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Neal D Rafferty Renewables Routemap Team 4th Floor 5 Atlantic Quay 150 Broomielaw GLASGOW G2 8LU Telephone: 0300-244-1227 Neal.Rafferty@scotland.gsi.gov.uk Dear Mr Rafferty, RE: consultation on the review of ROC bands applying under the Renewables Obligation (Scotland) mechanism. Please find the Greener Leith response to selected questions from this consultation below. ● What are your views on the proposal to remove support for large scale dedicated biomass electricity plants? We are of the view that the current Scottish Government policy on biomass is the right one as it will maximise the carbon savings that can be delivered from this resource. It therefore seems logical to align the subsidy regime in such a way so that it supports the current policy of favouring deployment of biomass in heat-only or combined heat and power plants, particularly off gas-grid, and to a scale which maximises heat use and local supply. Taking the Leith plant currently proposed by Forth Energy as an example, it is not scaled to supply a specific, identified heat demand. Nor is it scaled to maximise the benefits of local supply or located off gas grid. Yet it could still claim and estimated £116,880,000pa of ROC subsidy over twenty years under the current arrangements, even if none of the heat from the plant is ever used. By comparison, it is worth noting that a ten year programme for reducing the energy demand of every home in Scotland was costed at £170,000,000 per year by the Association for the Conservation of Energy1.

1 Submission from the Association for the Conservation of Energy to Scottish Parliament Finance Committee consultation on draft

budget proposals for 2012-2013. Available at: http://bit.ly/skvhyn

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

The developers of the Leith plant claim that they intend to sell the heat to various customers around North Edinburgh, but they give no binding undertaking to provide the necessary infrastructure to make this claim a reality. Should this plant, or others like it, receive consent from the Scottish Government, there is therefore no guarantee that it will ever deliver the good quality CHP heat and power that the developers claim is theoretically possible - even though the developers can be confident in receiving generous subsidies from day one. Recent news from the Department of Energy and Climate Change that the proposed Renewable Heat Incentive for large biomass plants is to be significantly reduced from 2.7p to 1p per kWH, only serves to throw further doubt on the viability of the Forth Energy heat network proposals2. Given the likely economic and environmental impacts of large electricity-only biomass power that have been identified3 in the context of the proposed Leith plant4, we believe it is right to withdraw ROC subsidy from all biomass plants, unless developers can guarantee, as a minimum, that they will generate Good Quality CHP heat and power5 from the first day of operation. We note however that the current CHPQA scheme, which defines Good Quality CHP, operates an exemption for biomass CHP power plants that allows them to qualify for subsidy under the current ROS banding scheme6 even if they operate at very low efficiencies. Whilst we understand that the CHPQA standards for biomass power plants are currently under review, and that this is ultimately likely to result in the adoption of higher efficiency standards at a UK level, we believe that there is no reason why the Scottish Government should not insist on a minimum overall efficiency of 70% for all biomass plants of any scale in order to qualify for ROS subsidy.

2Department of Energy and Climate Change. Renewable Heat Incentive. October 26th 2011. Available at: http://www.decc.gov.uk/

en/content/cms/meeting_energy/renewable_ener/incentive/incentive.aspx
3Government agencies line up to criticise Leith biomass plans. May 2011. Available at: http://www.greenerleith.org/greener-leith-

news/2011/5/17/government-agencies-line-up-to-criticise-leith-biomass-plans.html
4Objection to proposed Leith Biomass Plant. Greener Leith. 3rd March 2011. Available at: http://www.scribd.com/doc/49971570/

Forth-Energy-Leith-Biomass-Objection
5 Guidance Note 10. Defining Good Quality CHP - criteria for good quality CHP. (pdf) Available at: https://www.chpqa.com/

guidance_notes/GUIDANCE_NOTE_10.pdf
6 Guidance Note 44. Use of CHPQA to obtain Renewable Obligation Certificates (ROCs) Including Under a Banded Obligation.

Available at: http://chpqa.decc.gov.uk/guidance-notes/

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

This move would favour the development of smaller, and more efficient energy projects. This would also enable The Scottish Government to ensure that the subsidies that are available for biomass are aligned to European Union directive 2009/28/EC on renewable energy, which states in article 137: “In the case of biomass, Member States shall promote conversion technologies that achieve a conversion efficiency of at least 85% for residential and commercial applications and at least 70% for industrial applications.” We note that a withdrawal of ROC subsidy from electricity-only biomass plants would also align well with the conclusions of the recent Renewable Energy Review conducted by the UK Committee on Climate Change8, whose preliminary conclusion on biomass stated: “biomass would probably be of more value when used outside the power sector.” ● Should a threshold be set to incentivise smaller scale electricity plants, and at what level? In our opinion, it is hard to make a case from a carbon reduction point of view for subsidising electricity-only biomass plant at any scale. ● Should UK proposals on enhanced co-firing and conversion be mirrored in Scotland, and why? No, subsidies should not be made available for enhanced co-firing and conversion as the fact remains that biomass fuel should not be used in any power-only, large-scale plant. All existing coal-fired plant in Scotland can and should be replaced with lower carbon alternatives9. If subsidies are to be made available in this context, the government must be careful to specify fuel types and sources that will deliver genuine carbon reductions, as there is credible evidence that the carbon savings that are claimed for woody biomass used in this way may take up to 270 years to materialise10.

7 Directive 2009/28/EC Of The European Parliament And Of The Council: 2009. Official journal of the European Union. Available at:

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:140:0016:0062:en:PDF
8 Commitee on Climate Change. Renewable Energy Review, May 2011. Available at: http://www.scribd.com/doc/63936265/CCC-

The-Renewable-Energy-Review
9 The Power of Scotland Secured. Garrad Hassan. September 2010. Available at: http://www.foe-scotland.org.uk/sites/files/

Garrad%20Hassan%20PoSS.pdf
10 Woody biomass for energy: NGO concerns and recommendations. April 2011. Available at: http://www.greenerleith.org/greener-

leith-news/2011/8/3/leith-biomass-more-carbon-emissions-than-coal-for-270-years.html Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

In our view, a carbon saving that takes centuries to deliver is not worthy of subsidy, as it will not come soon enough to support the carbon reduction outcomes required by climate science or Scottish legislation. ● What are your views on whether a maximum threshold for biomass CHP plants is required? Aside from the efficiency of the fuel use and the consequent carbon emissions, there are other sustainability questions that are inherent in the development of large biomass CHP plants. It is our understanding of the latest research11 that smaller heat only, or CHP biomass plants, are far more likely to draw on local, rather than imported, fuel sources. We also note the key conclusion of recent Scottish Government funded research into whether a threshold should be applied. It stated: “Our recommendation would be for a 10MW threshold, given that a low to moderate deployment of plants up to 10MW level would use between approx 30% (equivalent to five 10MW plants) and 60% (equivalent to ten 10MW plants) of net available resource. We see this as a pragmatic balance between different risks and sector pressures to enable the Scottish Government to best meet a number of different policy objectives.” Greener Leith would support this recommendation. Such a threshold would help to tackle many of the other sustainability problems that are associated with larger plants as large plants start to have problems associated with scale and fuel supply. Large plants must almost inevitably be located by the coast, in order to allow ships to deliver the large quantities of imported fuel they will require. Yet, if they are to make effective use of the correspondingly large amounts of heat they generate they must also be built close to urban centres. By their very nature, these urban centres are usually already connected to the gas grid - yet the Scottish Government policy on biomass favours plants that are located off the gas grid where the potential for carbon savings are greatest. Furthermore, like many others around the world12, we remain to be convinced that managers of large biomass plants will be able to reliably or credibly obtain sufficient quantities of sustainably sourced fuel13 from outwith Scotland. Also, the sheer scale of fuel imports required to supply larger biomass plants may cause unacceptable displacement effects on global land and materials use14, or unintended economic impacts on other local users of wood.

11 Supporting Biomass Electricity in the Renewables Obligation Scotland. Available at: http://www.forestry.gov.uk/pdf/

BioenergyReportDec2011.pdf/$FILE/BioenergyReportDec2011.pdf 12 Leith Biomass plant draws international condemnation. March 2011. Available at: http://www.greenerleith.org/greener-leith-news/ 2011/3/30/leith-biomass-plans-draw-international-condemnation.html
13 Regional Carbon Dioxide Implications of Forest Bioenergy Production. October 2011. Nature Climate Change. Available at: http:/

/www.nature.com/nclimate/journal/vaop/ncurrent/full/nclimate1264.html
14 Price Volatility in Food and Agricultural Markets. World Trade Organisation. June 2011 Available at: http://www.wto.org/english/

news_e/news11_e/igo_10jun11_report_e.pdf Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Lastly, as large plants in urban areas are likely to be perceived as ‘bad neighbour’ developments they inevitably bring with them significant planning conflict relating to, for example, increases in traffic, negative economic impacts on the surrounding area, visual amenity, nuisance and air quality concerns. We believe the simplest means of minimising lengthy, expensive planning disputes, the risks of unsustainable international impacts of large scale biomass imports, AND of incentivising the construction of biomass plant off the gas grid is to put an upper limit on all large scale biomass plants beyond which no subsidy will be paid. Were the Scottish Government to align the ROC subsidy scheme with the banding of the RHI for biomass then this could create a powerful economic incentive to develop small scale CHP biomass plants, based on a more sustainable local supply, which could then be connected up as local heat networks develop. This would help to foster a more sustainable, diversified, decentralised, and therefore more robust heat and power system. Placing an upper limit on the size of biomass plants which qualify for subsidy would not prevent the development of urban heat networks, but it would serve to promote an incremental, and more diversified, approach to the development of efficient local heat networks, such as those already implemented by award winning Aberdeen Heat and Power.15 This non-profit firm already supplies low carbon heat to 1000 homes in Aberdeen from a series of small gas powered CHP generators. In our view, this incremental approach to developing heat networks is a more practical and socially just model that the Scottish public sector should aim to support and replicate throughout the country. ● Do you believe there is a need to revisit the biomass content threshold of 90%? No. Reducing the content threshold blurs the boundary between biomass fuelled plants and Energy from Waste plants. Given the unenviable record on air quality of some existing Waste to Energy plants in Scotland16, we would prefer to see subsidies for biomass energy used to support genuine biomass fuels. The 90% content threshold helps to support this distinction.

15 Combined Heat and Power System reaches milestone. City of Aberdeen Council. October 2010. Available at: http://

www.aberdeencity.gov.uk/CouncilNews/ci_cns/pr_domesticsuccess_090910.asp
16 Dundee Energy Recycling Ltd. Emissions breaches figures from SEPA. See: http://www.gainscotland.org.uk/dundee-derl.shtml

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Enhanced support for community owned renewable energy projects We are convinced of the potential for non-profit and cooperative approaches to developing renewable energy resources across all technologies17, and are aware of calls for a Community FiT tariff to promote the development of non-profit energy projects, such as Aberdeen Heat and Power. We would support these calls and ask that the Scottish Government consider the scope for an enhanced ROC subsidy for projects that are developed by non-profit, community led organisations. Community Energy Scotland have already put forward proposals for a Community FiT to DECC and many of the arguments they make in support of a Community FiT could also apply equally to the introduction of a community enhancement for ROC bandings.18

17 A Co-operative Green Economy. Co-operatives UK. See: http://www.uk.coop/system/files/docs/GreenEconomy_v1_0.pdf 18 Community Energy Scotland proposals for a Community FiT. Community Energy Scotland. See: http://

www.communityenergyscotland.org.uk/userfiles/ file%5CCommunity%20Energy%20Scotland%20Proposal%20for%20a%20Community%20FiT%20November%202011.pdf

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

About this response The Greener Leith committee consent to this consultation response being made available to Scottish Government officials and placed in the public domain. Greener Leith committee members are willing to be contacted by Scottish Government Officials to discuss this response further. Prior to submission to the Scottish Government, members of the public were invited to comment on the draft of this document online via our website and Twitter. After comments were received, the final version was agreed by our management committee. About Greener Leith Established in 2006, Greener Leith is a registered charity that is managed entirely by local residents who have professional backgrounds spanning planning, green energy, landscape architecture, finance and community engagement. Greener Leith, with the support of a CARES Loan from the Scottish Government, is currently exploring the feasibility of building Scotland’s first community owned urban wind turbine on the Edinburgh waterfront at Seafield. With the help of hundreds of local supporters, Greener Leith promotes community involvement, sustainable development and better public spaces. For more information on what we do, see www.greenerleith.org

Yours Sincerely,

Alastair Tibbitt, Trustee, Greener Leith.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095