Energy Policy Paper
Low-Carbon Power Generation and Energy Efficiency
2. Policy Context
3. Current Situation/Trends/Shortcomings
4. Labour Party Policy
5. Suggestions for Action and Examples from Elsewhere
With the publication of the Green Transformation document, Labour Party policy in respect of renewables, energy efficiency and reduction of fuel poverty has become more ambitious and this needs to be reflected in Welsh/regional/local Labour Party policy and documents. A Labour Government in Westminster is required to implement some of the proposals, and in the meantime financial constraints limit scope for action. Nevertheless, I think that more could be done at relatively low cost, especially in the following areas: creation of a renewable energy target for Anglesey, promotion of energy cooperatives, promotion of energy efficiency and improvements in planning guidance.
1.1. National Grid “Future Energy Scenarios” (July 2018)
Identified two options that meet the 2050 decarbonisation (at least an 80% reduction compared with 1990) target: (1) “Community Renewables”: more decentralised energy landscape; onshore wind and solar, co-located with storage, dominate the electricity supply picture; electric vehicles plus hydrogen used for LGVs; heat pumps plus smart technology to reduce electricity demand; use of green gas, i.e. biomethane, bio-SNG (synthetic natural gas), e.g. gas from black bin waste); (2) “Two Degrees”: use of larger and more centralised technologies to meet target: greater generation from offshore wind and nuclear, based more on the transmission network.
Under Community Renewables scenario by 2030, renewable generation, particularly wind and to a lesser extent solar, makes up more than 75 per cent of generation output.
Growth of onshore wind in all scenarios. Assumption that there will be more consumer acceptance of onshore wind plus a facilitative policy environment for local wind schemes. As a result, there is a dramatic growth in decentralised onshore wind in the Community Renewables scenario. Approximate installed wind capacity under this scenario: 48 GW (decentralised/transmission-connected onshore/ transmission-connected offshore = 12/11/25 GW respectively). Currently: ca. 12.8 GW for onshore wind and 7GW for offshore wind (2017 figures).
More than 7 GW of new nuclear is expected in all scenarios. Tidal streams, tidal lagoons and energy from wave technologies play a very minor role under all scenarios.
Growth in solar capacity is most pronounced in Community Renewables. By 2030, 33GW of solar is installed. Currently: 12.8 GW (end of 2017).
1.2. Committee on Climate Change – “Reducing UK emissions”. 2018 Progress Report to Parliament
“Act now, climate change will not pause while we consider our options. And act in the consumer interest: pursue the low-cost, low-risk options, like onshore wind, and enforce the standards that will reduce emissions from vehicles and buildings”. “Onshore wind and solar are likely to be 25% cheaper than new gas plants by the 2020s.”
“Efficiency in buildings is an obvious practical step. But insulation rates in homes are 95% lower than they were in 2012.” “Heat pumps could be crucial to decarbonising heat in UK buildings.”
1.3. National Infrastructure Commission – National Infrastructure Assessment, July 2018
Sustaining progress on reducing emissions requires government to show ambition. The crucial first step is to enable an increasing deployment of renewables.
Government should not agree support for more than one nuclear power station beyond Hinkley Point C before 2025.
Since a system with a high proportion of renewable generation looks cost effective in the long term, and adding more nuclear to the system in this timeframe is unlikely, it makes sense to continue to add more renewables to the system in the 2020s.
The Commission’s analysis suggests that tidal lagoon power will remain an expensive technology in the future. The extra benefits which arise from its predictability are not enough to offset its higher capital costs. And it will never be a large-scale solution: an entire fleet of tidal lagoons would only meet up to 10 per cent of current electricity demand in the UK. This also limits the scope for cost reductions through the kinds of learning and scale economies that have been achieved with wind and solar power. Further details are set out in technical annex: Tidal power: Given the broad portfolio of readily available lower cost, low carbon technologies, special treatment for tidal lagoons in the form of bilaterally agreed contracts is not justified. However, tidal should be allowed to compete on an equal basis with other technologies for Contracts for Difference.
2. Policy Context
2.1. Planning Policy Wales, edition 10 (draft; final version expected during December) – some key paragraphs, with my highlighting)
4.99. The Welsh Government is committed to delivering the outcomes set out in our Energy Policy Statement Energy Wales: A Low Carbon Transition (2012). Our priorities are: • Reducing the amount of energy we use in Wales; • Reducing our reliance on energy generated from fossil fuels; and • Actively managing the transition to a low carbon economy.
4.101 Planning applications for onshore generating projects in Wales which have an installed generation capacity of between 10MW and 50MW (there is no upper limit for onshore wind generating stations) are made directly to the Welsh Ministers under the Developments of National Significance (DNS) process. Provisions in the Wales Act 2017 devolve all energy generating projects up to 350MW, however, these provisions are yet to be commenced.
4.103 The planning system should: • Integrate development with the provision of additional electricity grid network infrastructure; • optimise energy storage; • facilitate the integration of sustainable building design principles in new development; • optimise the location of new developments to allow for efficient use of resources; • maximise renewable and low carbon energy generation; maximise the use of local energy sources, such as district heating networks; • minimise the carbon impact of other energy generation…
4.104 The Welsh Government has set targets for the generation of renewable energy:
• For Wales to generate 70 per cent of its electricity consumption from renewable energy by 2030;
• For one Gigawatt of renewable electricity capacity in Wales to be locally owned by 2030; and
• For new renewable energy projects to have at least an element of local ownership by 2020.
4.106 To assist in the achievement of these targets, local authorities must take an active, leadership approach at the local level by identifying targets for renewable energy in their development plans. In order to identify a measurable target which can be assessed and monitored through the planning system, these targets should be expressed as an absolute energy installed capacity figure calculated from the resource potential of the area and should not relate to a local need for energy.
4.108 Local authorities should consider the renewable energy resource they have available in their areas when formulating their renewable energy target and use the full range of policy options available (including developing spatial allocations in their 84 development plans – see below) in order to help them achieve these. Targets should not be seen as maximum limits but rather be seen as a catalyst to maximise available resource and where proposals exceed the target they should not be refused for this reason alone.
4.113 … Planning authorities should recognise the importance of energy storage and support appropriate development….
4.114 The Welsh Government expects all new development to mitigate the causes of climate change, in accordance with the energy hierarchy* for planning (as shown below). Reducing energy demand and increasing energy efficiency will assist in meeting this demand with renewable and low carbon sources of energy.
Note: Energy hierarchy = (in order of priority) reduce energy demand, use energy efficiently, renewable energy generation, minimise carbon impact of other energy generation, minimise extraction of carbon-intensive energy minerals.
4.116 The Welsh Government’s policy is to secure zero carbon buildings while continuing to promote a range of low and zero carbon technologies as a means to achieve this.
4.117 Sustainable building design principles should be integral to the design of new development.
2.2. Anglesey and Gwynedd Joint Local Development Plan (JLDP) 2011 – 2026
a) Strategic Policy PS 7: Renewable Energy Technology
The Councils will seek to ensure that the Plan area wherever feasible and viable realises its potential as a leading area for initiatives based on renewable or low carbon energy technologies by promoting: 1. Renewable energy technologies within development proposals which support energy generation from a variety of sources which include biomass, marine, waste, water, ground, solar and wind, including micro generation; 2. Free-standing renewable energy technology development
b) Policy ADN 1: On-Shore Wind Energy
No Large-Scale or Very Large-Scale wind farms / wind turbines will be permitted in the Plan area. Other on shore wind turbine proposals will be permitted subject to an assessment of their environmental and sustainability impacts:
Medium-Scale wind farms / wind turbines will only be granted on urban / industrial brownfield sites or when the proposal involves the repowering of existing wind farms / wind turbines.
Micro-Scale and Small-Scale wind turbine proposals will be granted outside the AONB and the Special Landscape Area provided they don’t have a significant detrimental effect on the setting of the AONB, National Park and World Heritage Site.
Note: What is small scale? Table 9 describes the used wind turbine typology and states that small-scale developments have an indicative output <5 MW and comprise turbines up to 3 in number, turbines up to 50 m to blade tip (i.e. perhaps 225 kW), and turbines viewed as a small group.
Table 10 lists “residential visual amenity assessment trigger distances”, e.g. 400 m for turbines of up to 50 m to bladed tip, 600 m for those up to 75 m to blade tip.
c) Policy ADN 2: PV Solar Energy
Proposals for Solar PV Farms of 5MW or more should be directed to the potential search areas shown on the Proposals Map. Proposals of this scale will only be permitted in other locations in exceptional circumstances when the need for a scheme can be justified and there are specific locational circumstances. (Note: six criteria listed. Table 11 lists “potential opportunity areas” ranging from 12 to 127 hectares).
d) Strategic Policy PS 8: Proposals for National Significant Infrastructure Projects and Related Developments (i.e. Wylfa, pylon connection)
“In their role as determining authorities for related development for a National Significant Project the Councils will require compliance, where appropriate, with the criteria set out in this Policy. In responding to proposals forming part of a Development Consent Order application to the Secretary of State the Councils will take the same considerations into account in the preparation of a Local Impact Report.”
e) Policy SO7: re energy efficiency: “Ensure that all new development meets high standards in terms of quality of design, energy efficiency,…”.
f) Strategic Policy PS 6: Alleviating and Adapting to the Effects of Climate Change
In order to alleviate the effects of climate change, proposals will only be permitted where it is demonstrated that they have fully taken account of and responded to the following: 1. The energy hierarchy: i. Reducing energy demand; ii. Energy efficiency; iii. Using low or zero carbon energy technologies wherever practical, viable and consistent with the need to engage and involve communities.
g) Page 87, re nuclear:
14. Any proposal on the Wylfa Newydd site (outside a DCO) to treat, store or dispose of Very Low level, Low Level or Intermediate Level Radioactive Waste or to treat or to store spent fuel arising from the existing nuclear power station or any future nuclear development within or outside the Plan area, in an existing or proposed facility on or off the nuclear site would need to i. demonstrate that the environmental, social and economic benefits outweigh any negative impacts.
2.3. New Nuclear Build at Wylfa: Supplementary Planning Guidance, July 2014
The “Vision”: “The New Nuclear Station at Wylfa is a positive driver for the transformation of the economy and communities on Anglesey, providing sustainable employment opportunities, improving the quality of life for the existing and future generations and enhancing local identity and distinctiveness.”
Section 3.2, “Objectives”, includes ensuring that the project places Anglesey at the forefront of energy research and development, maximises opportunities for employment and upskilling of local people, delivers infrastructure benefits, and improves quality of life and the environment, taking into account climate change.
Horizon and other third parties promoting projects relating to Wylfa will require consent, through the Town and Country Planning Act 1990, for works connected with the development.
Notes that National Planning Policy Statements for Energy (EN-1) and Nuclear Power Generation (EN-6) will set out the criteria to be considered by the Secretary of State when determining the application.
2.4. Supplementary Planning Guidance for Onshore Wind Energy, January 2013
Key aspect: Minimum separation distance from residential or tourism properties for medium and large turbines: “500m or 20 times tip height (in metres) (whichever is the greatest)”. What does this mean in practice? Under this SPG a turbine 60 m to tip height, with a power rating of perhaps 500 kW, would require a separation distance of 20 x 60 m = 1.2 km. But…
Important: I believe that this guidance has now been supplanted by the JLDP in that Sections 6.2.30 and 6.2.31 of the JLDP state that guidance on the application of separation distances from residential properties was commissioned by the Isle of Anglesey, Gwynedd and Snowdonia National Park and the ensuing report concluded that minimum separation distances were not appropriate but that indicative residential visual amenity assessment trigger distances were appropriate. As stated above, Table 10 of the JLDP cites less constraining indicative residential visual amenity assessment trigger distances.
2.5. Well-being of Future Generations (Wales) Act 2015
Establishes statutory Public Services Boards (PSBs) to assess the state of economic, social, environmental and cultural well-being in its area and set objectives designed to maximise the PSB’s contribution to the well-being goals.
Each PSB must prepare and publish a Local Well-being Plan setting out its objectives and the steps it will take to meet them. Each PSB will carry out an annual review of their plan showing progress. Gwynedd and Anglesey Well-Being Plan, May 2018: full of generalities and not relevant to energy issues.
Quotes from the Act:
“In this Act, “sustainable development” means the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle (see section 5), aimed at achieving the wellbeing goals.”
“In this Act, any reference to a public body doing something “in accordance with the sustainable development principle” means that the body must act in a manner which seeks to ensure that the needs of the present are met without compromising the ability of future generations to meet their own needs.”
2.6. Wales Act 2017
Section 43 permits the inclusion of development commonly referred to as “associated development” within the application for Development Consent Order (DCO). Developers may choose whether to include these types of developments within a DCO application or make separate planning applications to the Local Planning Authorities.
2.7. Energy Island Programme
In 2014 was estimated that the programme could contribute £2.5 billion to Anglesey and N. Wales economies over the next 15 years. Comprises schemes listed in Sect. 3.
2.8. Planning Act 2008
Covers applications for orders granting development consent. Relevant to pylons and Wylfa Newydd. Applications for an Order Granting Development Consent are made under section 37(2).
2.9. National Assembly for Wales. Climate Change, Environment and Rural Affairs Committee – “Low Carbon Housing: the Challenge”, August 2018.
Summary of some key recommendations (there are 13):
Recommendation 1. The Welsh Government must prepare and publish a ten year low carbon housing strategy. The strategy must include milestones and targets and must deliver, within its lifetime: ♣ The retrofit of all houses in fuel poverty in Wales to zero carbon in operation standards; ♣ All new build houses in Wales to be built to zero carbon in operation standards; ♣ A complimentary planning and building system with low carbon and energy efficiency at their centres, and supported by rigorous, independent inspection regimes; etc.
Recommendation 2. The Welsh Government should revise Part L of the building regulations to increase the required energy efficiency of new homes.
Recommendation 3. The Welsh Government should ensure that the inspection regime is robust and resourced appropriately to underpin confidence in low carbon housing.
Recommendation 5. The Welsh Government should continue to invest in and expand the current retrofitting schemes under Arbed 3.
3. Current Situation/Trends/Shortcomings
3.1. Anglesey and Gwynedd Joint Local Development Plan 2011 – 2026, Table 7: Renewable Electricity Potential for 2026
Onshore wind: Existing Installed Capacity (MWe = megawatts electric): 45.7; Additional Potential for Energy Generated (GWh): 104.6; Total Additional Potential for Renewable Energy Delivered by 2026 (GWh): 0.5 (My note: that is to say, the total additional potential by 2026 is only 0.5 GWh owing to the policies in the JLDP and previous SPG, whereas the theoretical potential is 104.6)
Solar: Existing Installed Capacity (MWe): 45.7; Additional Potential for Energy Generated (GWh): 289.2; Total Additional Potential for Renewable Energy Delivered by 2026 (GWh): 20.3
Biomass: Existing Installed Capacity (MWe): 0; Additional Potential for Energy Generated (GWh): 2586; Total Additional Potential for Renewable Energy Delivered by 2026 (GWh): 1913
Shortcoming: Very low ambitions for wind; very modest ambition for solar, very high ambition for biomass.
3.2. Onshore Wind
Following adoption of the SPG for Onshore Wind, there was a fall from 51 wind turbine applications on Anglesey in the two-year period 2011–2012 to only 15 in the two-year period 2013–2014. Even more significantly, the number of applications approved during these two periods declined from 11 to zero. I have entered an FOI request for data covering 2015 to 2017: not yet received (late coming).
Shortcoming: Onshore wind has effectively stalled completely.
Llanbadrig: 49.9 MW. 200,000 panels on 220 acres. Approved Dec. 2017.
Aberffraw, Bryn yr Odin, Soar (beyond Rhostrehwfa; Bodorgan Estate): 15 MW
Tai Moelion (Bodorgan Estate): Also 15 MW. 1.6 km from the Soar site scheme. 64000 panels
2015: 5-MW solar farm at Fferam Parc (Lightsource) – dropped following community consultation/opposition and opposition from Anglesey Against Solar Parks.
Orthios scheme for use of biomass for electricity generation plus use of CO2 in aqua/horticulture. Bid in the Contracts for Difference Auction was rejected, despite being at a comparable level to approved biomass projects elsewhere. Project is to be revisited. Canada is now the anticipated source of biomass.
Shortcoming: Biomass is dodgy, especially if it relies on imports from N. America/Africa – cf. cf. the 2014 DECC report “Life Cycle Impacts of Biomass Electricity in 2020” by Prof. David MacKay and Dr. Anna Stephenson.
3.5. Energy from Waste
North Wales Residual Waste Treatment Project, Parc Adfer, Deeside (incinerator): will manage up to 182,000/200,000 tonnes of residual municipal, commercial and industrial waste per annum from across N. Wales, incl. Anglesey. Generating capacity: 19 MW. Comment from Unite: “Park Adfer is a stain on the construction industry, the Welsh authorities are giving carte blanche to CNIM to turn the clock back 50 years on construction rights.”
Orthios are planning to create a “Polymer Processing Centre” in Holyhead. Will create ca. 650 jobs after 3-5 years. Electricity for export to grid or use onsite. Sean McCormick, CEO: “Backing from multi-millionaire; verbal promise of £600 million plus.” Potential products include benzene, toluene and zylene (hazardous chemicals). CO2 produced in the process (pyrolysis?) could again be used for aquaculture/growing peppers etc.
Shortcoming: The commitment to Parc Adfer involves a 25/30-year contract that may impact on waste minimization and recycling since it guarantees minimum tonnages with penalties for failure to deliver. Nothing can be done about this now. The Orthios plan sounds like it needs close scrutiny!
Wylfa Newydd: Application for Development Consent Order submitted in June. Applications also submitted for a Marine Licence, Operations Combustion permit, Operations Water Discharge permit and Construction Water Discharge permit from Natural Resources Wales.
Other: A National Thermal Hydraulic Facility is proposed at M-SParc (currently the preferred site). The facility will assess new coolants for small modular reactors (SMRs), e.g. liquid lead, molten salt. UK Govt. is giving £20 million, as is WG. This sum will be released following cost assessments and development of an operational model (now underway).
3.7. Offshore Wind
Rhiannon offshore scheme dead in the water due to geological issues. No sign of it being revisited at present.
3.8. Marine Energy
Nova Innovation Bardsey Project: Company deployed world’s first offshore tidal array in Shetland in 2016 (3 turbines). Worked with Tesla to add storage. Currently: Ynys Enlli (Bardsey) project: 1 MW, ten-device array. This is viewed as a stepping stone to the Morlais Tidal Demonstration Zone. Marine energy consenting easier in Scotland than Wales. Funding also a big issue.
Morlais Project (update from M-SParc meeting, Nov 2018): One of 3 tidal stream zones in the UK designated by Crown Estate. 35 km2 of sea bed. 45-year lease. 240 MW capacity. £4.5m of EU and £200k Welsh government funds. Morlais Zone is split into 8 sections. Aim: “Plug and Play” Tidal Stream Demonstration Zone by 2023. Revenue support is a key issue. Finance for Morlais A: £5.6 million obtained so far, most from EU. Morlais B: ca. £29 million needed. Financing not yet completed. Morlais B application to WEFO 2 months ago. Submissions to WG soon. Commitments from companies to 6 of the 8 zones, plus one probably. One not filled. Two companies had dropped out. Companies: Nova Innovation, Aquantis, Tidal Stream/Tocardo, Open Hydro, Instream, Verdant, Sabella (?). Design varies: some on sea bed, some mid stream, some below surface. Also working at Holyhead Deep. Grid connection options: Orthios or Valley. £400 million of inward investment anticipated from the turbine array deployments.
Application by National Grid Electricity Transmission PLC for an Order Granting Development Consent for the North Wales Connection Project made on 4 October 2018. Now under consideration.
3.10. Energy efficiency
According to the IACC Annual Performance Report 2017-18, “The Council has an established an energy efficiency to review and improve our energy usage across the island. “The project will work in partnership with others to secure grants and funding opportunities to reduce energy consumption by 15% by 2022 in line with our strategy. The project has already secured a grant from Salix to upgrade our street lights and Leisure Centre and a further grant from WG was secured to fund LED lighting within the council building. Work is ongoing with our new area schools and leisure centres to continuously improve our carbon footprint.”
Note: The Welsh Government Warm Homes (WGWH) Programme, which includes the Nest scheme and Arbed projects, has 4 years’ committed funding totalling £104m for the period 2017-21 to improve the energy efficiency of 25,000 homes across Wales. I have not been able to identify how much will be available on Anglesey.
4. Labour Party Policy
4.1. The Green Transformation: Labour’s Environment Policy (September 2018)
a) Guiding principles
1. Ambition is based on science
2. Interventions are transformational (and not left to the market)
3. Interventions will advance our Labour values – justice, equality, solidarity, and democracy – both at home and abroad
“We must tackle environmental challenges in ways that enable us to deliver good jobs and productive industries across the whole country, while maintaining and increasing access to affordable, high quality housing, transport, energy, and food. If phasing out carbon is seen to come at the expense of any of these, we will not only be failing to fulfil our responsibilities as the party of the many – we will also undermine support for environmental protection and set back our efforts.”
“Ending our reliance on finite resources, which lend themselves to monopolistic control, by replacing fossil fuels with renewable energy sources, creates an opportunity to fundamentally redistribute power and control over resources in the economy.”
b) Three Labour priorities for environmental action
1. Preventing dangerous climate change and adapting to existing climate change
“Because Labour accepts that the climate is already changing, we commit to investing in social and infrastructural measures necessary to adapt to climate change that cannot be avoided, in a way that prioritises the most vulnerable in our society.”
2. Achieving high air and water quality
3. Reversing the decline of biodiversity and protecting natural habitats
c) Labour Policies: complete abbreviated list on energy (n=6) and heating/energy efficiency (n=6), plus two items on transport (there are others)
Ensure that 60 per cent of the UK’s energy comes from low-carbon or renewable sources within twelve years of coming to power
Support the development of tidal lagoons, starting with approval of the Swansea Tidal Lagoon
Upgrade and invest in flexible energy networks capable of supporting a transition to decentralised renewable energy, by bringing the UK’s energy transmission and distribution networks back into public ownership. This means making more use of local, micro grids and of batteries to store and balance fluctuating renewable energy, and providing the necessary investment to connect renewable energy sources to the grid
Remove the barriers to onshore wind put in place by the Conservative government, and stop the Conservatives’ chopping and changing of energy policy, investing in wind, solar and other renewable projects to support the creation of a thriving renewables industry with good, long term jobs across the UK
Work closely with energy unions to support energy workers and communities through transition
Join France, Germany and other countries around the world in banning fracking
Upgrade 4 million homes to Energy Performance Certificate (EPC) band C in our first term, investing £2.3bn per year to provide financial support for households to insulate their homes
(Promote insulation): The take up and delivery of insulation schemes will be driven by local authorities working street to street – addressing one of the main reasons for the UK’s poor record on insulation to date: over-reliance on energy companies and market mechanisms to encourage households to insulate their properties. In addition to cutting greenhouse gas emissions, this would save at least £275 per year for affected households, improve the health and wellbeing of families, reduce costs to the NHS and create new skilled jobs.
Introduce a zero carbon homes standard for new-build homes as soon as possible – an important long-term programme previously in place until it was abandoned by the Conservatives
Prioritise affordable homes in a new zero carbon homes programme, ensure all council and housing associations reach EPC band C, and provide funding to support councils and housing associations to build new homes to Passivhaus standards
Tighten regulation of privately rented homes, blocking poorly insulated homes from being rented out
Introduce new legal minimum standards to ensure properties are fit for human habitation and empower tenants to take action if their rented homes are sub-standard
Position the UK at the forefront of the development, manufacture and use of ultra-low emission vehicles, supporting the creation of clean modes of transport through investment in low emission vehicles
Encourage greater use of public transport by introducing free bus travel for under 25s where local authorities regulate or take ownership of their local bus services, paid for using money ring-fenced from Vehicle Excise Duty
4.2. Achieving 60% Renewable and Low Carbon Energy in the UK by 2030 — Expert briefing note for Labour on wind, solar and energy efficiency (September 2018), preliminary report; full findings should be available soon.
“The pathway we recommend as the most practical and realistic to achieve the 60% target is comprised of three main components: reducing heat demand from buildings by almost one quarter; providing 85% of electricity demand from renewable and low carbon sources; and providing 44% of heating demand from renewable sources.”
Four key recommendations:
1. Harness the largest offshore wind resource in Europe
2. Revive the UK’s onshore wind industry. Proposal: Double the UK’s installed onshore wind capacity by 2030 to 30 GW. This would require a 25% increase in the rate of deployment that was seen up to 2017, when the current government’s policy barriers halted the expansion of onshore wind, costing 12,000 jobs in one year. Rationale: Onshore wind currently offers one of the cheapest ways to generate renewable energy, with costs continuing to fall.
3. Unleash the UK’s solar power potential
4. Make every house a warm, dry and cheap to power home. By 2030: • All homes energy efficient • 160,000 jobs • 26% less energy • End energy poverty. Proposal: Cut domestic heat demand by approximately one quarter by 2030. This would require a huge number of skilled energy assessors, engineers, technicians, trainers and ancillary workers, with jobs spread evenly across the country through the lifetime of the programme. The backbone of the strategy is a nationwide building upgrade programme with the aim of bringing all homes in the UK up to the highest energy efficiency standards, bringing improvements to lighting, damp, draughts, security, safety and community spaces by 2030. The immediate priority will be areas with high fuel poverty and low quality housing. The second priority will be homes with lowest energy performance. In addition to a concerted retrofit programme, we propose codes for all new buildings requiring EPC A/B from the start of a Labour government, and then a low-carbon requirement from half way through the first parliament.
5. Suggestions for Action and Examples from Elsewhere
Suggestion 1. Establish a measurable renewable energy target for Anglesey, expressed as an absolute energy installed capacity figure
This would be in accordance with para. 106 of draft edition 10 of PPW and should serve as a driver for renewables. The target must be calculated from the resource potential of the area and not in relation to local need for energy (cf. PPW para 106). The target should be for low-carbon projects, associated with a carbon intensity of <50 g CO2eq/kWh, and should exclude all technologies with an inferior carbon intensity. According to the median values cited by the IPCC in 2014, this includes: onshore and offshore wind, solar, hydropower, nuclear, and tidal/wave. It does not include dedicated biomass (cited median: 230).
Suggestion 2. Promote community energy projects/”energy cooperatives” by providing support at key stages in their development
This is in line with Labour policy on a transition to decentralised renewable energy.
A high level of leadership and support from municipalities has played a big role in the success of community energy in Germany, where there are ca. 965 energy cooperatives (https://www.mdpi.com/2071-1050/10/9/3339/pdf).
One option would be to support the establishment of an Anglesey energy cooperative along the lines of those elsewhere in the UK, e.g. the Bristol Energy Cooperative, which is a not-for-profit organization, supported by community investors, that owns and manages two solar farms and 11 large roof-mounted solar PV arrays across the Bristol region and is aiming to develop more renewable energy projects to invest in. Quoting from their website: “We have a tried and tested model for installing greenhouse-gas-reducing, energy-bill-saving solar photovoltaic systems on suitable large buildings with minimal hassle and no cost to the host building. If you lease or own a building with high daytime electricity usage, an annual electricity bill of £5,000 or more, and a roof with an area of least 200m² (three quarters the size of a tennis court) contact us for a discussion using the form below or via email.”
Note re “Energy Community Cooperatives – ECCOs”: Energy cooperatives in Wales include: Egni Coop, which has installed 119 kW of solar PV on five community buildings in south Wales; Awel Coop, which has two 2.35 MW wind turbines 20 miles north of Swansea and the Ynni Teg wind turbine; and the community hydro schemes in Gwynedd. The “ECCO project” involves established community energy groups in Wales, Ireland, France, Belgium, Germany and the Netherlands. The Green Valleys Community Interest Company is the Welsh partner. Project aims to grow the ECCO network and make ECCOs part of energy policy development. Want to create five new community energy cooperatives in Wales and create development plans for existing cooperatives. A limited aim but a hint of the future.
Suggestion 3. Promote energy efficiency and aim to reduce fuel poverty
Note: The Welsh Government Warm Homes/Arbed programme has included provision of grant funding to local authorities to enable them to manage energy efficiency schemes in their areas. Current phase 3, 2017 to 2021: £47m includes £24m WEFO funding.
a) Awareness-raising programmes. Aim: to educate tenants and householders to think differently about the way they use energy and to understand what schemes are available and the role of new technology. IACC should work street by street to drive take up and delivery of insulation schemes, as per Labour policy to encourage local authorities to drive take up and delivery of insulation schemes. Also: refer people to a council website where the details of all local (Anglesey and Gwynedd) suppliers and installers of relevant insulation/technology are shown (list to be updated regularly, deleting substandard contractors). Draw attention to the “Nyth/Nest scheme” (https://nest.gov.wales/en/), which provides householders living in Wales with access to free advice and support to help them reduce their energy bills, and to National Energy Action’s Empowering Communities Cymru project.
b) Practical actions as allowed by cost/legislation: Should be ambitious and do everything possible to expedite both the retrofit of all houses in fuel poverty to zero carbon in operation standards and the building of all new houses to zero carbon in operation standards (in line with recommendation 1 of National Assembly for Wales. Climate Change, Environment and Rural Affairs Committee – “Low Carbon Housing: the Challenge”, August 2018). Labour policy supports ensuring that all council and housing associations reach Energy Performance Certificate Band C. National Energy Action has also called on WG to commit to a new fuel poverty target to improve homes to a minimum energy efficiency standard of Energy Performance Certificate Band C by 2030 at the latest. Holistic retrofit programmes need to be promoted but obviously finance is the issue. Expert advice would be needed on what can realistically be done without increases in WG action/funding.
Suggestion 4. Create new, up-to-date Supplementary Planning Guidance
Produce overarching supplementary planning guidance (SPG) to ensure it is aligned with Planning Policy Wales, edition 10. The revised SPG should cover the development of all renewables, incl. wind, solar, marine and biomass, be as progressive as possible and take into account the scientific evidence on the value of each type of renewable. In particular it should examine the merits of biomass critically and support onshore wind, taking into account legitimate constraints, e.g. AONB protection.
Note: Section 1.33 of Planning Policy Wales, edition 10 (draft), states: “Place Plans are non-statutory documents. … Place Plans should support the delivery of LDP policies and are adopted as supplementary planning guidance.” This could be problematic in view of ADN 1 and ADN 2 of the JLDP (see above). ADN 1 in particular is so proscriptive that it may be impossible to promote onshore wind significantly prior to revision of the JLDP in ca. 2026. At present the greatest scope for promoting onshore wind appears to lie in greater acceptance of “small-scale” wind turbine proposals, defined in Table 9 of the JLDP as developments under 5 MW that meet the following criteria: no more than 3 turbines, turbines up to 50 m to blade tip and turbines viewed as a small group. The table actually makes no sense, since 3 turbines of less than 50 m to blade tip would not generate anywhere near 5 MW (more likely less than 1 MW). The JLDP presumably implies that all three criteria must be met, but there could perhaps be scope for a new SPG stating that when two of the three criteria for small-scale wind turbine proposals of <5 MW are met (no more than 3 turbines, turbines viewed as a small group), the application should be accepted unless other considerations outweigh the low-carbon benefits.
As the JLDP appears to have supplanted the SPG for Onshore Wind in some respects, especially by replacing minimum separation distances with indicative residential visual amenity assessment trigger distances, it would be appropriate to produce new maps to replace those in the current SPG (see page 22 in http://www.anglesey.gov.uk/Journals/2013/04/03/m/p/c/SPG_Wind_Energy_Adopted_2013.pdf). New maps should be produced for turbines 50 m to tip height and at higher tip heights, taking into account the new indicative trigger distances and giving Welsh Government renewable targets a higher priority in relation to such considerations as scheduled ancient monuments and landscapes of outstanding historic interest. The aim ultimately should be to identify areas where 3-turbine developments would be appropriate, pending revision of the JLDP in the mid 2020s. In addition, the scope for creation of one or more new onshore wind farms post 2026 should be investigated.
These suggestions are in line with Labour policy to remove the barriers to onshore wind.
Suggestion 5: Further develop the Energy Island programme as a basis for promoting the switch to renewables and attracting more “green” jobs.
Suggestion 6: Be vigilant regarding Wylfa Newydd to minimise impacts and maximise community benefits.
Suggestion 7. Waste-related measures
Anglesey has a good collection scheme and is committed to the Parc Adfer project for treatment of non-recyclable waste, so there is not much to propose, except:
A recycling end-use register for Anglesey should be published, along the lines of the Somerset Waste Partnership register. The register shows what happens to the recyclate and how much is exported. It creates confidence in the value of recycling and ensures that the local authorities pay attention to use of the recyclate.
Suggestion 8: Gwynedd and Anglesey Well-Being Plan
Improve the next edition of the plan to take into account the implications of the latest evidence regarding climate change and to formulate concrete local responses to predicted changes.