The future of energy in Scotland: consultation analysis

An independent analysis of the responses to the consultation on a Scottish Energy Strategy: The Future of Energy in Scotland.

Appendix 2: Chapter 3 - Meeting Our Energy Supply Needs: Question 2: Priorities and Related Actions

Priority 1: Continuing to support the recovery of North Sea oil and gas as a highly regulated source of hydrocarbon fuels

General support for the actions under this priority came from a range of respondents and especially from the Non-Renewable and Engineering / Network groups.

A number of respondents, however, wanted to see a reduced reliance on oil and gas and an increased focus on renewables with comments that support for fossil fuels is incompatible with the Scottish Government's commitment to act in accordance with the aims of the Paris Agreement.

Comments on specific actions, all from small numbers, are summarised below:

Action: continue to work with the Oil and Gas Authority ( OGA), the UK Government and industry to avoid premature cessation of production and maximise economic recovery of oil and gas through encouragement of innovation and investment, in line with Scotland's Oil and Gas Strategy, the OGA Corporate Plan and its Sector Strategies.

A small number of Third Sector / NGO respondents commented that this action is contrary to the commitment to a low carbon economy.

Action: with input from the Energy Jobs Task Force, provide continued ongoing support for the oil and gas industry as it adapts to the current economic challenges, ensuring that the sector can be competitive for decades to come.

There were comments that this should be Scotland-wide and not just apply to the North East and should prioritise the need to re-purpose this highly-skilled workforce for the CCS industry and sub-sea engineering.

A respondent from the Third Sector / NGO group suggested this should be reworded as: "provide support for the current oil and gas industry to transition from fossil fuels to more sustainable technologies."

Action: maximise opportunities for the transfer of skills and knowledge from the offshore oil and gas sector to support the development of manufacturing and low carbon industries - through the Energy Jobs Taskforce and the Energy Skills Action Groups and supported by the Transition Training Fund, and through the implementation of the Skills Investment Plan.

A respondent from the Engineering / Network group felt that this should be key as "skills and knowledge acquired in the North Sea are very applicable to the development and implementation of a low carbon transport and heating strategy".

An Energy - Other respondent wanted to see opportunities maximised for transferring skills and knowledge to support the development of manufacturing and low carbon industries.

There was also a comment on the need for further improvements to education and skills development, particularly in relation to innovation and decommissioning.

Action: support investment in the Oil and Gas Technology Centre, creating the conditions which help realise the ambition for Scotland to be the "go to" place for oil and gas technology solutions.

An Energy - Other respondent wanted to see a focus on research as well as investment.

Action: work with our enterprise agencies to implement the Decommissioning Action Plan, maximising the economic benefits from decommissioning of oil and gas assets for the Scottish supply chain - developing the infrastructure and capability to secure Scotland as an international decommissioning centre of excellence.

There was a comment on the need to grow the Decommissioning Challenge Fund to improve physical infrastructure.

A Public Sector / Delivery Agency / Regulator group respondent commented on the need for "requirements for end-of-life planning (focusing on reuse and remanufacturing rather than disposal or low-value recycling) to boost the adoption of Circular Economy practices in the energy sector".

Priority 2: Supporting the demonstration and commercialisation of Carbon Capture and Storage ( CCS) and CO 2 Utilisation

General support for the actions under this priority came from a range of sub-groups.

There was, however, some concern that there is an over-reliance on CCS. For example, a Third Sector / NGO respondent commented: "the Scottish Government may be over reliant on Carbon Capture and Storage ( CCS) in both the draft Energy Strategy and the draft Climate Change Plan in achieving negative emissions by 2027 and in using CCS in the short-medium term in conjunction with other technologies such as biomass".

There was also concern, from a respondent in the Academia / Research / Training group, that the actions may not be sufficient to deliver the vision for CCS.

Comments on specific actions, all from small numbers, are summarised below:

Action: work with industry to assess opportunities for small scale CCS demonstration and CO 2 utilisation projects in Scotland across a range of sources including the application of CCS within industrial processes.

A small number commented on the need for more focus on low-carbon industrial clusters.

Action: explore the opportunity to combine bioenergy production and CCS - with a view to maximising the benefits for the energy system as a whole.

Action: maintain pressure on the UK Government to align its CCS strategy with Scottish energy priorities.

Action: support the commercialisation of CCS through securing a demonstrator project, building on the conclusions of the Scottish and UK Government funded research into CCS.

Action: work with industry and the Oil and Gas Authority to ensure the retention of existing critical infrastructure, including key oil and gas pipelines suitable for use with CCS.

Respondents from various groups commented on the need for the Scottish Government to take the lead in demonstrating the benefits of CCS and developing a CCS industry; this could include financing a CCS demonstration project.

A respondent from the Public Sector / Delivery Agency / Regulator group suggested: "a full-time resource/individual whose role is dedicated to co-ordinating CCS activities across multiple sectors and organisations".

A Non-Energy respondent commented: "the Scottish Energy Strategy needs to be adaptable so that key outcomes can be delivered even if the UK Government does not support CCS. The final Scottish Energy Strategy should also explain the Scottish Government's policy for requiring the use of CCS in new thermal generation".

Priority 3: Exploring the role of new energy sources in Scotland's energy system

Several respondents commented on the actions under this priority; most were supportive.

Comments on specific actions, all from small numbers, are summarised below:

Action: following publication of the final Climate Change Plan, review the role for new technologies and energy sources as transitional fuels for use in transport, heat and industry, with practical demonstrations where necessary.

Comments on this action included, again, the need for more focus on low-carbon industrial clusters.

Action: consider how planning can support the future energy system, through policies within the current and future iterations of Scottish Planning Policy and the National Planning Framework.

This action received several comments, from various groups, and these included:

  • That this should be an overarching priority rather than an action.
  • The need for statutory timescales within the planning regime.
  • The need for Fuel Cells to be listed in Planning Guidance.
  • Consider any reforms necessary to account for the development of emerging technologies such as battery storage.
  • The need to look at the role of local authority woodlands and timber production.
  • The need for " national strategic spatial planning to identify suitable locations and set regional targets for renewable energy development" (Third Sector / NGO).
  • Proposals, from a respondent in the Local Government group, for " a national mechanism with statutory responsibility to audit national infrastructure demand and provision, and supervise by collaboration with colleagues across government the delivery of new projects [ … and … ] the introduction of a new non-local infrastructure levy".

A small number of respondents, mainly from the Renewables group, gave lengthy and detailed responses in relation to actions for planning particularly in respect of onshore and offshore wind. These included:

  • The need for a more coherent consenting process.
  • The need for confirmation of the proposed interventions to improve the efficiency of the process in light of the impending increase in fees.
  • Ensure guidelines consider the most efficient technologies aimed at maximising yield (for example taller wind turbines).
  • The need for supportive policy for redevelopment of existing wind farms.
  • The need for a comprehensive review of the offshore renewables consenting process to ensure competitive Scottish projects.
  • Streamline the planning system to avoid delays.
  • Set out what is expected for long term (25 year+) projects.

A small number voiced concern over the restrictions posed by Wild Land Areas.

There was a call to include a role for the National Marine Plan, local development plans and regional marine plans.

Action: collaborate with UK government, local government, industry and academia on the UK hydrogen routemap, establishing the strategic basis for hydrogen in the energy system, whilst continuing to fund innovative projects involving hydrogen.

This action also received several comments. Many of these, from various groups, were supportive of the development of a hydrogen routemap with comments on the need for Scotland to develop its own route map and stay 'ahead of the game' in the approach to the widespread rollout.

There was a request, from Third Sector / NGO respondents, to ensure that "exploration of the role of hydrogen does not displace, delay or detract from the use of proven low carbon technologies, particularly in the short term".

Priority 4: Increasing renewable energy generation

This section saw the largest number of comments. Respondents, from across groups, commented not only on the actions listed under the priorities but, in some cases, also commented on the actions mentioned under each of the technology headings.

There was a view, from the Renewable sub-group, that the actions need to be more transformational rather than 'business as usual'.

A Third Sector / NGO respondent wanted to ensure that incentives for increasing energy from renewables work for both nature and the climate; they pointed out that "many renewable energy technologies can have significant impacts on wildlife if they are sited in the wrong place".

There were also calls for stability in financial support measures for renewables, with a comment that changes, for example in Feed in Tariff rules, have hindered further deployment of renewables.

There was, again, some comment on the need to focus efforts on reducing fuel poverty.

Comments on specific actions, all from small numbers, are summarised below:

Action: call on the UK Government to provide a stable, supportive regulatory regime to provide certainty to renewable investors and developers - giving appropriate support for investment in renewable energy, establishing a route to market for onshore wind, and clarifying the future for the Levy Control Framework.

A respondent from the Renewable group saw this as the number one priority for the tidal sector.

Action: seek to address grid constraints in Scotland for distributed power generation at local, regional and national level, through engaging with the National Infrastructure Commission and working with local authorities, Ofgem, National Grid and Distribution Network Operators.

There was a call, from a Utility respondent, for changes to the charging system. There were comments on the need to address fuel poverty, and acknowledgement that distributed power generation could contribute to this aim.

Action: put in place measures which ensure that at least half of newly consented renewable energy projects will have an element of shared ownership by 2020.

A Utility respondent voiced concern about this action; over how this would be quantified and whether it is realistic; they asked for work to gauge the interest amongst communities. An Engineering / Network respondent made a similar comment. A Non-Energy respondent said that lack of community interest should not disadvantage any private development proposals.

A respondent from the Academia / Research / Training group, however, said there is a lack of evidence as to why shared ownership is a target and what benefit it provides.

Action: support the future development of a wide range of renewable technologies through addressing current and future challenges, including market and wider policy barriers (see box on pages 41-43).

There was a call for support to be extended to low carbon technologies such as stationary fuel cells and for CCS generation to be considered alongside other forms of low carbon generation. A Non-Energy respondent wanted to see a specific action defining an appropriate role for solar energy.

Comments on specific technologies, all made by one or two respondents, are summarised below:

Suggestions for supporting solar technologies, included:

  • The need to look at ways to assist the delivery of solar PV such as the use of Power Purchase Agreements.
  • The need for actions to support the solar industry such as encouraging public bodies to develop a strategy for solar energy.
  • Suggestions for a planning requirement to maximise installation of solar ( PV and solar thermal) in new buildings.

Suggestions for supporting onshore wind, included:

  • The need to establish a new route to market through a Contract for Difference ( CfD) mechanism.
  • Removing or reducing business rates.
  • The need for actions to support combining assets.
  • That the Strategy should recognise interconnection.
  • Reducing expectation on community benefits.
  • Managing environmental expectations;.communicating the potential for developments in restoring or improving natural environments.
  • Facilitating a more co-ordinated approach to grid connections.
  • The need for a " coherent commercially based long-term Power Purchase Agreement ( PPA) offering which enables the Scottish Government to procure and offer renewable electricity delivering positive externalities".
  • That Land Use Planning should be mentioned in relation to onshore wind.

There was also a comment, in relation to both onshore and offshore wind support, on the need for a more proportionate and affordable approach to radar mitigation.

In relation to offshore wind:

  • The need to ensure the new Crown Estate Scotland can support the delivery of offshore renewable energy projects in Scottish waters.
  • A Local Government respondent felt that action for offshore wind should include "' reduce the risk to consenting through marine planning'. Likewise for marine renewables".
  • A respondent from the Public Sector / Delivery Agency / Regulator group commented on the closure to new applications of support under the Renewables Obligation (Scotland) and wanted to see consideration given to other opportunities to incentivise developers.
  • There were also comments on the need for actions in relation to support for floating offshore wind, such as the provision of support following the closure of the Renewable Obligation Certificate system.

Comments in relation to marine technologies included:

  • That tidal power technologies need to be considered separately from wave energy and given specific support.
  • The need for a suitable revenue support mechanism for the tidal energy sector.

Comments on other technologies included:

  • The need for a strategy to support geothermal energy.
  • The need for a bioenergy action plan.

Action: building on the successes of REIF, design future support to meet energy priorities.

A small number commented in support of schemes such as REIF. There was a comment, from an Engineering / Network respondent, on the need to also give consideration to the social costs of pollution.

Action: following the final Climate Change Plan, begin work on a Bioenergy Action Plan to enhance our understanding of the opportunities of bioenergy for Scotland's energy system.

There was a call, from a Non-Energy respondent, for this to look at biomass sources and potential users. A respondent from the Engineering / Network felt this should not include "any study on direct firing of biomass as an energy source in urban areas".

A Non-Energy group respondent said the action plan "should make explicit reference to the value of biomass for heating in rural areas and the opportunities to create and sustain local employment, using local resources. The plan should also take into account issues of local air quality and sustainability in the supply chain of biomass."

A respondent from the Third Sector / NGO group wanted to see a presumption against importing biomass and biofuels.

Action: continue to offer financial support and advice to domestic and business customers of all sizes to uptake renewable heat technologies and asks that the RHI continue to cover a wide range of technologies including, biomass, heat pumps and solar thermal renewables to allow all potential Scottish investors and customers to obtain the benefits of the RHI scheme.

A small number of respondents commented on the need for additional actions to explore barriers and opportunities for heat pumps. There was a request to include fuel cells and other low carbon technologies within the RHI.

Action: work closely with the UK Government to ensure adequate incentives are put in place to continue to encourage the uptake of emerging renewable heat technologies post 2021 when the current RHI will end.

Action: carefully consider with local government the role for regulation in the development of District Heat Networks on a large scale, and for the development of Local Heat and Energy Efficiency Strategies as part of Scotland's Energy Efficiency Programme.

A small number of Renewable respondents gave lengthy and detailed responses relating to heat; main comments included:

  • The need for immediate steps to maximise uptake of renewable heat projects.
  • The need for grant and loan schemes to ensure schemes such as REIF are properly resourced.
  • The need for a clear action plan for the decarbonisation of heat.
  • The need to consider the recommendations set out in Scottish Renewables' Vision for Low-Carbon Heat in Scotland and Biomass Heat in Scotland policy papers.
  • The need for targets for renewable and low-carbon heat in the public sector.
  • The need to work with major private sector energy users to decarbonise their energy use.
  • The need to develop a low-carbon energy strategy for each sector.
  • The need to ensure business rates to not disproportionately affect on-site energy use.
  • Strengthen regulation and support to build investor and consumer confidence in respect of heat networks.
  • The need for targets for the proportion of renewable heat supplying heat networks.
  • The need for assessment of building standards to assess impact on the uptake of low-carbon heat technologies.
  • The need for a strategy for heat innovation; the need to build on the success of existing innovation demonstrators; the need to ensure successful innovation can be rolled out.
  • The need to make best use of existing infrastructure in order to lower cost and increase access to the electricity network.
  • The need to look at the potential offered by digital solutions and 'big data' analysis in relation to managing the network more effectively.
  • The need for support for infrastructure where there is aging equipment; and to increase overall efficiency.

A small number commented that they would like to see incentive schemes widened to include all low carbon heat technologies. A Utility respondent suggested an action urging the UK Government to take forward recommendations from the Energy and Climate Change Committee on future funding priorities under the RHI. An Energy - Other respondent commented on the need for the RHI to be redesigned in order to provide an upfront subsidy to overcome cost barriers. This respondent also wanted to see incentives to promote uptake of installing low-carbon heating systems as well as for training for installers.

A Non-Energy respondent wanted to see the position on Energy from Waste in the transition to renewable heat set out clearly in the Strategy.

A Public Sector / Delivery Agency / Regulator group respondent recommended that: "action to increase the deployment of heat networks is aligned with the development of green infrastructure and active travel networks". They also mentioned the potential offered by colocation with digital infrastructure.

There were also comments on the need for stronger regulation and support to build investor and consumer confidence in heat networks.

Action: following the current consultation, work with the UK Government to ensure the RTFO provides an important long term contribution to the decarbonisation of transport.

A Third Sector / NGO respondent said they would prefer an increase in sustainability criteria and support for biofuels, rather than a new target.

A respondent from the Energy - Other group commented: "Action on RTFO should consider extending the scope of the legislation to include fuels produced using sustainable feedstocks with lower overall lifecycle carbon footprint. This should include the use of sustainably produced hydrogen to achieve lower carbon footprint in refined fuels".

Additional actions suggested under this priority included:

  • Promotion of projects that combine the installation of renewables at the same time as other energy efficiency improvements.
  • A request for a price mechanism to make fossil fuels more expensive than renewable energy.
  • The need to address any barriers, including planning, to the hybridisation of renewable energy generation.
  • The need to acknowledge the continuing role of low carbon generating technologies such as nuclear; although there were also responses opposing the use of nuclear.

There were comments on the need for specific actions relating to renewable energy for the Scottish Islands; there was a comment that current policy is not helpful to renewable energy generation in these areas.

Priority 5: Increasing the flexibility, efficiency, and resilience of the energy system as a whole.

The actions related to this priority received several comments, from across groups, and were again mostly supportive. One respondent, from the Non-Renewable group, however, said they did not agree with the statement that the 'Scottish Government supports a balanced mix of electricity supply' as they felt this to be absent from the Strategy.

Comments on specific actions, all from small numbers, are summarised below:

Action: work in collaboration with BEIS and Ofgem in developing the Smart Energy Plan for the UK: seeking a fair treatment for storage and flexibility mechanisms, including pumped hydro storage ( PHS).

An Engineering / Network respondent stressed the need for a joined-up approach between the parties named; this respondent also wanted to see more focus on the potential benefits of digital. Another, from the same group, wanted to see any regulatory or commercial barriers to electricity storage removed.

Action: reiterate the proposal for the UK Government to implement a 'cap and floor' regime to provide a more appropriate regime for PHS and work with key stakeholders to realise the opportunities and overcome the barriers to deploying new PHS capacity in Scotland.

Views were mixed from the small number who commented, both within and across respondent groups, on the 'cap and floor' proposal.

While most comments were supportive, a respondent from the Engineering / Network group did not support a separate mechanism for new pumped storage capacity as, they felt, "current market mechanisms provide revenues to support this technology". A Renewables respondent wanted to see more efforts to show what PHS could contribute to the delivery of the Strategy.

Respondents from the Utility, Renewables, Engineering / Network and Individual groups made supportive comments, including a comment that a cap and floor mechanism has already been established for interconnectors.

However, respondents from the Engineering / Network, Renewables and Utility groups disagreed. Comments included: the need to consider optimisation of the existing pumped storage assets before introducing a new capacity; that a cap and floor mechanism is uncompetitive; and that pumped storage should access support on the same basis as other technologies.

Action: support innovation and demonstration of new forms of storage - including support for The Power Networks Demonstration Centre ( PNDC) - a unique world-class facility designed to accelerate the adoption of new, 'smart' technologies within advanced power grids - and work under the Energy Technology Partnership.

There was support for innovation in storage, particularly for the Island regions. There was a suggestion to consider hot water as an energy store.

Action: work with industry, academia, local authorities and environmental groups to consider proposals for re-powering existing large-scale electricity generating sites - recognising their potential strategic role in future system design and planning as part of the transition to a low carbon energy system.

A small number suggested that the application of CCS to existing large-scale sites would be beneficial. One respondent, from the Engineering / Network group, suggested the use of existing large sites such as Longannet for use within a district heating network; they also suggested the potential for electricity storage from green power generated on site. A Third Sector / NGO respondent was keen to ensure sites, especially those designated for conservation, are used sensitively.

Additional actions suggested under this priority included:

  • A request, from a small number, for an additional action on the need for specific actions in relation to grid connection and energy independence for the Scottish Islands.
  • A Third Sector / NGO respondent wanted to see consideration given to actions to reduce transport demand.


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