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1 Response on Behalf of the Scottish Green Party General Comments The Response on behalf of the Scottish Green Party General comments The Scottish Green Party (SGP) welcomes the publication of this draft energy strategy. We welcome, in particular, the whole system approach, reference to other policy areas, and consideration of current practice, and short, medium and longer term targets. We are pleased to take this opportunity to respond to this consultation, and are glad other organisations and individuals can also participate. The SGP would welcome similar discussions in other parts of the UK, and indeed, internationally. We very strongly welcome the Scottish Government’s commitment to honouring international agreements regarding climate change. We believe that Scotland, along with other industrialised nations, must take the lead in acting urgently to reduce greenhouse gas emissions, to avoid dangerous anthropogenic climate change. So we support a key aim of this draft strategy consultation: to work out how to decarbonise the energy sector, while providing for the nation’s needs. We welcome the draft strategy’s discussion of the whole energy system, and its inclusion both of matters which are both devolved to Holyrood and of those reserved to Westminster. We would hope for constructive cooperation between the two governments on these matters, and that any differences in priorities or strategies across administrations will not hamper the implementation of the bold and ambitious final strategy which we hope will arise from this consultation. Chapter 3: Energy supply Q1 What are your views on the priorities for the Scottish Government set out in Chapter 3 regarding energy supply? In answering please consider whether actions are both necessary and sufficient for delivering our vision Regarding the specific five priorities (section 66 of draft strategy) The SGP would want to see much higher prominence given to demand reduction, when discussing energy sources. More detailed comments on this matter follow in our responses to Qs 8-10. (Naturally we welcome the discussion in Chapter 4, and the separate consultation on SEEP.) The SGP strongly disagrees that maintaining the North Sea oil and gas sector into the longer term should be a key priority. On the contrary, we oppose any new oil or gas fields. We believe the focus needs to be a move away from fossil fuels, as quickly as practicable, to low- carbon technologies. We would like to see Scotland leading in decommissioning oilfields, with opportunities to export the expertise and technologies we will be using for this. Thus we believe the priority here should be promoting a just and fair transition of the economy and jobs from the oil and gas extraction and downstream activities, to roles and sectors such as oil and gas decommissioning, development and exploitation of offshore renewable energy including wind, tidal and in the longer term wave, and also seeking new markets for current supply chains, e.g. pipes of the type used for oil could also be used for district heating schemes – these pipes are currently imported. Regarding carbon capture and storage (CCS), the SGP position is that this technology is yet to be proven at scale for effectiveness; neither have financing models been agreed. We 1 consider this draft strategy’s very heavy reliance on this expensive and unproven technology, to be its major shortcoming. While we support CCS research, SGP favours putting money and effort into other priorities which will be needed to deliver the future vision of a decarbonised Scotland. The SGP strongly welcomes the “increasing renewable energy generation” priority – with the caveat that renewable generation must also be sustainable considering other environmental and social factors. The SGP welcomes “exploring new energy sources [and energy carriers, such as hydrogen]” provided such sources / vectors are low carbon, and of low environmental risk. o Fracking: The SGP strongly opposes work on unconventional oil and gas (UOG), mainly on the grounds that this is continuing a fossil fuel economy, which we should be concentrating all efforts to move away from. We are also concerned about environmental risks: fugitive emissions which could make UOG more greenhouse gas intensive than coal; groundwater contamination; water consumption and generation of contaminated waste water. We question whether existing legislation is fit for purpose, and whether our regulators are sufficiently resourced to be able to minimise risks. In line with our principles on social justice, we are deeply concerned at the lack of accountability or benefit expected for communities affected. o Hydrogen as an energy vector; the SGP welcomes investigation into this, but the assumption stated in the draft that hydrogen, if used at scale, is likely to be fossil- fuel-derived, is one we would strongly disagree with, for reasons stated above. The alternative is hydrogen produced by electrolysis using renewable energy. o Any risk that structural moves towards the use of hydrogen as an energy vector creates a greater reliance on fossil fuel must be avoided. Clearly “increasing flexibility, efficiency and resilience of the energy system as a whole” will be absolutely essential to underpin any vision of a future low-carbon energy system. We do not underestimate the magnitude of this task, nor the level of investment which it will require. However, we cannot afford not to do it. 2 Q2 What are your views on the actions for Scottish Government set out in Chapter 3 regarding energy supply? In answering please consider whether actions are both necessary and sufficient for delivering our vision The SGP supports the actions relating to the priorities which we agree with, namely: increasing renewable generation, all technologies; support for new energy sources and vectors which are not fossil-fuel based; increasing the resilience of the future energy system to accommodate such changes. We would support actions to further additional priorities: promoting a just, fair and speedy transition away from North Sea oil and gas and towards a low-carbon economy, with an emphasis on using Scotland’s existing skills base and domestic supply chains; Becoming world leaders in offshore decommissioning and the development of home-grown technologies in the fields of marine energy, and future energy systems. We oppose actions relating to: long term continuation of exploitation of North Sea oil and gas; exploitation of unconventional oil and gas (for example, hydraulic fracturing – fracking, and coal bed methane). We welcome the decision of the Scottish Government to not pursue underground coal gasification. We also oppose the building of new nuclear plants, and welcome the Scottish Government’s current position on this matter. Regarding CCS, as stated above in Q1, we believe efforts and money would be better spent on other priorities to deliver a future energy system, as this unproven technology cannot be relied upon to avert dangerous climate change. The draft energy strategy appears from the graphs included to be heavily reliant on bio-energy with CCS (BECCS), apparently to be delivered by large new thermal power stations, to reach net zero electricity production by 2026. This is utterly unrealistic, given the current state of CCS technology. Future energy mix We agree that is essential to support the whole range of renewable energy and associated technologies; we agree with the proposed actions to work towards decarbonising the heat and transport sectors. Future energy system In keeping with the Greens’ internationalist aims, we would support full development of renewable resources, with connections to enable export of surplus electricity at times of high renewable energy generation, to aid not just the Scottish economy, but to enable other parts of the UK, and other countries we are connected to, access low-carbon electricity. However we recognise the need to implement ways to store and use energy generated from renewables in Scotland, because: a) we will also need far greater quantities of renewables in the future here in Scotland, to supply heat and transport needs as well as electrical demands; 3 b) high renewable generation presents opportunities to develop industries which could utilise this energy, particularly those able to schedule their energy use flexibly; and c) there will be times of high renewable output region-wide (e.g. windy weather across NW Europe), during which our neighbours may also have high renewable generation, and little need to import electricity. We welcome long-term research into “supergrids” as a possible means to export electricity over longer distances across Europe, enabling excess renewable generation in one region (e.g. NW Europe) to contribute to shortfalls in other areas. However this must not distract us from the pressing need to develop storage and other local system solutions. Even just considering the renewable capacity that is currently built or at some stage in the Planning system, if it was all to be built, wind generation, at time of high generation, would vastly exceed the capacity of both local and national networks. This is without future developments such as deep / far offshore wind, tidal and wave energy, which we expect to materialise in the future. It is imperative that network connections are upgraded, and also additional storage deployed to enable energy to be transported, used and stored at times of high generation. We welcome reference to new pumped hydro schemes in the draft strategy, and consideration of hydrogen as a possible future energy vector. We would also welcome support to investigate and aid deployment of other means of storage, including but not limited to both existing and new types of battery, compressed air, methanation of sustainably produced hydrogen where methane has advantages, and demand-side- management / demand-side-response. We see the major challenges as being:- Stabilising the future electricity system, with a very high penetration of renewable energy generation, most of which will be variable output depending upon weather and season. A much greater level of sophistication in networks, especially local electrical distribution networks, will be essential.
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