1 Response on Behalf of the Scottish Green Party General Comments The

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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

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.

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;

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.  Providing “fuels” for transport and heat, which are currently dominated by petroleum and natural gas, respectively. We believe biomass / biofuels / biogas, geothermal, electrification of heat and transport, are all likely to have a part to play, but all energy sources must also be sustainable, which we elaborate below.

Sustainability comments

The environmental performance of our future energy system is not just aboutgreenhouse gases. Ecological, other environmental impacts and social impacts, are also of key importance, both here, and in source countries which supply us with materials and equipment. In line with Greens’ commitment to environmental and social sustainability, the SGP would insist that any energy generation resource or infrastructure (conventional or renewable) be subject to robust assessment to ensure it will not cause significant environmental adverse impacts or risks, and will be acceptable to people who will be affected by it, here and overseas.

Embodied energy and fugitive emissions of greenhouse gases resulting from developments

We recognise that there is “embodied energy” and thus carbon emissions associated with equipment manufacture, and also that installation of equipment can increase greenhouse gas emissions from the land. We recognise in particular the value of deep peat in Scotland and globally as a carbon store, and the importance of preserving this asset.

We welcome existing guidance on greenhouse gas emissions from onshore wind sited on peat, and consideration of embodied energy in equipment. This type of consideration should be extended to all energy generation sources, and the new connection and storage infrastructure needed for a future energy system with high penetration of renewables.

Biomass and biofuels

The SGP supports research and development of technology to produce second generation biofuels which are sourced from sustainable non-food crops, or other sustainable lignocellulose or cellulose substrates; however we oppose the use of food crops for biofuel, and note that biofuels and biomass energy production can have significant environmental impacts, and may cause greater greenhouse gas emissions than some fossil fuels.

We:  Have a presumption against large-scale imports of biomass from other continents (such as imports of biomass from North America to Drax power station in England).  Wish to see primarily residues (saw mill materials, brash etc.) used for biomass. Our expectation is that prime timber would be used in higher value applications, such as a building material, rather than for burning.  Support local forestry and other biomass crops, such as short-rotation willow coppice, particularly on ground of low or marginal agricultural value, (subject to an assessment that

planting such crops will sequester, rather than release, CO2eq).  Call for a requirement for all biomass to have a suitable certification, declaring its

sustainability, with regard to full life-cycle CO2eq emissions (including from its transport and fugitive emissions from land), and environmental and social factors such as damage to ecosystems and displacement of food crops, or their use in biofuels, which the SGP opposes. We would prioritise this requirement for imported biomass.  Call for a requirement for biomass to be labelled with a statement of the timescale over

which equivalent quantity of greenhouse gas (as carbon dioxide equivalents, CO2e) is expected to be removed from atmosphere by replacement biomass growth. This timescale needs to be considered when calculating greenhouse gas budgets.

Energy from waste

The SGP prioritises the avoidance of waste, by: “redesign, reduce, re-use, repair, refurbish and recycle” and wishes these actions to be done in preference to “recover” energy value in materials.

For food waste, for example, the SGP calls for avoidance and minimisation as key aims.

However, for wastes, residues and effluents which remain, the SGP supports recovery of biogas by anaerobic digestion (AD). We would strongly support such installations in all sewage works, for example, of a size where an AD installation would be feasible.

Though we believe biogas is not likely to be a large contributor to energy demand on a national scale, it may be significant in some local areas, and its versatility is valuable: biogas is a fuel which can be stored; it can provide heat or alternatively dispatchable electricity / CHP generation, and so may have a role in stabilising electrical networks.

We recognise further benefits AD can bring include avoidance of less sustainable disposal methods for such solid wastes, and reducing the impact (biological oxygen demand) of effluents entering the water environment.

However, the SGP does not support AD which uses a feedstock which is specifically grown for this purpose.

Financial measures: subsidies, taxes and quotas

Support for renewables The SGP supports financial measures to support emerging renewable heat and electrical generation technologies. While subsidies need not continue indefinitely, there should be stability in policy, with clear timescales for subsidies’ duration, to allow new and initially costly technologies to become competitive, and give communities, businesses and their backers confidence to proceed with such projects. Subsidies can also have a role in redressing the current system which favours large-scale centralised generation, and network constraints and /or connection charges which can make local renewable projects unfeasible. We recognise the previous success of measures such as Feed in tariffs (FiT) in promoting onshore wind, offshore wind and solar PV, to a level where these are (or are near) competitive with conventional generation. We also recognise that abrupt changes in FiT rules, and uncertainty over Contracts for Difference (CfD) have hindered further deployment of renewables. Thus, we call for stability in current financial support measures for renewables, which include FiT, CfD for offshore renewables, and the Renewable heat Incentive (RHI) rates.

Carbon tax / allowance The SGP favours the principle of a carbon tax, in recognition that the money we currently pay for fuels does not include the whole cost to the environment: these wider costs are borne by wider society, for example: by the NHS in treating ill-health caused by air pollution (largely from traffic pollution); and by future generations, and people in parts of the world most affected by climate change.

Ownership models The SGP strongly supports diversified ownership of energy infrastructure: we support a move to public ownership, on different scales. We particularly favour community ownership of local energy generation assets. The Scottish Government has made welcome progress on its target for local and community owned generation, but the vast majority of generation capacity has been “local” – i.e. small-scale but largely privately owned. Much more progress is needed to deliver on the wider social benefits that community owned renewables can deliver. Other actions we support include a stipulation for a minimum community share of new onshore wind facilities. We discuss this further in Qs 11-13.

Q3 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 comment on both the ambition and feasibility of such a target.

The SGP strongly welcomes this target. We believe a bold target is essential to move to decarbonise Scotland’s economy; but such a target must be matched with policy measures that make reaching it feasible. We believe it can be achieved, but only by going beyond what the Scottish Government has yet promised to do. Our visions of a 50% energy from renewables future requires significant reduction in energy demand in buildings (discussed in Qs 8-10); modal shift in transport away from air and road to rail, active transport and journey avoidance; an industrial sector which is increasingly

6 energy efficient, and able to utilise variable output energy from renewables; as well as a significant move to non-fossil energy vectors (electricity from renewables, and with a role for sustainable biomass / biofuels and potentially sustainably produced hydrogen) for transport and heat.

This single target must be accompanied by absolute targets on fossil fuel consumption, and greenhouse gas emissions in the energy sector.

We call on the Scottish Government to publish all the assumptions in the TIMES modelling, to allow better public scrutiny and fuller discussion. We also call for publication of a few sample “energy future visions”, illustrating potential routes to achieving the 50% target, not as targets themselves, but as examples to inform and stimulate further debate.

Planning

The SGP recognises that a great deal more sites will need to be built, including prototypes for new technologies prior to large scale adoption, if we are to hit targets for reducing CO2 emissions and the 50% all energy from renewables by 2030.

SGP favours development plans and guidance which can provide clear support for renewables, and provide certainty for prospective developers, particularly for mature technologies and where likely impacts are well-understood. Public and other interested parties must be able to participate in the process, and full scrutiny of all applications on environmental grounds must not be compromised.

Planning, SEA and EIA processes must protect the ecological and social value of Scotland’s land and seas, while maximising renewable energy outputs.

Q4 What are your views on the development of an appropriate target to encourage the full range of low and zero carbon energy technologies?

Specific targets would require more detailed analysis than is possible here, but the SGP recommends targets that include a range of terms (short, medium and long), with appropriate levels of specificity. Short-term targets need to be both specific and ambitious but achievable; longer-term targets should be flexible enough to allow for technological and social developments, while retaining a clear commitment to making the kind of radical reductions in greenhouse gas emissions the science demands. Major decision-points (such as commitments to build large-scale storage) should be mapped out as far ahead as is feasible.

Q5 What ideas do you have about how we can achieve commercial development of onshore wind in Scotland without subsidy?

The costs of onshore wind have already fallen to a level slightly below the cheapest new conventional generation plant, and solar and offshore wind costs are approaching these levels. (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/566567/BEIS_Ele ctricity_Generation_Cost_Report.pdf).

To create a more level playing field, the SGP calls for significantly greater transparency on fossil fuel subsidy and support. We note the Overseas Development Institute has recently judged the UK’s

7 transparency on the level of coal subsidy to be “very poor” and that despite providing financial support worth billions to the fossil fuel industry the UK government denies it provides subsidy. We support an end to all support for fossil fuel industries, including North Sea oil and gas, other than for aiding the transition of this industry into the low carbon economy.

We further call for the imposition of fiscal measures to constrain carbon consumption and promote renewables. We note Sweden has imposed a carbon tax on fossil fuels, with success, and that (apart from aviation fuel) transport fuels are already taxed in the UK.

Naturally such measures would have to come with a package of safeguards for those in or near fuel poverty.

Q6 What are your views on the potential future of Scotland’s decommissioned thermal generation sites?

The SGP vision is for a Scotland powered by renewable generation, and for a far more decentralised system with local generation playing a prominent role in supplying our energy needs.

The SGP calls for:

 No new nuclear power stations to be built;  No new fossil fuel power stations to be built, including on decommissioned sites;  Any plans for fuelling a thermal power station with biomass to be subject to scrutiny, and a presumption against long distance large scale imports. Full assurances of fuel sustainability must be obtained for any source material, as discussed above in our response to Q2.  We support consideration of thermal power stations run on renewable electricity-derived hydrogen, or sustainable biogas, as a possible part of the future energy mix in the longer term.

In any network with a high penetration of renewables there will be a need for backup, at least in the transition, to balance the grid. In the current environment, this includes importing electricity from England, much of which will be fossil-fuelled. It is SGP's aim to create a Europe-wide electricity network that allows renewable shortfalls in one geographical area to be met by renewable surpluses from another area but we recognise the need for the retention of some thermal generation in the transition. We would welcome the final energy strategy identifying any decision points on this matter.

On a related topic, we categorically oppose the proposal for a coal gasification power plant with CCS at Grangemouth.

Q7 What ideas do you have about how we can develop the role of hydrogen in Scotland’s energy mix?

The SGP welcome investigation into hydrogen as a potential low / zero carbon energy carrier, which may have a role in a low carbon future energy system. We recognise this technology can utilise energy at times of high renewable output (sometimes termed “power-to-gas”), and so can have a role in balancing the grid. The hydrogen has potential for use as a fuel for transport (although currently, we consider it is not yet clear it will have more than a minor role here), heat and CHP. We strongly welcome pilot projects Levenmouth Community Energy Project and Surf ’n’ Turf on Orkney.

We stipulate that the hydrogen be made from renewable energy, from electrolysis of water using electricity from renewable generation. We question, however, whether renewable energy-derived hydrogen could realistically provide heat on the scale currently delivered by the gas grid, and believe other solutions will be needed for large-scale heat demands. The draft strategy notes: “hydrogen gas at scale will most likely require natural gas (methane) as the source feedstock and as such in order to be low carbon, carbon capture and storage facilities will be a necessary requirement.” (page 36, box “Hydrogen as a means to decarbonise heat”) . As discussed above (in responses to Q1, Q2 and Q6), we do not support reliance on the unproven fossil fuel-with-CCS approach to providing our energy needs, for environmental, practical and financial reasons.

We note that hydrogen is also considered an indirect greenhouse gas: large-scale leaks of this gas would contribute to CO2eq emissions, though to a much lower level than the emissions from fossil fuels that hydrogen would displace. This must be borne in mind if large scale use of hydrogen becomes established in the future. See http://ec.europa.eu/environment/integration/research/newsalert/pdf/39na1_en.pdf.

In summary, we believe it is imperative that the Scottish Government continue to promote a broad range of renewable technologies and low carbon energy storage means, for the nation’s heat, transport and electricity needs.

Chapter 4: Energy use

Q8 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.

 addressing the need to reduce demand and increase energy efficiency through the development of Scotland’s Energy Efficiency Programme (SEEP)  Helping energy consumers manage their bills, harnessing smart technology in the home and supporting business new models in the retail market;  Supporting the introduction of viable, lower carbon alternatives across all modes of transport; and  Delivering enhanced competitiveness and improved energy efficiency in Scotland’s manufacturing and industrial sectors

The SGP strongly supports the four priorities listed in para 151, shown above.

We believe further priorities are also necessary:  Transport of people o Reduction in demand for transport, o modal shifts from high energy / carbon modes (air, road) to much lower ones: active transport, and rail.  Transport of goods o Encouragement of local food produce o A carbon tax on imported goods for which the transport emissions are significant

These additional measures on transport are particularly important because:  simply electrifying existing road transport, as suggested in the draft strategy, risks putting major strains on existing electrical networks (as the draft strategy mentions); and  other transport modes (aviation, shipping) are challenging to decarbonise, but without changes in these sectors too, it is unlikely that long-term targets will be met.

Further priorities we call to be added are:  Consumption o A carbon tax on imported goods which have been manufactured in a carbon- intensive manner. This would help make a “fairer playing field” for energy-intensive Scottish industries, particularly those affected by EUETS and other measures to reduce energy use and carbon emissions. (We recognise this is not possible for the Scottish Government to implement under the current devolution settlement.) o More importantly, a move to a far less consumerist society, where well-being is promoted over what one can and does purchase. We refer to the work done (in Wales) on the Zero Carbon Britain project (http://www.zerocarbonbritain.org/en/) as an example of a future vision, without endorsing it in detail.  Circular economy – continuing support for measures which promote maximum utilisation of resources, and thus reduce material and energy consumption and waste generation. While there are examples of great practise in Scotland, these tend to be the exception rather than the norm. We applaud work currently done by Zero Waste Scotland in this regard (see for example http://www.scot-reman.ac.uk/ and http://www.zerowastescotland.org.uk/our- work/circular-economy), and urge the Government to continue funding this.

Q9 What are your views on the actions for Scottish Government set out in Chapter 4 regarding transforming energy use? In answering please consider whether actions are both necessary and sufficient for delivering our vision

Addressing the need to reduce demand and improve energy efficiency through SEEP

Reducing demand for energy is a key plank of the SGP vision for a sustainable future. Thus we warmly welcome the discussion of energy demand in this draft strategy, and also the separate consultations on SEEP and district heating.

The SGP strongly welcomes targets to reduce energy demand, and the ambitious targets to transform heat to low carbon (80% / 96% of domestic / non-domestic heat by 2032) set out in the SEEP consultation.

We call for a similar bold level of ambition for heat demand reduction: 6% / 10% of domestic / non domestic heat demand reduction by 2032 set out in SEEP consultation is not ambitious enough, even allowing for the slow turnover of the building stock.

We call for transparency: publication of all assumptions used in TIMES modelling, and results from some sample scenarios (and clarity about what exactly the 6% / 10% refer to, e.g. how do they relate to consumption in previous years?)

We call for the following measures to reduce demand in existing buildings:

 Major and ambitious programme of fabric improvements, prioritising homes where incomes are low and building energy performance poor.  Major and ambitious programme of upgrading heating systems to be efficiency and low carbon.  Checks and improvements, where applicable, to heating and other energy control systems, including mandating that domestic control systems need to be user-friendly and easy to understand.  Training and education to help people understand energy systems in their homes. This may be particularly important with new types of heating systems, such as heat pumps.  Checks on buildings post major refurbishment, to check projected improvements have been achieved, and that no undesirable effects have been inadvertently introduced.  Operators of energy systems in commercial or public-sector buildings over a certain size, to be required to have appropriate accredited training in energy systems and energy efficiency.  Building on the existing Energy Saving Opportunity Scheme (ESOS) system, which requires large organisations to conduct energy audits and identify measures to save energy and payback times – extend this system to include smaller organisation. SMEs should be supported by a Government Owned Energy Company that can provide expertise.  Bringing in the requirement for all public buildings in Scotland to have Display Energy Certificates (DECS), which display actual, as well as predicted, energy consumption, as is the case in other parts of the UK.  Improving accuracy of the existing Energy Performance Certificates (EPCs), and work to a baseline EPC of “C” for homes in all sectors by 2025 (for all but some older or historic

residential properties, where such a level is impractical) with an expectation of increasing minimum performance of buildings;  Include targets for energy consumption for lights and appliances (including cooling systems) alongside targets for heat comsumption.

We support the introduction of minimum energy efficiency standards at the point of sale or rent but also call for incentives and other measures to promote the roll-out of these refurbishments without waiting for changes in ownership or tenancy.

Scotland should learn from the experience of our neighbours, for example:-  in Ireland, where Sustainable Energy Ireland implemented “Retrofitted Passive Homes: Guidelines for Upgrading Existing Dwellings in Ireland to Passive House Standard”; and  elsewhere in Europe, for example: “Building Renovation Case Studies: IEA ECBCS Annex 50 Prefabricated Systems for Low Energy Renovation of Residential Buildings”.

The embodied energy of buildings, as well as the energy consumed when they are occupied, needs to be considered, when assessing retrofit or indeed new-build options. We would welcome encouragement of a move to use lower embodied energy building materials, where feasible.

For new buildings, minimisation of demand needs to be designed in, by measures such as: very high quality building fabric minimising heat loss; maximising passive solar thermal heating (while avoiding overheating); natural lighting reducing the need for electric lighting; cooling needs met by ventilation and shading without the need for air conditioning systems; heat recovery systems; and wherever practical, embedded renewables to capture heat and electricity generation. In-building energy storage, of both heat and electricity, are likely to be increasingly important in future and should also be included.

For new homes, energy performance to go beyond Sullivan recommendations, and reach total-life zero carbon and zero energy buildings by 2030 at the latest. We would welcome the wide availability of certified types of building, including Passivhaus.

We recognise a need to work on the skills base within the construction industry, to ensure energy- efficiency, and what is needed to achieve this in buildings, is understood and implemented. We recommend engaging with existing training programmes in Scotland, learning from their experience and that of our European neighbours, to ensure that our construction sector can indeed deliver buildings to exacting new standards.

We also recognise that patterns of energy demand may, in future, become as important as total quantity of consumption. We welcome, in principle, the introduction of smart systems to facilitate energy use “demand side management” and / or “demand side response” which can take advantage of periods of high renewable generation (with caveats discussed below under section on tariffs). Many larger industrial and commercial users of energy already have some such arrangements; and we would welcome extension to smaller consumers, provided there are safeguards discussed below.

Helping energy consumers manage their bills, harnessing smart technology in the home and supporting business new models in the retail market

The SGP believes everyone has a right to an income which allows them to heat their home. We believe it is necessary to address all three causes of fuel policy: low incomes, energy inefficient homes, and high fuel costs.

As described above, we believe a major and ambitious programme of building refurbishment is needed across all housing sectors, including social housing and the private rented sector as well as owner-occupier dwellings. This would play a part in reducing the amount of energy required to heat homes.

We support a Citizen’s Income as one part of an economic strategy, to ensure everyone has access to an income which allows a decent standard of living. Clearly all financial “safety-nets” must take into account changing costs of energy and fuel.

Regarding tariffs:  We support tight regulation of energy suppliers to ensure they offer fair pricing structures to all customers and genuinely social tariffs to their most vulnerable customers.  We oppose regressive tariffs, with high standing charges, or higher rates per unit for first units purchased, with lower unit costs for higher consumption, which unduly penalise those on low incomes and provide no incentive to reduce energy demand.  We would conversely support the principle of progressive tariffs, in which initial units are of low costs, but unit costs rise with consumption, as a means to reward and encourage low demand, provided overall costs remain acceptable.  We support, in principle, the roll out of smart meters, provided they are able to genuinely enable customers to better understand their energy consumption, and access the best tariffs, including ease of switching supplier.  We anticipate Time-of-Use tariffs may be an option in future energy systems, particularly with increasing renewable generation.

Supporting the introduction of viable, lower carbon alternatives across all modes of transport (Scottish Govt draft strategy priority), and reducing demand for transport (SGP priority)

The SGP strongly supports initiatives stated in the draft aimed at decarbonising road transport, and the recognition in para. 169 of actions to encourage a modal shift in transport.

We believe stronger actions, and targets, are needed to reduce transport demand and emissions, including:  Better infrastructure to encourage walking and cycling.  Encouragement of journey avoidance, such as enabled by video-conferencing and flexible work arrangements.  Planning policy frameworks which take into account likely travel implications of new developments and provide sustainable transport options.  Promotion of domestic tourism in other parts of Scotland / the UK, as an alternative to holidays overseas.  A presumption that employers have facilities and policies which encourage active transport, and where practical, discourage road transport in employees.  Continuing investment in rail, to ensure it is the transport mode of choice for many medium and longer distance journeys, as the lowest-carbon form of mass transport (after active transport), and one which Greens favour returning to public ownership.  Fiscal measures to discourage air travel, a mode which largely benefits those on higher incomes, including raised airport duties (not lowered, as has been recently proposed) and a “frequent flyer tax” in recognition of environmental damage aviation causes. We would

exempt air travel to Scottish remote island communities from such a tax, and introduce a road equivalent tariff for remote islands where air travel is as or more viable (financially or in terms of fuel use) than sea or surface travel.  Imposition of a long-distance transport tax on imported goods for which transport energy consumption and emissions are significant.

Regarding decarbonisation of road transport, we agree that electric vehicles are the leading technology at present and should be supported for reasons of lower primary energy use, ability to run on electricity generated from renewables, and lack of air pollution from the vehicles themselves.

We recognise the considerable strain EVs risk putting on local electric networks (described, for example, by http://myelectricavenue.info/) , and the need for smart technologies to facilitate their charging in ways which avoid costly large-scale network reinforcements.

Our vision of a future energy system would give batteries, including those in EVs (or cheaper ex-EV batteries “retired” for use in the home or office) a role in balancing the grid, whether for supplying a householder or business with their own electricity at peak times or times of low on-site renewable output, or potentially, to sell electricity back to the grid at peak times.

We recognise that the world’s largest lithium reserves (lithium being the leading vehicle battery material) are in South America, and impacts of extracting and processing this metal can be significant. We thus call for a certification to require minimum standards of environmental performance in lithium providers and battery manufacturers, to prevent environmental damage in source countries. We would also urge the Scottish Government to support the recovery and recycling of lithium here., and to continue to fund research and development into alternative energy storage options.

We also wish the final strategy to be open to other sustainable technologies which may become viable in the future.

This strategy’s aim to address and decarbonise road transport is admirable, but shipping and aviation are also significant emitters of greenhouse gases, and ones which are difficult to decarbonise, as discussed in the Scottish Government’s Draft Climate Change Plan 2017. We would particularly welcome development of renewable-derived hydrogen in maritime transport serving our island communities, such as the Surf’n’Turf project on Orkney.

Delivering enhanced competitiveness and improved energy efficiency in Scotland’s manufacturing and industrial sectors

The SGP supports existing proposals to encourage better use of energy within industry. We call on the Government to go further.

We support the principle of the EU Emissions Trading Scheme (EUETS) a cap-and-trade scheme in which large emitters of CO2 and other powerful greenhouse gases are required to obtain and surrender carbon allowances equivalent to their emissions. Some allowances have been awarded to energy-intensive industries, and additional ones, if needed, must be purchased (and excess ones can be sold). However, the scheme has suffered from an oversupply of carbon allowances, which has led to low trading prices of these carbon allowances, and so correspondingly little incentive to reduce carbon emissions. The scheme is being revised with the aim of improved functioning and reduced

14 carbon emissions. (https://ec.europa.eu/clima/sites/clima/files/factsheet_ets_en.pdf) Despite these issues, the SGP would support Scotland remaining within the EU-ETS scheme.

We believe there is a niche for industries which consume significant quantities of energy, but can match their consumption to times of high renewable generation and low demand (and conversely, reduce consumption at high demand). Such ability may play an important role in stabilising the increasingly renewables-dominated electricity system. We realise this already happens to some extent. We would encourage an industrial policy which encourages both industries with flexible energy demands, and location of industries near generation centres (e.g. large windfarms) to reduce the need for transmission infrastructure.

We support innovation, particularly moves to materials, products and manufacturing processes of low energy -intensity, which can replace traditional more energy intensive ones. Where no such substitution is possible, electricity-using industries should be encouraged, by the use of appropriate tariffs, to be flexible in the timing of energy-intensive processes, so that as the proportion of renewable-derived electricity rises, they can carry out these processes as far as possible during times of low demand and/or abundant supply.

The SGP recognises the devastation that unplanned industrial collapse has caused to many communities, and urges a planned move away from the fossil-fuel economy, with Government support to ease the transition. We believe at least 200,000 jobs could be provided in the sectors of renewable energy, energy efficiency and decommissioning of North Sea oil and gas fields, and associated infrastructure: see the report Jobs in Scotland’s New Economy, by Mika Minuo-Paluello (https://greens.scot/sites/default/files/Policy/Jobs_in_Scotland_New_Economy.pdf). We also recognise that a reduction in energy consumption by Scottish industry will increase global greenhouse gas emissions, as well as harming those who lose their jobs, if production moves to a country where the goods are made in a less energy-efficient way. As stated elsewhere, we would support the imposition of a carbon tax on imported goods which have high embodied energy / carbon intensity in their manufacture. This would create a fairer market environment for Scottish industries.

Q10 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.

The SGP believe Scotland should be compliant with any EU-wide energy efficiency target, and would urge Scottish Government to aim higher. However, we believe sector-specific targets will be more useful in monitoring performance and ensuring that the country is indeed “on track” to reduce energy use and decarbonise.

Chapter 5: Delivering smart local energy systems

Q11 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.

 Directly supporting the demonstration and growth of new innovative projects; and  Developing a strategic approach to future energy systems in partnership between communities, the private and public sectors

The SGP strongly supports the above priorities, stated in para 184 of the draft strategy.

We would add further priorities:  Promoting local ownership of energy assets (including, but not confined to, generation assets); this is discussed further in our response to Q12.  Promoting a vision in which decentralised generation – including on a community, campus / business and domestic scale - contributes an increasingly significant part of our energy needs .

Q12 What are your views on the actions for the 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 welcome the actions proposed, as far as they go, but consider that more could and should be done.

We particularly welcome the suggestions of mapping (Scotland’s Heat Map, and Energy Masterplanning), and see such maps as key tools in identifying which low-carbon heat systems are likely to be feasible in specific areas.

While we recognise the need to avoid premature decision making which could result in stranded assets (e.g. installing one technology, but later replacing it with another) we nevertheless call for a speedy roll-out in cases where the choice is fairly clear, for example installing heat pumps (preferably ground or water source) in low density housing not connected to a gas grid or any other potential source of heating.

While Chapter 5 identifies the recent growth of community-owned renewable energy assets in Scotland, we are still far behind some countries in western Europe. The advantages of local ownership of renewable energy assets are clear from the example of Denmark, where a majority of onshore wind turbines are owned by local community cooperatives, and there is very little public opposition to turbine construction. There is also a flourishing turbine-construction industry. The cooperative model has spread to Germany and the Netherlands; there is no reason it could not work well in Scotland on the same scale as in Denmark. For this to happen, the availability of grants and loans for local energy schemes (currently provided by CARES) will need to be greatly increased in scale, and loan costs significantly decreased to the borrowers – an interest rate of 10% for pre- planning loans is likely to deter many community groups.

Scottish Greens support diverse ownership of energy infrastructure: we also advocate the encouragement of employee-owned enterprises, and there is plenty of room for municipal, state and private ownership alongside cooperatives and individual households.

Q13 What are your views on 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.

Offshore wind, tidal and wave power developments are likely to require more resources than local cooperatives could provide, so we strongly support the creation of a GOEC (Government-owned energy company). Such a company could also act as a domestic energy supplier, providing an alternative to commercial suppliers. Currently, many of the latter devote considerable effort to attracting new customers by limted-term offers, relying on customer inertia to retain them thereafter. Another function of a GOEC could be to provide information and advice to communities interested in developing their own energy solutions; Greens’ ideal is for independent community- owned local energy companies, as discussed under Q12.

Q14 What are your views on the idea of a Scottish Renewable Energy Bond to allow savers to invest and support Scotland’s renewable energy sector? In answering please consider the possible roles of both public and private sectors in such an arrangement.

We would strongly support the setting up of a Scottish Renewable Energy bond. We note that financial models requiring short pay-back times from very long term assets (such as district heating infrastructure, or ground or water source heat pumps) are a barrier to their deployment. While we recognise the Green Deal was an attempt to address this matter by providing loans, we call on the Scottish Government to explore other approaches to this matter, and the role a Scottish Renewable Energy Bond could potentially play. Such bonds should be issued by the Scottish Government; it would be possible to make such a bond hugely attractive to investors, both individual and corporate, by including a clause that, in the event of default, such bonds are acceptable means of paying taxation.

Q15 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 have no objection to the involvement of the private sector in energy production, but this should always be in the service of local communities and the wider public, and should prioritise the urgent need to reduce greenhouse gas emissions as fast as possible. To ensure this, the lead should remain with the public sector with regard to large projects, and with local communities in relation to smaller ones.

Chapter 6: Delivery, monitoring, public engagement

Q16 What ideas do you have about how the delivery of the Energy Strategy should be monitored?

We believe a broad range of measures is needed. Many of the measures in place already are useful, such as percentage of energy and electricity equivalent from renewable sources.

Additional measure could include:

Supply side:  Total annual renewable generation  Total electricity exports and imports  Total annual curtailment of renewable energy

 Electricity system failures: power cuts (number, total no. of customers affected, lost customer hours and lost MWh)  Capacity of dispatchable and non-dispatchable renewable electricity generation  Quantity of storage installed: heat and electrical, at all scales from domestic to grid-scale  Quantity of electricity sold from small renewables in a smart system

Demand side:  Annual quantity of unabated fossil fuel used in each sector and in total

Building stock:  Percentage of dwellings and non-domestic buildings in different EPC ratings; percentage refurbished since an appropriate date e.g. 2017  Total domestic and non-domestic heat demand  Total domestic and non-domestic electrical demand for lights and appliances

Transport  Annual passenger miles by road, rail, air, active transport  Vehicle fleet – different vehicle types  Transport emissions and energy consumption associated with imports of goods from overseas, and exports from Scotland  Goods and services: road, rail, sea and air miles in Scotland

Industrial energy demand  A range of measures needed, including energy intensity (energy per unit output); total consumption of fossil fuels, renewable heat, electricity  Additional new heat recovery since an appropriate date, say, 2017, and whether used “in- house” or to supply a neighbouring business or other heat demand.  Embedded energy / emissions in goods imported into Scotland Land use  Estimates of absolute quantity, and change (positive or negative) of any greenhouse gas emissions or removals from the Agriculture or Land Use, Land Use Change and Forestry sectors, affected by energy e.g. new forestry / short-rotation coppice for biomass, or energy installations. (While it is expected there will be a great overall benefit in renewable energy projects in terms of greenhouse gas emissions, energy generation and security, it is important to be transparent, and include any costs as well as benefits terms of emissions.) The method used for emissions estimation (e.g. modelling, measurement etc.) should be clearly stated.

Q17 What are your views on the proposed approach to deepening public engagement set out in Chapter 6?

The current proposals for deepening public engagement are lacking in specifics concerning central questions, such as what funding will be made available, what bodies will have the responsibility for public engagement programmes, and what range of approaches and messages will be used. We note that “The Scottish Government is committed to developing an engagement plan and will publish this plan as part of the final Strategy.”, and urge that in doing so, the Scottish Government seeks the involvement of community groups, relevant NGOs, and academic researchers into behavioural change – which will be an essential component of any successful public engagement programme. Experience from the past few decades shows that government can play a crucial role in changing

18 public attitudes and behaviour, for example with regard to smoking, and drink-driving. This has required a combination of informational campaigns, and real incentives, both positive and negative, to change problematic behaviours. Any public engagement campaign also needs to be aware of the key problem of the “rebound effect” in relation to the efficient use of energy: reductions in total energy use, and in consequent greenhouse gas emissions, are partially or even wholly lost if money saved by households or businesses is then spent on additional energy-intensive activities.