The British Wind Energy Association welcomes the opportunity to participate in the House of Lords' Science and Technology Committee's inquiry on the Practicalities of Renewable Energy.

  The BWEA was established in 1978 and is the representative body for companies active in the UK wind energy market. Its membership has grown rapidly in recent years and now consists of 281 companies including all grid-connected wind energy and every company with a lease to develop offshore.

  Wind energy is widely recognized as an abundant energy resource indigenous to the UK. Most commentators accept that wind is likely to represent at the very least half of the Government's "10 per cent by 2010" target because of the maturity and low cost of wind powered generation relative to other forms of renewable electricity generation technologies. Continued growth of installed wind energy generation capacity beyond this 10 per cent 2010 baseline is almost guaranteed. In representing the industry BWEA is therefore in a unique position to comment on the measures necessary to ensure that "UK Plc" is able to deliver the requisite number of MW of installed wind and other renewables capacity by 2010.

  In a letter of 18 July 2003 the Committee noted the challenging set of targets contained within the White Paper and requested information on the practical steps that will be needed to ensure that these demanding targets for renewable energy production are met. In answering this question we have been guided by the Committee's particular interest in the following four areas.

—  The cost effective technologies available now for the generation of renewable energy.

—  The number of sites potentially available for such technologies and the obstacles to taking these up.

—  The logistics of providing stand-by capacity for times when intermittent sources are not available.

—  The intermediate milestones that should be set on the way to achieving the White Paper's aims.

  In answering these questions we have clearly focussed on wind-related issues; in addition we have not, where we believe that there are additional points of relevance, confined ourselves solely to the above four areas.

  BWEA believes that the White Paper has laid out a bold vision for renewables. In creating a 10 per cent renewable energy target for 2010 and a 20 per cent aspiration by 2020 it would be fair to say that the UK is now a world leader in creating stable incentives to encourage the development of an efficient and effective renewables industry. Nonetheless BWEA would also note that political and financial commitments alone are not enough.

INTRODUCTION

  BWEA notes that there has been a significant increase in developer interest in wind farm projects since April 2002. BWEA firmly believes that this increased interest is directly attributable to the stimulus provided by the Renewables Obligation (RO). The following table clearly indicates the growth in planning submissions since the RO was introduced.

  * Full year 2003 numbers are an estimate

  and, as Figure 2 demonstrates, there are clearly sufficient numbers of MWs getting through planning.

  * Full year 2003 numbers are an estimate

  The numbers speak for themselves. However the rate at which consented projects are being built is a different story as illustrated below.

  * Full year 2003 numbers are an estimate

  Today there is about 1,400MW of wind capacity in the UK which has received planning permission but which is not being built. The remainder of this document seeks to provide the Committee with a summary of the views of the wind industry regarding matters affecting the speed with which wind farms are being constructed and the possible reasons for delays in wind farm construction.

  In this regard we would note that the barriers to further development of the UK's vast wind resource are institutional and not technical. As such solutions to them are, while not simple, entirely within government influence. We are concerned with institutional hurdles in three broad areas: Finance, Grid and Planning, and will address each in turn.

1.  FINANCE

1.1  Government track record in energy markets

  This Government has a very poor track record of regulatory intervention in the energy markets. As a result the private sector has had its "fingers burned" on a number of occasions; the most notable of these relates to investments in the 1990s in both CCGT and British Energy. The introduction of NETA and the subsequent collapse in wholesale prices, has severely damaged these investments such that there is now in the region of £10-15 billion of distressed assets in UK power generation. Given this background and continued generation capacity overhang, it should come as no surprise that the private sector does not appear to be rushing to invest a further £10 billion in building 10,000MW of renewable generation plant by 2010.

  The nature of the RO means that an investment in renewables today is affected by changes to the RO over the next 10-15 years. Consequently the value of the Renewable Obligation Certificates (ROCs) is highly susceptible to political interference. In some European countries, where the government has established a favourable track record with the financial and energy communities, such a high degree of regulatory risk would not be an issue. Unfortunately, as mentioned, the UK Government has a poor record in the energy markets. It will therefore take some time for the financial community to get sufficiently comfortable with the RO. Only once they have this level of comfort will they be prepared to make significant long-term investments in renewables.

1.2  BWEA commissioned financing study

  In June of 2003 BWEA commissioned an independent report into the efficacy of the RO. In September BWEA released the findings of this analysis and these findings are publicly available through our web-site or by contacting BWEA direct. BWEA is now consulting with its members and will not take an official position before this consultation is complete. We currently expect to have developed a view by the end of November and will share our findings with Government at that time.

  While it would seem clear from this study that the problems of the RO run deeper than the lack of a post 2010 target, BWEA would nonetheless note that the absence of such a target does not help. We are concerned that as the industry moves closer to 2010 without a clear decision being made on renewable energy targets beyond that date, the current interest in developing and building wind farms, both on and offshore, will fall off rapidly.

  Notwithstanding the above we re-iterate our view that we do not believe that a simple extension of the existing 2010 targets will necessarily provide financiers with sufficient comfort to cause them to invest capital in renewables to the degree required.

1.3  Co-firing

  On Friday 29 August 2003 the DTI opened "The Renewables Obligations (Amendment) Order 2003 Statutory Consultation". This consultation outlines a number of changes that DTI is proposing to make with effect from April 2004. Most are minor technical alterations that will have minimal impacts on the RO mechanism. However the most significant relates to an extension of the existing co-firing rules.

  BWEA would remind this Committee that the RO was created to support renewable generation and in this regard notes that the only apparent support for the co-firing changes as proposed comes from the thermal generators—specifically the coal lobby. Hardly anyone from the renewables industry believes that the measures as proposed will support renewables. On the contrary the view of the overwhelming majority is that the proposals will do great harm to the credibility of the RO and to the development of renewables.

  BWEA sympathises with the concerns of the Government that the RO in its present form is not encouraging sufficient amounts of investment in renewable generation plant. Nonetheless BWEA does not believe that the solution to this problem lies in a co-firing "quick fix". Such a "quick fix" would only benefit coal fired generators and would ensure that targets for renewables are met (even if not with renewable generation!). However it would NOT assist the development of the British biomass industry and would significantly damage confidence in the RO and hence the nascent renewables industry.

  There are real solutions to the current problems with the RO and BWEA has been investigating these for some months now. We are currently consulting internally and with other trade associations and would encourage Government to work with us to find a real solution to this complex problem.

2.  GRID

2.1  Licence obligations

  BWEA notes that, at its most fundamental, the problems that developers face in securing Grid connections can be distilled down to the simple fact that the primary licence obligations of the Transmission System Operators (TSOs) and Distribution Network Operators (DNOs) as well as the industry regulator (Ofgem) are to ensure a safe, secure and economical supply of electricity. In all instances, environmental considerations are secondary (or less) obligations. BWEA believes that the licences for all of the above institutions should include, as a primary obligation, a requirement to encourage the connection of;

  (1)  renewable generation technologies

  (2)  technologies which, while they may not comply with existing Grid and Distribution code technical specifications, are moving toward compliance and are not present in sufficient amounts to threaten grid stability.

  BWEA recognises the efforts that are being made by TSOs and DNOs to connect renewables, but nonetheless notes that these entities must be mindful, in the first instance, of their licence obligations. Consequently, until such time as the licence conditions are amended to address this problem, BWEA believes that Grid related problems will persist.

2.2  Nature of the Grid Codes

  The England & Wales as well as the Scottish Grid Codes today are functional specifications of existing, relatively mature, large centralised synchronous generation sets. Likewise the Distribution Code has been written for networks that are designed to supply customer demand with power sourced from a high voltage transmission network and subsequently delivered to demand loads which reduce with distance from that transmission network.

  Wind generation turns these traditional models upside down. At a transmission level, BWEA notes that wind turbine generators (WTGs) most commonly employ asynchronous generation technology and that this technology is relatively immature and rapidly evolving. At a Distribution level, WTGs are generally located in areas with low population and load densities and hence connecting them fundamentally alters the operation of distribution networks. BWEA therefore wonders whether a fundamental review of the Grid and Distribution Code might be more appropriate than the "tinkering" that is currently taking place.

2.3  Development of ancillary markets

  We return to the point made in 2.2 above that the Grid Code is little more than a functional specification of existing technology. In this regard BWEA is concerned that current markets for reactive power and frequency response rely on all generators having the capabilities necessary to compete in those markets. What this means is that prices in these ancillary markets are being driven down perhaps to the point where generators choose not to bid. The result of this is that the cost of providing ancillary services is then, by default, being passed on in the MWh price, thereby forcing up the cost of generation.

  BWEA feels it would be more appropriate to have a system wide review which identified the needs of the system in respect of ancillary services and examined the differing properties of synchronous and non-synchronous generation such that the benefits of each can be recognized and the ancillary services market adjusted accordingly to enable the system to obtain optimum economic and technical benefit from each. The result would be a stable grid system which would not, as is the case now, involve excessive cost for electricity consumers.

2.4  Regulatory monitoring

  The renewable energy industry generally and the wind industry specifically has, relative to existing generators and established market participants, extremely limited resource with which to be able to monitor and respond to the very many consultations and grid issues that are currently underway. The significance of this should not be underestimated and should be addressed as a matter of priority.

2.5  Intermittency

  We note that the Committee has specifically requested information on the logistics of providing stand-by capacity for periods when intermittent sources (such as wind) are not available. In this regard we would refer you to the response submitted by David Milborrow on Friday 10 October. David Milborrow is a BWEA Board member and also acts as BWEA's technical consultant. Consequently his response, which focuses specifically on Intermittency, covers all the points that BWEA would wish to make on this subject and should therefore be considered as an integral part of this formal BWEA submission.

3.  PLANNING

3.1  PPS22

  The wind industry is anxious for the ODPM to put in place the revised PPS22 Planning Guidance for Renewables in England. We flagged this as a concern to PRASEG in May of this year; nonetheless we note that the program continues to run behind schedule. Progress on TAN 8 for Wales will also be critical to achieving increased progress in planning. BWEA notes that similar guidance in Scotland, as well as strong support from the Scottish Executive, was published much more rapidly and has already proved beneficial in promoting planning consents.

3.2  Site constraints

  Planning authorities should recognize that planning is only one of many areas that a wind developer needs to consider when assessing a potential site. Industry therefore requests that planning authorities do not attempt to zone or identify sites for wind farms but instead provide clear, criteria based policies to inform and guide developers as to the planning considerations in their plan area.

3.3  Aviation

3.3.1  Low flying and Tactical Training Areas (TTAs)

  Defence Estates (DE) continues to object to all wind farm applications within TTAs. Nonetheless BWEA believes that TTAs can co-exist with wind farms as with other forms of development and transport infrastructure. DE should therefore be encouraged to cater for some wind developments in TTAs as these regions provide otherwise appropriate siting areas for wind turbines.

3.3.2  Radar

  Civil and military aviation stakeholders continue to object to wind farms which are in the "line of sight" of radar; these objections cover a very significant portion of the UK land and sea area that has wind development potential. BWEA notes that there has been no equivalent problem between wind turbines and radar in other parts of Europe. The most attractive solution developed to date has been the AMS Advanced Digital Tracker (ADT) which is currently being trialled at two sites in Scotland and is a software based filter which removes turbines from the radar display without blocking the entire area of the wind farm. It is vital that this technology is supported and developed and BWEA feels that the House of Lords may have a significant role to play in progressing this issue.

3.4  Telecommunications

  The ways in which telecom operators deal with wind turbines and their effects on remote telecoms links is inconsistent. While the Radio Communications Agency (RCA) is sympathetic, they would appear to have no control over objections raised by individual operators. BWEA believes that the solution to this should include a universally agreed set of data and distance requirements which would be available to wind developers and network operators alike and which should become accepted as best practice guidelines by all concerned. While BWEA continues to work closely with RCA on this, any support which this Committee can provide would be welcome.

  In conclusion, the various hurdles that the British wind industry has to overcome in order to build wind farms are many, varied and complex. Given the intended audience, BWEA has endeavoured to summarise these issues and in doing so we have endeavoured to ensure that none of the salient facts are omitted. Nonetheless please be assured that BWEA remains ready to give additional evidence and provide any further clarification as and when it may be required.

October 2003