APPENDIX 66
Memorandum by Scottish and Southern Energy
Scottish and Southern Energy (SSE) is grateful
to have this opportunity to submit written evidence to assist
the Committee's inquiry into the capacity of microgeneration and
other forms of distributed generation to meet a substantial proportion
of UK electricity demand. SSE is one of the UK's largest energy
companies, with major interests in the generation, transmission,
distribution and supply of electricity and in the storage, distribution
and supply of gas. It has a variety of investments and interests
in microgeneration technologies.
The definition of distributed energy
SSE accepts the definition of "distributed
energy" which the government used in its report in July 2006
on the progress of the review of UK energy policy: "|there
are a number of ways of producing heat and/or electricity for
a home, housing development, industrial site or local community,
and of connecting these sites through small-scale electricity
or heat networks. `Distributed energy' is a broad term used to
denote this diverse range of technologies. Its essence lies in
generating electricity near where it is used."
The benefits of distributed energy
SSE also endorses the summary of distributed
energy included in the July 2006 report: it "can potentially
lower emissions, increase the diversity of our energy supply and,
in some cases, lower costs".
More specifically, SSE agrees that generating
energy more locally has the potential for more efficient use of
fuels and that a more community-based energy system might lead
to greater awareness of energy issues.
The problems with distributed energy
Distributed energy accounts for a very small
proportion of the UK's total supply. In particular, technologies
that allow energy generation at a household or community level
currently make a minimal contribution to the UK's overall energy
supply.
The fundamental reason for this is that the
main types of low-carbon distributed energy technology are relatively
new and therefore expensive to purchase. In addition, the government's
Microgeneration Strategy recognised that lack of awareness is
a key barrier which limits the take-up of the technologies. Moreover,
there are complexities involved in the arrangements for planning
consent for distributed energy developments and for dealing with
"surplus" energy.
In other words, systems and structures in the
UK are fundamentally geared towards centralised energy production
and distribution. This will need to evolve over time to allow
a significant take-up of distributed energy.
Creating opportunities for distributed energy
In its July 2006 report, the government sets
out a series of proposals for incentivising community and building-level
distributed energy. SSE is broadly supportive of many of the proposals.
They reflect SSE's submission to the energy review, which called
for a package of measures to reduce demand for energy from the
national electricity and gas grids.
The report commits the government and Ofgem
to completing a comprehensive review of the incentives and barriers
that impact on distributed electricity generation, including CHP.
This review is welcome, and should set the right context for future
policy development.
This should build on the new incentives on Distribution
Network Operators to facilitate the connection of distributed
generation introduced by Ofgem in 2005. In our view, these incentives
do not go far enough. For example, the current incentive framework
provides for a partial pass-through of capital invested, with
the rest remunerated by a £/MW term. This is sufficient to
remunerate connection of distributed generation but incentivises
DNOs to minimise their risk by investing only what is required
to accommodate distributed generation on a scheme-by-scheme basis,
leading to a piecemeal and sub-optimal development of the distribution
network. Particularly in areas where network infrastructure is
sparse (often those areas with potential for renewable generation)
there is a need to plan network upgrades to cater for sizeable
increments of generation over the medium to long term in an holistic
manner.
It is also the case that the current incentives
do not give DNOs a positive incentive to promote distributed generation
connections; nor does it allow DNOs to build distributed generation
themselves to remove the need for reinforcement where it is efficient
to do so. A more positive aspect of the current incentives is
the "Registered Power Zone" concept, which provides
funds to encourage field trials of innovative connection approaches
for distributed generation. As a final comment on the framework
of incentives facing distributed generation, SSE believes it is
possible that the uncertainties of an ongoing requirement to pay
distribution use of system charges, as now currently required
for new generation, might act as a barrier for these developments.
In SSE's view, there would be merit in reverting to an approach
whereby generation connecting to distribution systems pays a contribution
to network costs on a one-off basis at the time of connection
only, so that its commercial position is not adversely affected
by future uncertainty in ongoing liabilities.
The package of measures set out by the government
could be boosted further, in line with the content of SSE's submission.
For example, setting national targets for the take-up of micro
generation and annual reporting of progress to meet such targets
would be a step forward, as would amendment of the planning rules
to include micro generation as a permitted development.
More generally, achieving a greater contribution
from distributed energy will require an approach which embraces
both the distribution and the supply of energy, and the policy
and regulatory framework will have to accommodate this.
Meeting a proportion of electricity demand
SSE's submission to the government pointed out
that, at present, there are fewer than 100,000 homes in the UK
with any form of micro generation of electricity. Measures such
as those listed in the government's report in July 2006 should
help confirm the viability of micro generation technologies, lead
to increased production and, ultimately, lower costs.
It also quoted the Energy Saving Trust's assessment
that, by 2050, micro generation technologies could provide as
much as 40% of the country's electricity needs and deliver a 15%
reduction in carbon emissions. SSE's view is that this may be
feasible, but only if real action is taken to kick-start the sector.
On balance, the Energy Saving Trust assessment
is highly ambitious. As the government has stated, we will be
heavily dependent on much of our centralised infrastructure for
decades to come and we need to foster the growth and development
of distributed energy in a way that maintains and strengthens
the safety and reliability of supply.
In summary, distributed generation has a growing
part to play in meeting the UK's electricity needsbut that
growing part will develop over the long-term. Policy development
must reflect that.
4 October 2006
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