energy generation

3. What particular challenges does Wales face in reducing carbon dioxide emissions from energy generation, and how can these challenges be overcome?

WEL members are in favour of de-carbonising energy generation. We would therefore regard the following as challenges to achieving this:

• The Welsh Assembly Government’s lack of legislative and planning competence in relation to important areas of energy policy (see qu.8);
• The expectation that the 250 million tonnes of coal estimated to be present underground in Wales should be mined and used, with the development of CCS (Carbon Capture and Storage) technologies used in justification;
• Reliance in England upon imported Welsh electricity - the WAG Renewable Energy Route Map suggests that all, or virtually all, of Welsh electricity needs could be met by 2025 from Welsh renewable sources; however, fossil fuel generation could be needed to meet additional English electricity demand;
• High reliance on oil fuel heating in rural areas due to lack of mains gas;
• Lack of grid coverage in mid Wales to transmit electricity produced from renewable sources.

However, WEL also believes that Wales does have some particular advantages that are unique to Wales, and that there is therefore no reason for Wales not to be reducing CO₂ emissions from energy generation. For example:

• A physical geography that presents numerous opportunities in terms of energy generation from renewable sources, such as on- and off-shore wind power, wave power, tidal range and tidal stream technologies, solar power (subject to locations being environmentally sustainable);
• Small, distinct rural communities that lend themselves to community-based forms of energy generation, such as CHP, and to off-grid micro-generation technologies;
• Reliance on oil heating and lack of grid coverage, which could both provide an impetus and incentive for decentralisation and micro-renewables;
• Wales has CAT, the Centre for Alternative Technology, a UK centre of Excellence on demonstrating practical solutions to our energy generation problems;
• Wales has some of the worlds leading companies in renewable technology, such as Sharp Manufacturing Company in Wrexham - one of Europe's leading PV module manufacturing facilities, which has implications for making supply chains more efficient in Wales.

4. Do the current energy policies of the Welsh Assembly Government give sufficient emphasis to carbon reduction through low carbon energy generation?

In general, WEL believes that the energy policies of WAG do give sufficient emphasis to carbon reduction through low carbon energy generation, but are concerned that these policies are not being translated into action. The late appearance of the Energy Route Map, and the lack of reports on Environment Strategy climate change actions (see qu.9), are two significant examples of the slow progress that has been made to date.

Renewable Energy Route Map for Wales

WEL has not yet formed its response to the recently published consultation document, but initial reactions are that:

• WEL welcomes WAG’s recognition of the fact that it is "feasible for us within 20 years to produce more electricity from renewables than we consume as a nation”.
• WEL is extremely concerned that the Severn barrage is included in the Route Map as a major input in terms of energy production for Wales.
• We welcome the indication the Minister has given that even without such a project, Wales could be self-sufficient in renewable electricity by 2025 (statement to Plenary, 19/02/08). It is therefore difficult to justify such a potentially damaging development.
• WEL is disappointed that microgeneration is only projected to contribute 2% of energy production in Wales by 2025.
• WEL would be happy to provide the Committee with its response to the Route Map, once it has been finalised. WEL is also in the process of updating its position statement on the barrage, and would be happy to provide the Committee with a copy of this too.

Microgeneration Action Plan   

WEL welcomed the Action Plan and regards it as a strong policy document but, as stated above, is concerned that the projected outputs by 2025 represent such a tiny proportion of the planned renewables contribution. WEL is further concerned about delivery of even the limited planned outputs, and recommends that the Committee request that WAG provides an update on progress with the Action Plan.

WEL also suggests, that in order to maximise the potential of microgeneration for energy generation in Wales, it is necessary to introduce feed-in tariffs as is the case in Germany (see qu.7) and a national grant system as is the case in Scotland and Northern Ireland (see qu.6).

TAN 8

WEL welcomes the One Wales commitment to "review TAN 8, revising upwards the  targets for energy from renewables including their application on-shore and off-shore”, subject to locations being environmentally sustainable, but would also express concern that WAG is not on track for achieving the current targets.

• The TAN 8 target is to produce 4 TWh of renewable electricity by 2010, and 7 TWh of electricity by 2020.
• Current figures show that, to date, only around 1.5TWh is being produced.

Non-renewable energy generation

WEL is unsure as to WAG’s current policy for non-renewable energy generation technologies, but acknowledges that:

• Large scale energy production from fossil fuel and nuclear sources is to be addressed in the forthcoming Energy Strategy for Wales.
• Policies to reduce emissions from large scale, fossil fuel power stations mainly originate from Europe.
• That planning authority over the construction of new power stations above 50MW capacity rests with DBERR in London.

WEL would therefore recommend that:

• The Energy Strategy for Wales will be published as soon as possible, so that all sectors of the economy have a clear idea of WAG’s vision for the future of energy generation in Wales.
• The Assembly seeks to influence the next round of the European Emissions Trading Scheme, to ensure that it maximises carbon reduction from energy generation.
• WAG continues its efforts to gain powers over developments above 50MW capacity and, in the meantime, seeks to influence UK Government policy decisions about the construction of new power stations.
• WAG acknowledges that CCS technologies are unlikely to become viable for quite some time into the future, and should not be used as justification for enhanced coal-mining and coal-burning now.
• WAG formally indicates - in the same way as they have done with nuclear power - that they wish to see no new coal fired power plants, that do not capture CO₂, built in Wales (a move deemed entirely appropriate by James Hansen, the world's leading climate scientist and head of the Nasa Goddard Institute of Space Studies).

National Energy Efficiency and Savings Plan

• WEL seeks assurance that the National Energy Efficiency and Savings Plan is published as soon as possible, and that it will adequately address the need for increased effort to reduce demand for energy and improved efficiency.
• WEL recommends that a target for energy demand reduction be introduced as part of this Plan.  
• Reducing energy consumption effectively means that less energy needs to be generated, and investment and support in this sector should therefore be prioritised as a response to this issue, over the problem of low carbon energy production.  
• As Kevin Anderson of the Tyndall Centre has stipulated, "the current blinkered interpretation of energy as an issue of supply, particularly electricity supply, is likely to lead to inappropriate, wasteful and ultimately ineffective policies…Whatever the arguments for and against alternative low-carbon supply options, we simply do not have the luxury of waiting the decadal timeframe necessary to bring about such a supply transition…If the UK is to demonstrate effective leadership on climate change, it is incumbent on the government to redress the balance of its policy agenda in favour of reducing energy demand”.(1)

Public sector energy generation policies

• WEL is not aware of any WAG policy specifically focussed on energy generation within the public sector.
• WEL therefore suggests that Local Authorities be required to develop, publish and act upon their own energy strategies, such as that recently published by the City and County of Swansea - A Sustainable Energy Action Plan for Swansea 2008.
• Such strategies should contain a coherent programme of performance measures, targets, financing, and accountability through audit. Audit and annual performance measures should specifically include reference to emission reduction plans in local authority operations and the local authority community or area.

5. To what extent has the Welsh Assembly Government been successful in utilising the powers available to it in order to reduce carbon dioxide emissions from energy generation?

WEL notes that the most recent figures for Welsh carbon emissions from energy generation show a fall of 6% over the period 1990 to 2005. While encouraging, this improvement is well short of the scale of reduction needed and conceals both upward as well as downward movement over the 15-year period.

WEL recognises the limits to the powers that WAG has in order to develop and introduce policies which have the intention of reducing carbon dioxide emissions from energy generation.

Despite this, WEL believes that WAG has been successful in developing policy which has the intention of reducing carbon dioxide emissions from energy generation but, as stated above, does not believe that WAG has been successful in taking the next step to actually deliver on these policies.

One example of successful delivery however has been WAG’s use of Objective 1 money to run the Wood Energy Business Scheme. The Scheme promotes the use of a low carbon energy source - woodfuel from sustainable Welsh sources - and can have biodiversity benefits by making it viable to bring native woodland back into management.

6. Could alternative targeting of Welsh Assembly Government financial resources lead to greater emission reduction from energy generation than is currently being achieved? If so, where could additional resources lead to greatest impact? (Please provide detail to support your evidence).

WEL believes that greater emission reduction from energy generation could be achieved if financial resources were invested in:

A dedicated Welsh grant scheme for microgeneration

• Research by the Energy Savings Trust(2) found that by 2050 microgeneration could provide 30-40% of the UK's total electricity needs and reduce CO₂ emissions by 15% per year.  
• A requirement for planning permission is only one barrier relating to the take-up of microgeneration technologies, and financial obstacles must also be minimised if the Assembly Government’s ambitious Micro-generation Action Plan targets are to be met.
• WEL believes that Wales suffers from the lack of a dedicated Welsh grant scheme for microgeneration - as have been introduced in Scotland and Northern Ireland (see qu.7). Demand for the Low Carbon Buildings Programme grants outstrips availability massively.
• WEL therefore recommends that the Welsh Assembly Government investigates how well Wales accesses this programme, and considers whether a Welsh promoted and run scheme would be better.
• WEL also suggests that WAG’s Home Energy Efficiency Scheme should be expanded to include microgeneration.
• Micro and community-scale generation has the potential of having a significant positive impact on the Welsh economy. Local Authorities, Health Boards, SME’s and community organisations could all install micro or small-scale CHP, wind, solar or hydro electric capacity which would not only help meet their own immediate needs but could provide a trading income from surplus energy sold  into the grid or to local users.
• Investment at this scale, especially if allied to a small-grants scheme and a feed-in-tariff, together with the ROC’s already available, would be attractive for commercial lenders and local investors and would subsequently create wealth which would re-circulate within the Welsh economy. This local multiplier effect would also increase the demand for installation and service engineering skills within Wales offsetting employment losses from other sectors, as well as helping to maintain the viability of a range of essential businesses vulnerable to increases in energy costs or supply shortages.
• Where community organisations and Social Enterprises can be involved, there is tremendous scope for the profits from energy generation to be reinvested through local assistance schemes to provide energy surveys, insulation and energy-efficiency improvements to local homes and community buildings, thus multiplying Carbon reductions at a compound rate, combating energy poverty, and reducing the cost-burden to the local economy.
• Take up could also be promoted through offering low interest loans to farms, SMEs and community organisations wanting to install microgeneration technology.
• The provision of a secure long-term framework for investment in the sector, would replace the current reliance on stop-start grants and would attract investors to microgeneration by ensuring they have confidence in the market for the long-term and see incentives to invest.
• The Sustainable Development Commission’s reports on tidal energy and nuclear power, highlight the risk of large scale energy projects - like a Severn Barrage - diverting attention from efforts to reduce energy demand and develop other renewables such as microgeneration.

WAG Grant requirements

• Energy audits and carbon planning could be made a condition of other WAG grants, with recipients required to reduce their energy use and greenhouse gas emissions.

Public sector leadership

• Providing the financial support for the introduction of renewable energy technologies - such as CHP and microgeneration - on public sector buildings, so as to demonstrate leadership and increase market demand.

Research and development into Combined Heat and Power (CHP)

• CHP is a technology which captures this waste heat rather than allowing it to be lost.
• The available waste steam is extracted at a higher pressure than in conventional power stations, maintaining a higher temperature, enabling the waste heat to be used either for industrial processes or supplied to CH (community heating, often called district heating) networks which in turn supply buildings.
• There is a small drop in electricity production as a result, but the overall efficiency of CHP plants can reach in excess of 90% compared to the 50% of centralised electricity-only thermal power plants.
• The technology is well proven, but in the UK the main application has been on industrial sites. Elsewhere, especially in Scandinavia, it is normal practice to build power stations using CHP technology and in locations where the heat generated can be used to supply large scale CH networks. The cities of Copenhagen and Helsinki are heated in this way.
• Any major thermal power station, whether coal, oil, gas or biomass-fired, can in theory operate as a CHP plant, as only a small modification to the steam turbine system is required.
• However, since the UK’s major power stations have historically been built remote from population centres, it has not been practicable to use their waste heat for buildings. Now, though, it is possible to generate electricity from thermal combustion at a range of scales, making it more suited to sites located much nearer to centres of demand, or even to location within buildings as part of their heating system.  
• Greater consideration therefore of ways to make our use of fossil fuels in Wales more efficient are necessary.

Suitable infrastructure for renewable technologies

Concerns have been raised by businesses requiring necessary infrastructure to implement their technology, such as jack-up barges in the case of the marine environment. There is a shortage of this kind of service in the UK and consequently a long waiting list to use the available capacity. This may have been caused by insufficient investment or support at earlier stages from Government.  

7. What examples from other administrations (devolved, UK, and overseas), where other means have been used to achieve reductions in carbon dioxide emissions from energy production, could be adopted in Wales under current powers?

Scotland and Ireland - Microgeneration grants

The Scottish Community and Householder Renewables Initiative(3) dedicates £3.7million per annum to its objectives:

• To support the development of community scale renewable projects
• To support the installation of household renewables
• To raise awareness of renewable technologies and their benefits to Scotland

In Northern Ireland, the Environment and Renewable Energy Funding Package(4) includes a Household Programme which will receive £8million for the period 2006-08. This programme aims to enable at least 4,000 private households to install solar, PV, biomass, wind or geothermal energy systems and enhanced energy efficiency measures.

Germany - Feed-in tariffs

• DBERR handed out grants in 2007 to fit solar PV systems to just 270 houses in the whole of the UK - the corresponding figure for Germany in 2007 was 130,000.
• This is because the financial climate in Germany is considerably more attractive, as it is intended to reflect the strong benefits of PV over other more polluting alternatives.
• REFIT (Renewable Energy Feed-In Tariff Scheme) enables much higher prices to be paid for PV electricity sold to the grid - around 50 E cents per kWh, roughly equivalent to US$0.60 or £0.35.(5)
• In addition, very low interest loans are offered to home owners where if certain retrofit targets are reached homeowners pay only 90% of the loan back.

Combined Heat and Power (CHP) in Denmark

• In the 1980s in Denmark, the rapid growth in national primary energy consumption halted and consumption has remained almost stable at about 800Pj per year ever since.
• Between 1975 and 1985 domestic energy consumption for space heating was reduced by 50%. Since 1985 it has been held constant by continuing the expansion of the district heating networks and by using the countries new found gas supplies.
• By 2000 well over a half of Danish homes used district heating. District heating also made up 12% of the delivered energy supply, and the extensive use of CHP kept the national figure for losses down to 22% compared to the UK figure of 31%.(6)

London Green Homes service

The flagship London Green Homes service is unique to the capital, and offers:

• An information website, www.londonclimatechange.co.uk, where Londoners may access information and advice on how to reduce their carbon footprint.
• A free telephone helpline - 0800 512012 - to access one-to-one, personalised advice from experienced staff on how to make your home 'green’.
• A paid-for concierge service that is designed for homeowners who want to make more significant changes to their homes without the hassle, by providing a customised audit of a property. This includes a thermal image, and a 'blow door’ test to identify sources of draughts; a report of recommended ways to reduce emissions; and, if wanted, full project management of a programme to cut emissions, including sourcing of competitive quotes. The subsidised service costs £199 for annual membership.(7)

Demand matching, USA

• In addition to demand reduction, there is significant potential for existing generating capacity to be rationalised through better demand matching and the development of distributed storage strategies. These can be in the form of 'smart’ appliances such as refrigerators which sense grid demand through the mains and delay their operation accordingly, or as is being proposed in the US, a collaboration between electricity generators, supply companies and householders to use battery electric vehicles (BEV’s) or plug-in hybrid vehicles (PHEV’s) to act as a massive storage network for surplus power during the off-peak periods, to be drawn upon at time of peak load.
• Such vehicle-to-grid systems as they are known could be particularly effective for Wales, with a large number of small settlements and the potential for a broad mix of renewable sources all generating discontinuously at different times. The harmonisation of a number of WAG strategies relating to planning and buildings development, transport and the microgeneration strategy could create a supportive environment for such initiatives to be tested here.

8. In the context of the Government of Wales Act 2006, which further means of reducing carbon dioxide emissions from energy production could only be achieved with the introduction of further legislative competence for the National Assembly for Wales?

WEL believes that WAG needs to gain planning authority for energy projects with capacity greater than 50MW, in order to achieve full Welsh responsibility over forms of power generation and over carbon emission levels from such generation. WEL therefore advocates that WAG should continue to press for the transfer of planning responsibility for all power generation projects located in Wales, irrespective of capacity.

This would be consistent with other elements of the existing competences for determining other major development in Wales are concerned, so far as the Assembly’s devolved planning competence and powers.   

There has also been pressure for WAG to gain powers over building regulations, on the ground that it could then stipulate that new build includes renewable energy technologies, such as microgeneration or CHP.

9. If specific carbon dioxide emissions targets are to be set for Wales, should those targets be subdivided into shares by sector? If so, what share of the total should reductions as a result of energy generation comprise?

Sectoral targets should set the requirement for change in all sectors, to ensure that stakeholders are in no doubt as to what is required. It should be clear that the targets will need partnership working to deliver them, but the same is true for any business or government. It is not something that can be achieved alone.

The key objective of an 80% decrease in emissions by 2050, in order to play an active part in reducing the threat from the worst impacts of climate change, should continue to frame the context within which these targets are set.

WEL does not have the necessary data to determine what share of the total reductions as a result of energy generation should comprise. However, we would like to draw the Committee’s attention to the fact that:

• WAG should be able to provide a reliable figure in response to this questions since, in the Environment Strategy Action Plan for Wales, they did commit to "carry out research to establish the level of greenhouse gas emissions in Wales, by sector, which the Assembly Government has powers to address” (Action 1).
• this research was due to start in May 2006, but WEL is not aware whether it has been completed. WEL would therefore suggest that the Committee ask WAG for an update on this research, and the resultant sectoral targets.

Wales Environment Link values the opportunity to take part in this important consultation process and trusts the above response will be taken into consideration by the Sustainability Committee.

The member organisations of Wales Environment Link that sign up to this consultation response are:

Butterfly Conservation Wales
Campaign for the Protection of Rural Wales
Cylch (Wales Community Recycling Network)
Groundwork Wales
Keep Wales Tidy
National Trust Wales
RSPB Cymru
Snowdonia Society
WWF Cymru

For further information please contact:
Michele Aitchison
Advocacy Officer for Wales Environment Link
Baltic House
Mount Stuart Square
Cardiff
CF10 5FH
Telephone: 02920 431 716

E-mail: maitchison-wel@wcva.org.uk