Royal Commission on Environmental Pollution

Thank you for inviting the Association of Electricity Producers (AEP) to submit evidence to the Royal Commission on Environmental Pollution.

AEP is the trade association representing electricity producers, ranging from small firms to large PLCs. Our members encompass a wide range of generating technologies from conventional to renewable sources of energy.

We would like to comment on two particular issues related to your study: renewable energy developments and policies to reduce greenhouse gas emissions.

Renewable energy
To reach the Government's target of 10% of electricity coming from renewable sources by 2010, there must be a significant increase in the number of renewable energy projects in the UK. Our members cite difficulties in obtaining land-use planning consent as one of the greatest barriers to the development of renewable energy schemes. In particular, wind and energy-from-waste projects face formidable challenges.

The Association is keen to find ways to speed up the planning process and so avoid unnecessary and costly delays to projects. Our members work hard at a local level to inform and receive support from the local community. We have spoken to the Department of Trade and Industry about the obstacles presented by land-use planning, over many years, and are pleased that the issue is receiving more attention at present.

One of the more frustrating aspects of the planning process has been the slow response of statutory consultees; perhaps this can be tackled.

As the debate moves forward at a regional level, the Association is making contacts in Regional Development Agencies to build relationships, provide information and develop discussion. The South West Regional Development Agency has, for example, recently set up a Renewable Energy Group to promote renewable energy in its area. The Association participates in this Group.

The Association has argued that the 10% target for renewable energy should be imposed on a UK-wide basis. It continues to hold this position: the recent 'percentage obligation' to be placed on suppliers can be traded, making local renewable energy resources potentially a more valuable commodity. We understand, however, that regional bodies may need to be encouraged to have their own targets to focus their discussions and developments.

Perhaps I could draw your attention to two documents published recently, that you may want to bear in mind and possibly use to support your arguments: European Commission draft Directive 'on the promotion of electricity from renewable energy sources in the internal electricity market' and the DETR's 'Guidance on Preparing Regional Sustainable Development Frameworks'. The EC's suggested 'fast-track' system for renewable energy projects might focus attention on consent deadlines.

Greenhouse gas emissions
The electricity sector emits around a third of the country's CO2 emissions. For those generators who use fossil fuels, and by extension for the industry as a whole, greenhouse gas emissions and their control are integral to current business activity and investment decisions.

To date, the generating sector has provided the largest sectoral reductions in greenhouse gas emissions. CO2 emissions have been reduced from 54 million tonnes of carbon (MtC) in 1990 to 40MtC in 1997, whilst electricity demand over this period rose by 14%.

The Association would emphasise that industry is best placed to make assessments and decisions that involve knowledge about the company, the sector and available opportunities. In the area of greenhouse gas emissions abatement, the Association has long advocated caps on emissions being agreed through negotiation between Government and industry, then a trading scheme being set up to allow for emission reductions to take place where they are cheapest across the economy as a whole.

Principles
The approach outlined above should be replicated in other areas of environmental planning. Once environmental targets have been set, industry should be allowed to meet them. Monitoring and compliance procedures should ensure the environment goal is achieved.

Environmental planning, where it consists of setting and achieving environmental goals, crosses many economic sectors and Government departments and other regulatory bodies. The Association would urge that the importance of communication between players as the rules are set and the goals are achieved is recognised.

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