The UK Department of Business, Energy & Industrial Strategy (BEIS) chose 9 November 2016 to release a series of long-awaited energy policy documents. The substance of some of the announcements, which primarily cover subsidies for renewable electricity generation and the closure of the remaining coal-fired generating plants in England and Wales, was first outlined almost a year ago when Amber Rudd, the last Secretary of State for Energy and Climate Change, "re-set" energy policy in outline in a speech of 18 November 2016. Broadly speaking, the documents indicate that little has changed in the UK government's thinking on energy policy following the EU referendum and the formation of what is in many respects a new government under Theresa May.
Contracts for Difference
BEIS has confirmed that the next allocation process for contracts for difference (CfDs) for renewable generators will begin in April 2017, aiming to provide support for projects that will be delivered between 2021 and 2023. There will be no allocation of CfD budget for onshore wind or solar, consistent with the Government's view that these are mature and/or politically undesirable technologies which should no longer receive subsidies. The only technologies supported will be offshore wind, certain forms of biomass or waste-fuelled plant (advanced conversion technologies, anaerobic digestion, biomass with CHP) wave, tidal stream and geothermal.
The budget allocation is a total of £290 million for projects delivered in each of the delivery years covered: 2021/22 and 2022/23. Details are set out in a draft budget notice and accompanying note. CfDs are awarded in a competitive auction process, the details of which are set out in an "Allocation Framework" (the one used for the last auction, in 2014/2015, can be found here). It is likely that most, if not all, of the budget will be taken up by a small number of offshore wind projects, as the size of the projects which could be eligible to bid in the auction is large in comparison with the available budget.
Competition for CfDs will be fierce and Government should be able to show progress towards achieving its target of reducing support to £85/MWh for new offshore wind projects by 2026. For the 2017 auction, "administrative strike prices" have been set at levels designed to ensure that "the cheapest 19% of projects within each technology" can potentially compete successfully. Behind this terse statement and the methodology it summarises lies an extensive BEIS analysis of Electricity Generation Costs, underpinned or verified by studies or peer reviews by Arup, Imperial College, NERA, Prof Anna Zalewska, Prof Derek Bunn, Leigh Fisher and Jacobs and EPRI.
The heat is on
Alongside the draft budget notice, BEIS has published two documents about CfD support for particular technologies.
One of these is a consultation that returns to the long-unanswered question of what to do about onshore wind on Scottish islands: should it be regarded as just another species of onshore wind (and therefore not to receive subsidy, in line with post-2015 Government policy), or does it face higher costs to a degree that merits a special place in the CfD scheme, as was suggested by the 2010-2015 Government? It comes as no surprise that the Government favours the former view: another item to add to the list of points on which the UK and Scottish Governments do not see eye to eye.
The second document is a call for evidence on the currently CfD-eligible thermal renewable technologies of biomass or waste-fuelled technologies (including biomass conversions), and geothermal. These raise a number of issues, on which the call for evidence takes no clear stance.
- Is continued support for the fuelled technologies in particular consistent with getting "value for money" by focusing subsidies on the cheapest ways of decarbonising the power supply (except onshore wind and solar), given that (with the exception of biomass conversions), they have a relatively high levelised cost of electricity generation?
- Can they be justified on the grounds that they are "despatchable" (and so do not impose the same burdens on the system as "variable" renewable generation like wind and solar)? Or on the grounds that (where they incorporate combined heat and power), they contribute to the decarbonisation of heat, as well as of power generation – an area in which more progress needs to be made soon in order to meet our overall target for reducing greenhouse gas emissions under the Climate Change Act 2008 (and the Paris CoP 21 Agreement)?
- Is the current relationship between the CfD and Renewable Heat Incentive support schemes the right one in this context? Is a CfD for a CHP plant unbankable because of the risk of losing the heat offtaker?
- Are all these technologies about to be overtaken as potential ways of decarbonising the heat sector on a large scale by other contenders such as hydrogen or heat pumps (and if so, is that a reason to abandon them as targets for CfD or other subsidy)?
- Should more existing coal-fired power stations be subsidised to convert to burning huge quantities of wood pellets (is that really "sustainable" – and would such subsidies comply with current EU state aid rules, for as long as they or something like them apply in the UK)?
Against this background, the draft budget notice proposes to limit advanced conversion technologies, anaerobic digestion and biomass with CHP to 150MW of support in the next CfD auction.
Kicking the coal habit
Finally, BEIS is consulting on the best way to "regulate the closure of unabated coal to provide greater market certainty for investors in the generation capacity that is to replace coal stations as they close, such as new gas stations". The consultation needs to be read alongside BEIS's latest Fossil Fuel Price Projections (with supporting analysis by Wood Mackenzie). These set out low, central and high case estimates of coal, oil and gas prices going forward to 2040. BEIS has significantly reduced its estimates for all three fuels under all three cases as compared with those in its 2015 Projections.
We are talking here about eight generating stations, which between them can produce 13.9GW. Their share of GB electricity supply tends to fluctuate with the relative prices of coal and gas. Most are over 40 years old. All can only survive by taking steps to comply with the limits on SOx, NOx and dust prescribed by the EU Industrial Emissions Directive – at least for as long as the UK is within the EU.
The Government's difficulty is how to ensure that these plants close (for decarbonisation purposes), but on a timescale and in circumstances that ensure that the contribution that they make to security of electricity supply is replaced without a gap by e.g. new gas-fired plant, of which so little has recently been built. BEIS evidently hopes that by the time this consultation finishes on 1 February 2017, the results of next month's four-year ahead Capacity Market auction will have seen a significant amount of new large-scale gas fired power projects being awarded capacity agreements at prices that make them viable (when taken together with expectations of lower-for-longer gas prices).
Although BEIS professes confidence in the changes that it has made to the rules and market parameters for the next Capacity Market auctions, one cannot help but wonder how convinced Ministers are that the 2016 auctions will succeed in this respect where those of 2014 and 2015 failed. Because from one point of view, if the Capacity Market does result in new large gas-fired projects with capacity agreements, and gas prices remain low, the market should simply replace the existing coal-fired plants – which, as the consultation points out, aren't even as flexible as modern gas-fired plant. Maybe if a newly inaugurated President Trump pushes ahead with his plans to revive the use of coal in the US, higher coal prices will help accelerate the closure of some of our remaining coal-fired plants: BEIS calculates that with relatively low coal prices and no Government intervention, they could run until 2030 or beyond.
So how will Government make the plants close? Two options are proposed. One would be to require them to retrofit carbon capture and storage (CCS), the other would be to require them to comply with the emissions performance standard (EPS) that was set in the Energy Act 2013 for new fossil-fuelled plant with a view to ensuring that no new coal plant was commissioned. Neither path is entirely straightforward. As it seems unlikely that operators would invest the kinds of sums associated with CCS on such old plant, there must be a risk that in trying to make CCS a genuine alternative to complete closure, regulations could end up allowing operators to run a significant amount of capacity without CCS whilst taking only limited action to develop CCS capacity. With the EPS approach, there would be some tricky questions to resolve around biomass co-firing, as well as biomass conversion, if that were to remain an eligible CfD technology and budget were to be allocated to it.
When it comes to consider how to ensure that coal closure does not involve a "cliff-edge" effect, the consultation seems to run out of steam a bit: having mentioned the possibility of limiting running hours or emissions, either on a per plant basis or across the whole sector, BEIS says simply that it would "welcome any views on whether a constraint [on coal generation prior to closure] would be beneficial and, if so, any ideas on the possible profile and design".
Nothing stands still. The period of these consultations / calls for evidence, and the next Capacity Market auctions, overlaps with other processes. Over the next few months, the Government is scheduled to produce over-arching plans or strategies in a number of areas that overlap with some of the questions posed in these documents. It will also continue to develop its strategy for Brexit negotiations with the EU; and the European Commission will publish more of its proposals on Energy Union (including new rules on renewables, market operation and national climate and energy plans).
The documents state more than once that while the UK is an EU Member State, it will "continue to negotiate, implement and apply" EU legislation. But – at least in relation to coal closure – the Government is trying to make policy here for the 2020s. By that time, it presumably hopes, it will no longer be constrained by EU law. It remains to be seen how Brexit will affect the participation of our remaining coal-fired plants in the EU Emissions Trading System, which is at present a significant feature of the economics of such plant. In the short term, the coal consultation points to an announcement in the Chancellor's 2016 Autumn Statement (23 November) of the "future trajectory beyond 2021" of the UK's own "carbon tax", the carbon price support rate of the climate change levy.
After a period in which we have been relatively starved of substantive energy policy announcements, things are starting to move quite fast, and decisions taken by Government over the next few months could have significant medium-to-long-term consequences for UK energy and climate change policy.
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