8/3/2019 Greener Leith ROC Consultation Response

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Greener Leith

36, Newhaven Road

Edinburgh

EH6 5PY

www.greenerleith.org

 justask@greenerleith.org

 

Neal D Rafferty

Renewables Routemap Team

4th Floor 

5 Atlantic Quay

150 Broomielaw

GLASGOW

G2 8LU

Telephone: 0300-244-1227

Neal.Rafferty@scotland.gsi.gov.uk

 Dear Mr Rafferty,

RE: consultation on the review of ROC bands applying under the Renewables

Obligation (Scotland) mechanism.

 

Please find the Greener Leith response to selected questions from this consultation below.

● What are your views on the proposal to remove support for large scale

dedicated biomass electricity plants?

 

We are of the view that the current Scottish Government policy on biomass is the right oneas it will maximise the carbon savings that can be delivered from this resource. It thereforeseems logical to align the subsidy regime in such a way so that it supports the current

policy of favouring deployment of biomass in heat-only or combined heat and power plants,particularly off gas-grid, and to a scale which maximises heat use and local supply.

 Taking the Leith plant currently proposed by Forth Energy as an example, it is not scaled to

supply a specific, identified heat demand. Nor is it scaled to maximise the benefits of local

supply or located off gas grid. Yet it could still claim and estimated £116,880,000pa of ROC

subsidy over twenty years under the current arrangements, even if none of the heat from

the plant is ever used.

By comparison, it is worth noting that a ten year programme for reducing the energydemand of every home in Scotland was costed at £170,000,000 per year by the Association

for the Conservation of Energy1.

 

1 Submission from the Association for the Conservation of Energy to Scottish Parliament Finance Committee consultation on draft

budget proposals for 2012-2013. Available at: http://bit.ly/skvhyn

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

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Lastly, as large plants in urban areas are likely to be perceived as ‘bad neighbour’ 

developments they inevitably bring with them significant planning conflict relating to, for

example, increases in traffic, negative economic impacts on the surrounding area, visual

amenity, nuisance and air quality concerns.

We believe the simplest means of minimising lengthy, expensive planning disputes,the risks of unsustainable international impacts of large scale biomass imports, AND of 

incentivising the construction of biomass plant off the gas grid is to put an upper limit on all

large scale biomass plants beyond which no subsidy will be paid.

 

Were the Scottish Government to align the ROC subsidy scheme with the banding of the RHI

for biomass then this could create a powerful economic incentive to develop small scale CHP

biomass plants, based on a more sustainable local supply, which could then be connected

up as local heat networks develop. This would help to foster a more sustainable, diversified,

decentralised, and therefore more robust heat and power system.

Placing an upper limit on the size of biomass plants which qualify for subsidy would notprevent the development of urban heat networks, but it would serve to promote an

incremental, and more diversified, approach to the development of efficient local heat

networks, such as those already implemented by award winning Aberdeen Heat and

Power.15 This non-profit firm already supplies low carbon heat to 1000 homes in Aberdeen

from a series of small gas powered CHP generators.

In our view, this incremental approach to developing heat networks is a more practical

and socially just model that the Scottish public sector should aim to support and replicate

throughout the country.

 

● Do you believe there is a need to revisit the biomass content  threshold of 90%? 

No. Reducing the content threshold blurs the boundary between biomass fuelled plants and

Energy from Waste plants.

 

Given the unenviable record on air quality of some existing Waste to Energy plants in

Scotland16, we would prefer to see subsidies for biomass energy used to support genuine

biomass fuels.

 

The 90% content threshold helps to support this distinction.

 

15 Combined Heat and Power System reaches milestone. City of Aberdeen Council. October 2010. Available at: http://

www.aberdeencity.gov.uk/CouncilNews/ci_cns/pr_domesticsuccess_090910.asp

 

16 Dundee Energy Recycling Ltd. Emissions breaches figures from SEPA. See: http://www.gainscotland.org.uk/dundee-derl.shtml

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

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About this response

 

The Greener Leith committee consent to this consultation response being made available

to Scottish Government officials and placed in the public domain. Greener Leith committee

members are willing to be contacted by Scottish Government Officials to discuss thisresponse further.

Prior to submission to the Scottish Government, members of the public were invited to

comment on the draft of this document online via our website and Twitter. After comments

were received, the final version was agreed by our management committee.

 

About Greener Leith

 

Established in 2006, Greener Leith is a registered charity that is managed entirely by local

residents who have professional backgrounds spanning planning, green energy, landscapearchitecture, finance and community engagement. Greener Leith, with the support of a

CARES Loan from the Scottish Government, is currently exploring the feasibility of buildingScotland’s first community owned urban wind turbine on the Edinburgh waterfront at

Seafield. 

With the help of hundreds of local supporters, Greener Leith promotes community

involvement, sustainable development and better public spaces.

For more information on what we do, see www.greenerleith.org

 

Yours Sincerely,

Alastair Tibbitt,

Trustee, Greener Leith.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095