Committee for the Environment - Inquiry into Climate Change Submissions

Comments by British Wind Energy Association and Irish Wind Energy Association

20 February 2009

Summary Points

The British Wind Energy Association (BWEA) and the Irish Wind Energy Association (IWEA) welcome the Environment Committee’s Inquiry into Climate Change. The Committee is right to focus its Inquiry at identifying how Northern Ireland can play its part in tackling climate change. The scientific and economic rationales for addressing human impact on climate change is well established and widely accepted. The time for action is now.

IWEA and BWEA represent the interests of the renewable energy industry in Northern Ireland, Ireland and Great Britain. Through this submission, we will demonstrate the necessary role that wind, wave and tidal technologies will be required to play in order to meet existing climate change objectives, and provide guidance as to how the Assembly can facilitate the deliver of renewable energy and climate change targets. We very much welcome the opportunity to submit evidence at this stage and look forward to engaging with you further.

Northern Ireland can positively contribute to both the European and UK Carbon targets in two main ways. Firstly, taking advantage of the natural resources available to Northern Ireland will make an appreciable contribution to these targets. The UK has a rich variety of renewable energy resource, including 40% Europe’s wind resource. Northern Ireland has a significant share of this resource, with one of the greatest wind resources in Europe. As such, Northern Ireland has a real opportunity to make a meaningful contribution to reducing carbon-dioxide emissions through renewable energy, while meeting Northern Ireland’s energy demands and delivering a cleaner local environment.

As the world moves towards a low-carbon economy the price of carbon will increase. Northern Ireland should not be left behind but should embrace this approach; indeed Northern Ireland has the potential to be a world leader in the ever growing green economy. The region has unique access to markets and natural energy resources including wind, marine and geological storage. US president elect Obama has outlined a strategy for developing 5 million new green collar jobs in the US. Based on the relative sizes of the US and NI economies this would be equivalent to over 14 000 new jobs in NI if the region can deliver a similar strategy. IWEA and BWEA believe that Northern Ireland can use its strategic advantages to surpass this level.

We believe that there are four key areas in which the Northern Ireland Assembly can enable the renewable energy sector to realise climate change objectives:

Northern Ireland should adopt a target of 42% electricity from renewable sources by 2020.
A strategy for investment and development in the Grid infrastructure should be developed.
Consistent policy and strategy should be adopted across government. In particular energy and planning policy should be aligned.
A roadmap for policy development should be introduced to provide greater investment confidence in all aspects of the renewable energy sector

The need for action

The Committee is right to focus its Inquiry at identifying how Northern Ireland can play its part in tackling climate change. The scientific and economic rationales for addressing human impact on climate change is well established and widely accepted.

The Intergovernmental Panel on Climate Change (IPCC), a group containing over 2500 scientists, reported in 2007 that ‘warming of the climate is unequivocal’ and that ‘most of the observed increase in temperature is very likely (90%) due to human activity’. The findings of the IPCC are also supported by the Academies of Science of the 11 largest countries in the world, including the Royal Society of London.

The Stern Review calculated that the dangers of unabated climate change would be equivalent to at least 5% of GDP each year. However, when more recent scientific evidence is included in the models, the Review estimates that the dangers could be equivalent to 20% of GDP or more. In contrast, the costs of action to reduce greenhouse gas emissions to avoid the worst impacts of climate change can be limited to around 1% of global GDP each year. The central message is that reducing emissions today will make us better off in the future: one model predicts benefits of up to $2.5 trillion each year if the world shifts to a low carbon path.

The people of Northern Ireland are asking for leadership from the Assembly. A survey conducted in 2008 by Sustainable Northern Ireland for the Northern Ireland Climate Change Impacts Programme revealed that, “92% of respondents were willing to make changes to their lifestyles, especially if encouraged to do so by strong government leadership.” The Committee should provide this leadership.

The industry would welcome the opportunity to make an oral presentation to the Committee Inquiry.

BWEA and IWEA broadly support the views set out by Northern Ireland Environment Link. We have re-iterated some of these points in this response, for the purpose of emphasis. If you would like to discuss these comments we would be delighted to do so.

Submission of Evidence

The comments below relate to the Terms of Reference provided by the Committee, in its call for evidence.

a) To identify initial commitments for Northern Ireland that will ensure it plays a fair and proportionate role as part of the UK in meeting climate change targets.

The Committee on Climate Change recommended, and the UK Government has accepted that a reduction of 80% by 2050 - based on 1990 emissions levels - would be an "appropriate" UK contribution to global aims to cut emissions by 50%. The Assembly has accepted that the provisions of the UK Climate Act will be extended to Northern Ireland. However, the UK Act does not set specific emission reduction targets for the devolved administrations.

Northern Ireland’s per capita emissions of 12.83 tonnes per annum compares badly with the UK average of 10.48 tonnes, the global average of 4 tonnes and the global fair share of 1.65 tonnes.

The Executive and Assembly should urgently make commitments to introduce a Northern Ireland Climate Change Act with a legally binding regional target to reduce our carbon dioxide emissions by 80% from 1990 levels by 2050. This is the minimum requirement that will be necessary to play our part in the global attempt to avoid dangerous climate change.

To ensure we achieve an immediate and sustained decline in Northern Ireland’s greenhouse gas emissions the Executive should set an “intermediate” target for emissions in 2020, a series of legally binding 5 year “carbon budgets” and an annual carbon reduction target at an average of at least 3% per annum. Combining indicative annual milestones with the legal framework of the budget periods should offer flexibility without compromising longer term targets.

The Committee on Climate Change’s role in Northern Ireland should be enhanced to facilitate the setting and monitoring of Northern Ireland specific budgets and action plans. The Committee on Climate Change’s reports on progress and action plans should be delivered to the Assembly and responded to by the Executive.

The Committee on Climate Change should help ensure co-ordination of emissions reduction efforts across the UK. Carbon emissions in Northern Ireland and the Republic of Ireland are closely interlinked. Therefore, provisions to enable joint achievement of emissions reduction goals should be made.

All plans, programmes and policies should be assessed (Climate Impact Assessments) to determine their contribution to or impact on achieving carbon budgets.

b) To consider the necessary actions and a route map for each significant sector in Northern Ireland (energy, transport, agriculture and land use, business, domestic, public sector etc)

The Committee on Climate Change’s statutory duty to Northern Ireland includes:

To provide advice on the sectors of the economy in which there are particular opportunities for contributions to be made towards meeting the budgets through reductions in emissions.

The Committee on Climate Change’s first report was released in December 2008. It includes an analysis of what opportunities exist for making emission reductions in Northern Ireland. It states Northern Ireland could contribute emissions reductions of over 2MtCO2e (Million tonnes of carbon dioxide equivalent) per year in 2020:

Emissions from buildings and industry could be reduced by up to 1 MTCO2 in 2020 by using energy more efficiently;
More efficient vehicles and new transport fuels could deliver reductions of up to 1 MTCO2 in 2020;
Emissions from agriculture, land use and forestry and waste management sectors could be reduced by up to 0.5 MtCO2e in 2020.

BWEA and IWEA do not consider that the actions outlined above go far enough to keep Northern Ireland on track to achieve an 80% emissions reduction target by 2050. We believe that it should be a requirement of each government department to investigate the opportunities for and obstacles to carbon reductions within their areas of responsibility, and that the Public Sector procurement budget be used as a tool to deliver significant emissions reductions.

But first and foremost, it is imperative that all government departments work together in establishing a holistic approach to carbon reduction. All government departments have a key role to play in delivering a low-carbon economy and in ensuring economic, social and environmental resilience, through a commitment to sustainable development. The need for joined-up policy approaches to economic policy, energy policy and spatial planning, for example, will be essential if Northern Ireland is to deliver on existing climate change targets, and develop more sustainable communities.

We therefore recommend that the Committee on Climate Change’s role in Northern Ireland be enhanced to facilitate the setting of Northern Ireland specific budgets and action plans, and the monitoring of these budgets and plans.

The rapid deployment of renewable energy and improved energy efficiency are essential in meeting carbon reduction targets. This view is shared by many governmental, scientific and environmental stakeholders, including the IPPC, the Carbon Trust, Stern, WWF, and RSPB, etc. as key areas to target early in the de-carbonisation plans.

A Strategic Energy Framework target of sourcing 15% of all our energy (electricity, transport and heat) from renewable sources by 2020 (this is the target set for the UK in the EU Climate and Energy Package) will act as the driving forces towards a low carbon society.

To achieve the energy target it is estimated over 40% of electricity would have to be produced from renewable sources and renewable sources would also have to provide a significant source (5-10%) of energy for heating purposes. The Department of Enterprise Trade and Investment, in co-operation with its counterpart in Ireland, published the internationally acclaimed All Island Grid Study in January 2008. This study demonstrated that 42% of the island’s energy needs could be met by renewable sources. The IWEA and BWEA believe that Northern Ireland should adopt 42% as a formal target.

It is vital that a formal target is adopted as this will create the framework for other policy decisions. Without a target in place for renewable energy, development of the industry will continue to be frustrated by a multitude of detailed policy concerns and minimal progress will be made.

Achieving a 42% share of electricity from renewable sources would ensure lower wholesale energy prices, lower carbon emission, enhanced energy security and robust system stability as well as foster the growth of a multi-million pound Northern Ireland renewable industry.

c) To identify the costs associated with meeting these obligations and compare them with the costs that will be incurred if they are not achieved.

The significant emissions reductions proposed for the UK in the Committee on Climate Change’s first report can be achieved without harming the economy and at a cost less than 1% of GDP in 2020. In other words, an economy that might grow by 30% in the period to 2020 would instead grow by 29%. The Committee on Climate Change advises that this is a price worth paying, given the long-term costs of inaction on climate change.

Based on current market conditions, meeting a 42% renewable electricity target will generate private investment of over £1.2bn in wind generation in Northern Ireland. Of this, around £300m will be retained by local NI businesses. This will provide a significant boost to local industry and will create several thousand jobs in high value industries.

The Prime Minister stated that the overall added value of the low carbon energy sector by 2050 could be as high as $3 trillion per year worldwide and that it could employ more than 25 million people. The Carbon Trust estimates that more than 70,000 jobs could be created in the UK by investing in and developing offshore wind technology.

Investing in innovation and development of skills will allow Northern Ireland to benefit significantly from the growing international market for renewable energy and support services. NI is also uniquely placed to access the UK and Irish markets for energy and renewable certificates. Increased interconnection and harmonisation of policy will also facilitate access to these markets.

Government should see investment in a low carbon future as a way to stimulate the local economy (as President Obama has in the USA). The move to renewable fuels may help develop industries that will provide economic opportunities and jobs. Given the huge potential that exists around our shores for wind power there are sound economic and environmental reasons for ensuring that a significant proportion of these jobs are developed in Northern Ireland.

Action Renewables estimate that almost 6,000 short term and 400 long term jobs could be sustained in Northern Ireland, exclusively by developing renewable energy within the region. We believe that there is potential for even greater growth in the number of green collar jobs in Northern Ireland, based on the proposals of US President Obama. If the Executive were to adopt a similar strategy to the US, there would be the potential to generate 14 000 new jobs in Northern Ireland. BWEA and IWEA believe that Northern Ireland can use its strategic advantages to surpass this level.

In addition, a robust and reliable grid infrastructure will be necessary to enable the continued development of the Northern Ireland economy. A high performance grid infrastructure which takes advantage of the latest technological advancements to support both renewable and conventional generation is needed for a high performance generation portfolio. An infrastructure which can accommodate increased levels of renewable generation gives greater energy security, greater price stability and depresses the average market price, ultimately resulting in lower energy costs for consumers.

A robust grid system provides greater security of supply to Northern Ireland customers and enables investment in energy intensive industries. It will also allow for more efficient dispatch of generating resources and the reduction of transmission losses.

Further interconnection with the ROI and the UK would add to system flexibility while the enhanced integration of the SEM North and South should lead to greater price stability.

d) To identify a formal cost effective mechanism for assessing the potential impact of new policies on climate change / CO2 emissions. (Akin to Regulatory Impact Assessments/Rural Proofing)

The industry believes that long term plans, supported by a strong legislative framework, are the best way to promote efficiency and innovation in policy and technology design and thus the best mechanism to minimise costs.

A consistent policy framework facilitates the efficient delivery of objectives. This will reduce the ultimate cost of implementing any strategy to the benefit of the customer and the economy. Due to the complexity of the energy industry this is a challenging task that most jurisdictions have not effectively addressed. This strategic energy review provides Northern Ireland with an opportunity to investigate means of delivering a consistent platform for policy.

In particular there is a need to align policy between the planning and energy sectors. The development of new energy generation facilities (renewable or conventional) will have a significant interaction with the planning process. It is essential that the developments respect the character of Northern Ireland’s landscape and fit within its overall planning strategy. Once this has been achieved the costs of new developments can be reduced by aligning the planning process with energy considerations.

The current process for determining supplementary planning guidance for wind development in Northern Ireland should fit within the overall Northern Ireland policy framework. It is feared that in the event that this process imposes restrictions on the height of turbines that may be developed, Northern Ireland will be forced to develop more expensive generating facilities in the future. Reducing the height of a wind turbine leads to a disproportionate loss in energy yield. This will add significant costs to the consumer and will result in a greater number of turbines being required to deliver the same quantity of energy. We believe that Northern Ireland should use world class technology to fully reap the benefits of its natural resources.

It will also lead to less efficient and more dispersed grid development. We believe that the draft SPG should be amended to reduce its prescriptive nature. This will allow individual developments to be considered on their merits. It will allow for more efficient development in specific cases where this meets overall policy objectives.

There should also be more flexibility in the generator licensing process. In particular if it were possible to assign licenses it would simplify the transfer of ownership process and facilitate the entry of new investors to the Northern Ireland energy sector.

All plans, programmes and policies should be assessed using Climate Impact Assessments to determine their contribution to or impact on achieving carbon budgets. The process should be akin to equality screening and should be initiated at the start of policy design to maximise outcomes and minimise costs.

e) To make recommendations for appropriate targets/actions that could be included in the new Northern Ireland Sustainable Development Implementation Plan.

The key climate targets that the SD Strategy should deliver are those identified in a Northern Ireland Climate Act, carbon budgets and annual targets.

We believe that the SD Strategy should include a renewable energy strategy within it, which should be fed down to the local level and developed for each of the 11 new proposed super councils.

The SD Strategy should also help deliver the recommendations on how to achieve emissions reductions put forward by the Committee on Climate Change.

The SD Strategy could play an important role in helping to inform and empower individuals to take action to tackle climate change.

The Strategic Energy Review also has a key role to play here. While the strategic Energy Framework will set the broad direction of energy policy for Northern Ireland there will be many detailed policy issues to be developed as the industry evolves. The manner in which this policy develops is of central interest to investors and energy market players. A clear and transparent process greatly reduces the perceived risk associated with Northern Ireland as an investment location. Policy makers in Northern Ireland have an excellent track record in this regard. We strongly commend their efforts to involve industry in discussions and analysis of key issues. However, the sheer number of important issues that require analysis makes it difficult for industry to engage as constructively as it might wish. The proposed roadmap is a device to facilitate industry in its engagement.

We recommend the introduction of a formal process for policy development that provides clarity on its scope and likely timing. It is recognised that policy makers may need to make decisions on issues outside the normal timelines and process. If there is a facility available to fast track decisions and consultations where necessary we believe that it will allow the development of a more structured and scheduled approach to be adopted for the majority of policy considerations

f) To make recommendations on a public service agreement for the DOE Climate Change Unit’s commitments in the second Programme for Government that will ensure Northern Ireland will meet its climate change obligations.

The legal responsibility to deliver the targets set in a Northern Ireland Climate Change Act, and through the carbon budgets, should fall collectively on the Executive.

Specific responsibilities to deliver the targets set in the Climate Act and in the carbon budgets should be identified in public service agreements for each Northern Ireland department. Departments should prepare action plans on how they intend to deliver their reduction targets.

Sharing responsibility to meet targets across the Executive and departments is the only way to ensure that all parts of government play their part in delivering the targets.

A public service agreement should be drafted for the Department of the Environment which would include a commitment to provide information and support to the other departments to help deliver the targets set in a Northern Ireland Climate Change Act and in the carbon budgets.

g) To consider what secondary legislation raising powers within the UK Climate Change Act would contribute to Northern Ireland’s commitment to the UK Climate Change Bill.

The industry believes that the secondary legislation in the UK Bill should not be the basis of Northern Ireland’s climate change regulation. Instead, Northern Ireland should introduce its own primary legislation.

The introduction of primary legislation in Northern Ireland will enable secondary legislation to be introduced to set 5-year carbon budgets and annual carbon targets (3% annual emissions reductions is a minimum) for the region.

Secondary legislation under a Northern Ireland Act should be used to impose public sector duties to deliver targets and to set sectoral targets for emissions reductions.

The role of the Committee on Climate Change should also be set and amended via secondary legislation.

The UK Act enables targets to be reviewed and amended but the 2020 and 2050 targets should only be amended based on the best available scientific advice.

h) To express views on if and how the Assembly might conduct more effective scrutiny of climate change responsibilities across all relevant departments.

The Environment Committee should scrutinise progress towards achieving the targets in the Act and within budgets. The Minister should be asked to explain progress and outline plans to achieve the targets to the Committee

The ability of the Committees and the Assembly as a whole to scrutinise progress will be greatly enhanced by ensuring the Committee on Climate Change report to the Executive and the Assembly and that the Executive respond to their reports in the Assembly.

i) To produce a report on the findings and recommendations of the inquiry by September 2009.

The longer Northern Ireland delays significant and decisive action on climate change, the larger the task will become. Stern has concluded that early action makes economic sense. The greatest opportunities for job creation and market share in emerging technologies will also be delivered by responding early to the challenges we know we face. Therefore, the Committee should use its influence to encourage action now. Waiting until September to recommend that Northern Ireland should act on climate change, is only delaying the inevitable.