South East Scotland Quakers respond to Scottish Government Energy consultation

South East Scotland Quakers have responded to the Scottish Government Consultation on a Scottish Energy Strategy: The future of energy in Scotland. Our full response is published below.

Response from Religious Society of Friends (Quakers) - SE Scotland Area Meeting to Draft Scottish Government Energy Strategy, May 2017

1. What are your views on the priorities presented in Chapter 3 for energy supply over the coming decades? In answering, please consider whether the priorities are the right ones for delivering our vision.

South East Scotland Area Meeting includes all local Quaker meetings in Edinburgh, Lothian, Scottish Borders and southern Fife.  As a community, we share a particular concern with the challenge of living sustainably.  We believe it is important to consider how we can meet our own needs here in the present without compromising the rights of those poorer than ourselves, in Scotland and elsewhere across the globe.  We believe it is important to uphold the rights of future generations and the rights of other life-forms – with which we are intimately connected and on which we ultimately depend. 

Most of our response to the draft Energy Strategy is of a general nature that does not fit readily with the consultation questions – so we have included these points in our response to Q1.

We welcome much of the content and aspiration of the draft strategy, including the whole-systems view, the emphasis on energy efficiency and renewable energy supply targets and, especially, the importance attached to developing local energy economies and community energy solutions.

However, we have a number of concerns – or what we would prefer to frame as opportunities – that we feel are not fully realised in the draft Energy Strategy.  Please address these in your re-drafting:

  • We are concerned by the emphasis on continuing investment in recovering remaining North See fossil fuel reserves.  It is urgent that fossil fuel use is phased out as soon as possible and we feel that such investment would be better focussed on rapid and permanent reduction in energy demand as well as in transition of skills into development and implementation of offshore renewables.
  • We are concerned also by the reliance on unproven Carbon Capture and Storage technology.  At the very least, we feel that there needs to be an alternative scenario in case CCS fails to deliver and we would prefer to see investment in proven techniques for managing our soils as carbon sinks, with associated benefits for biodiversity, climate adaptation, health and agriculture.
  • It is crucial that we get beyond the mantra of ‘sustainable economic growth’.  GDP is no longer a useful measure of economic performance.  What was at one time the means has become confused with the end. If we are to create a Fairer Scotland, we need better indicators of well-being.
  • Reimagining the purpose of the economy gives the opportunity to ask what sort of communities we want to live and work in.  Renewable energy is dispersed and diffuse by nature;  so the creation of local energy economies is a real opportunity to (literally) empower people to create communities that maximise well-being and opportunities for meaningful local livelihoods.
  • Creation of more localised economies creates opportunities for communities to become empowered to created innovative local solutions, enhancing resilience locally and nationally and driving down energy demand – for example through greatly reduced need to travel.
  • We welcome the idea of developing Local Heat and Energy Efficiency Strategies, provided this process meaningfully engages local communities in truly representative forums.  There is an opportunity to link this together with local (climate resilient) place plans as part of connecting the Planning Reform, local democratic renewal, regeneration and Community Empowerment agendas.  Such master-planning must also follow through to enable and support communities to fully realise community benefits through appropriate technical and capacity building support, ideally through a trusted, community-led, intermediary organisation such as Community Energy Scotland.  
  • Linked to this is the need to clearly distinguish between ‘local’ and ‘community’ ownership (conflated in current energy generation targets) and to ensure opportunities for community ownership of all parts of the energy supply system and for active community participation and involvement in implementation of local energy efficiency measures. 
  • We suggest that community owned energy infrastructure proposed as part of democratically agreed masterplans should carry a presumption of planning approval in recognition of the wider socio-economic benefits as well as the creation of a robust and resilient energy infrastructure appropriate for the decentralised, renewable future economy. 
  • The scope for most communities to engage with community energy ownership has been greatly diminished by the removal of feed-in-tariffs / ROCs. Given the wider local benefits of community ownership and the voluntary effort this can leverage, we believe that there is a strong case for lobbying the UK Government for a ‘Community FiT’ to provide predictable, long-term support. 

2.  What are your views on the actions for Scottish Government set out in Chapter 3 regarding energy supply? In answering, please consider whether the actions are both necessary and sufficient for delivering our vision.  

We believe that Chapter 3 promotes a faulty emphasis on energy supply rather than outlining options to reduce energy consumption.  These opportunities will include technical and engineering solutions – most of which already exist.  However these opportunities also rely on a cultural shift in understanding about how to flourish on a finite planet. 

We express some doubt about the reliance on BioEnergy with Carbon Capture and Sequestration and urge Ministers to look more closely at benefits of delivering more wide spread change through existing established grassroots initiatives which would have an enduring impact. 

3.  What are your views on the proposed target to supply the equivalent of 50% of all Scotland’s energy consumption from renewable sources by 2030? In answering, please consider the ambition and feasibility of such a target.  

We note the dramatic year-on-year reductions in costs of solar photovoltaics, wind turbines and of distributed electricity storage and the recent cost reductions achieved for onshore offshore wind turbine arrays and we ask the Government to re-calculate costs and benefits again before publishing the final Energy Strategy to 2050. 

We believe a more ambitious renewable target should be set – say 75% by 2030 with total net decarbonisation feasible using existing technologies by 2040.  The latest research report published by the Centre for Alternative Technology at Machynlleth, Wales – Zero Carbon Britain: Making it Happen – outlines a clear way forward using existing technologies IF the right policy direction were taken. 

4.  What are your views on the development of an appropriate target to encourage the full range of low and zero carbon energy technologies?

We commend the ambition you have set, and the funding you have already allocated over recent years, to deliver a de-carbonised energy system in a very short timescale.  We believe stronger emphasis is required on funding for energy efficiency and low carbon local heat and energy efficiency. 

5.  What ideas do you have about how we can achieve commercial development of onshore wind in Scotland without subsidy?

We believe Government should allocate capital grant funding to community organisations promoting renewables where the surplus arising is asset locked for the benefit of the local community.  Promote financial and governance models which embrace mutual benefit – with surpluses being allocated to reinvest in local energy efficiency schemes and further low and zero carbon technologies and or promote social cohesion / for community benefit. 

6.  What are your views on the potential future of Scotland’s decommissioned thermal generation sites?

We recognise that such sites – like former Cockenzie Power Station are all very valuable point source locations for renewable electricity generation and recommend installation of very large Solar Photovoltaic arrays and / or marine energy generation [depending on site].  

The presumption should be that these sites would be developed by or on behalf of the local community as they were all established by publicly-owned entities – so contributing to the target for Community Owned and Controlled proportion of energy generation.  

7.  What ideas do you have about how we can develop the role of hydrogen in Scotland’s energy mix?

The opportunity to create hydrogen from water by electrolysis when large wind farms / other renewable energy generation facilities are facing constraint is vital.  We encourage further modeling to determine where these conversion facilities might best be located which would result in sensible distributed energy storage.  This might be adjacent to the main trunk routes for gas grid conveying gas from St Fergus and Bacton? 

We note that Hydrogen can both be injected into the existing national gas grid in low proportions – as can Bio-Methane from Anaerobic digesters – or used for direct firing in modified heat and / or power facilities using reciprocating engines or fuel cells.  

8.  What are your views on the priorities presented in Chapter 4 for transforming energy use over the coming decades? In answering, please consider whether the priorities are the right ones for delivering our vision.

We are concerned that Local Authorities alone do not have sufficient capacity to deliver the necessary leadership and technical skills to prepare Local Heat and Energy Efficiency Strategies;  nor to manage Scotland’s Energy Efficiency Programme on their own. 

Both these initiatives [LHEES and SEEP] need integrating and we suggest that the a national agency be charged with facilitating the overall collaborative master-planning of the response by ALL statutory bodies AND related publicly-funded bodies.  

We suggest that these Public Bodies – all those involved in Community Planning Partnerships – should be charged with collectively implementing plans which dramatically reduce the carbon footprint of the existing building stock and urban and rural infrastructure and ensure any new developments meet very ambitious low / net zero carbon levels. 

Scottish Government could effectively support and direct the development of locally-matched solutions to the challenges ahead and ensure good cross-fertilisation of best practices / innovative approaches between the different local authorities and even different LHEES teams within and across some council boundaries where appropriate. 

9.  What are your views on the actions for Scottish Government set out in Chapter 4 regarding transforming energy use? In answering, please consider whether the actions are both necessary and sufficient for delivering our vision.

We believe that significantly greater staffing and systems must be urgently deployed to enable the delivery of Energy Efficiency as a Nation Planning Priority.  Resources need to be diverted from other political priorities like road building if the ambition is to be met. 

We encourage Ministers to make grant support to public bodies contingent on their collaborative implementation of programmes where schemes are worked up by more than one public body for mutual benefit.  This is especially important when the potential for community heating schemes employing heat networks are concerned. 

Scottish Government has belatedly recognised that low-grade heat is a huge component of the nation’s delivered energy and yet very little recognition is given to the crucial role of mutual benefit from heat networks serving multiple types and classes of buildings. 

Diversity thus achieved will go a long way towards optimising such heating systems – especially when combined with Private Wire delivery of both heat AND power to a significant proportion of buildings in Scotland existing dense urban communities. 

10.  What ideas do you have about what energy efficiency target we should set for Scotland, and how it should be measured? In answering, please consider the EU ambition to implement an energy efficiency target of 30% by 2030 across the EU.

We believe that Scotland should be much more ambitious and draw on the huge ambient energy resources available to us from wind, wave and tide as well as solar – to set a significantly higher target.

11. What are your views on the priorities presented in Chapter 5 for developing smart, local energy systems over the coming decades? In answering, please consider whether the priorities are the right ones for delivering our vision.

The big challenge as we see is that each major energy industry operates in a silo: Gas and Electricity don’t collaborate.  We urge support for any new monopoly utility like District Heating to achieve an equal footing. 

We invite urge Ministers – together with teams from BEIS and other UK departments involved in competition policy etc – to re-imagine a regulatory mechanism which emerges out of Ofgem and treats Heat, Power and Gas companies even-handedly on a lowest carbon cost basis to deliver monopoly services to customers.  

This will certainly mean a very different statutory basis for the establishment of heat networks which enable the not-for-profit / mutually-owned organisations developing and installing district heating infrastructure to obtain capital funding at very low interest rates with long time horizons envisaged for the appreciation of value. 

We see that storage of energy in the form of heat might be a vital component in an integrated full-on renewables mix – where constrained power can be fed into thermal stores / buffer tanks which already provide for heat networks to be run more effectively to smooth out peaks and troughs.  This will mean collaboration between three monopolies.

12.  What are your views on the actions for Scottish Government set out in Chapter 5 regarding smart, local energy systems? In answering, please consider whether the actions are both necessary and sufficient for delivering our vision.

We are concerned that there are not enough resources identified to back-up to the proposals outlined.  Please don’t only think of these initiatives solely being delivered through the local authorities alone. 

Community Planning already requires LAs to collaborate with all statutory bodies in their area to bring forward collectively agreed plans and programmes which benefit citizens through cohesion and co-working.  This concept MUST be applied to the energy supply and efficient usage conundrum too!

13.  What are your views on the idea of a Government-owned energy company to support the development of local energy? In answering, please consider how a Government-owned company could address specific market failure or add value.

We recognise some merit in the idea of establishing one single entity such as a Scottish Energy Company – or perhaps establish a framework whereby locally-owned and managed initiatives might benefit from collective knowledge, skills exchange and access to capital through some form of consortium?

Please consider using the knowledge, skills and local contacts of existing national agencies as a stepping stone to such a new entity.  We encourage a review of the different structures and competing entities such as the Zero Waste Scotland / Resource Efficient Scotland / Energy Saving Trust / Home Energy Scotland / Local Energy Scotland / Community and Renewable Energy Scotland etc. 

Simplify these multiple agencies down to deliver services through trusted local partners that have track record.  And simplify absolutely the entry points and the range and extent of grant support and stop changing the names of everything.  Plan for at least ten year frameworks which consistently offer support to key target audiences. 

14.  What are your views on the idea of a Scottish Renewable Energy Bond to allow savers to invest in and support Scotland’s renewable energy sector? Please consider the possible roles of both the public and private sectors in such an arrangement.

There is real merit in establishing a Scottish Energy Bond or similar financial offering; and there may well be merit in promoting mechanisms which support local energy bonds too.  Several successful Community Share Offers have financed a growing number of the community energy installations and raised millions in this way – e.g. £1.4million raised by Edinburgh Community Solar Co-operative to install solar photovoltaic panel arrays on 24 publicly-owned buildings.  

15.  What ideas do you have about how Scottish Government, the private sector and the public sector can maximise the benefits of working in partnership to deliver the vision for energy in Scotland?

We ask Scottish Government to provide a clear and unwavering de-carbonisation roadmap for the direction of travel.  We urge a refresh of the clear-sighted Sullivan Report with clear timetable and targets for zero carbon domestic and non-domestic buildings – and for the Scottish Government to be absolutely resolute; and then everyone will co-operate.  Most important is to get the public bodies co-operating on major energy infrastructure opportunities like heat networks as a condition of funding allocation to them. 

Simply ask the Chief Execs to get their people working together on implementing the Energy Strategy for mutual benefit.  This might be on building capacity in the local SME market players for energy retrofit capacity / training trades staff in the necessary higher installation standards required by Passivhaus and similar low energy standards. 

And of course re-instate the Sullivan Report timetable for Low and Zero Carbon new building AND introduce retrospective enhancement of existing building stock … with sufficient grant support to make it worth the owner’s while to embark on ambitious energy efficiency measures.  Carrot required as well as serious stick! 

16.  What ideas do you have about how delivery of the Energy Strategy should be monitored? 

We encourage the Government to set robust high level objectives for these ambitious plans and not to micro-manage every step of the way;  and to encourage innovation in developing open-hearted delivery vehicles which bring especially the public bodies together and in due course private and commercial interests for mutual benefit. 

17.  What are you views on the proposed approach to deepening public engagement set out in chapter 6?

It is significant and not altogether welcomed that the draft Energy Strategy opens with assurances that there will be full support for the oil and gas industry and only at the very end gets to the engagement of the five or six million people who are those that really have to embrace a low carbon future as an underpinning element of a smart and successful and relatively prosperous Scotland in coming decades. 

We believe it is not enough to tack a bit of ‘behaviour change’ at the end and hope this will keep folk happy.  There is not sufficient recognition of the essential learnings from research SG commissioned with DEFRA which resulted in the ISM (Individual-Social-Material) toolkit.  Please use this tool to engender collaboration across SG departments!

The revised version of the Energy Strategy we look forward to will put community engagement, community empowerment and co-creation of both the programmes and the governance structures needed for the new energy infrastructure right centre stage.  It will make much clearer that hydrocarbons have been amazing drivers for our current levels of development but that Scotland is firmly in the 21st century – the Solar Century. 

Most important of all is the need to start discussing how these huge changes are going to be financed.  This will take many years of consistent and unwavering grant support and provision of skilled advice for small and large organisations which emerge to help deliver the aspirations outlined in the Energy Strategy.  

 

We thank you for the opportunity to respond to this strategy and hope you will consider the role that faith groups and community organisations will need to play in implementing the deep changes needed in our society to achieve a low carbon society free of the burden of fuel poverty. 

 

Elizabeth Allen, Clerk

South East Scotland Area Meeting of the Religious Society of Friends (Quakers)

27 May 2017

 Image from Wikimedia commons in the Public Domain