On 21 October 2011, the Scottish Government published the Consultation on the Renewables Obligation Scotland (ROS) Banding Review. The consultation sets out the proposed levels of support for generating stations from 2013-17 under the ROS. The consultation demonstrates the Scottish Government's ongoing support of certain renewable energy technologies and its commitment to the ambitious Scottish renewable electricity generation target of 100% by 2020. Whilst it has shown support to onshore and offshore wind and marine technologies and broadly follows the proposals which were announced by the Department of Energy and Climate Change (DECC) for England and Wales yesterday, it greatly alters the landscape for the development of Biomass in Scotland. This is clearly a departure from the approach taken in England and Wales and will without doubt impact on the Government's plans as outlined in the Road Map and its targets for heat generation.
Please note the following key proposals:
Biomass: Scottish Government propose not to incentivise new large scale dedicated biomass and dedicated biomass with CHP but have followed the DECC proposal to provide two new bands to support Biomass conversion and Enhanced Co-Firing from 1 April 2013 Increased support for marine and tidal technology: The proposal is to offer support at 5 ROC/MWh for wave and tidal technologies. This can only be claimed by projects that are operational before 1 April 2017. Scotland's wave and tidal energy resource is almost unparalleled and with the increased support the Scottish Government remains convinced that Scotland can and should continue to lead the world in the development and deployment of marine renewable technologies. Unlike the DECC proposals, there is not a 30MW cap on marine-energy projects looking to benefit from the highest ROC banding.
- Cutbacks for onshore wind and offshore wind: Onshore wind is proposed to be reduced to 0.9 ROC/MWh from 1 ROC/MWh from 1 April 2013 and offshore wind is proposed to be reduced from 2 ROC/MWh to 1.9 ROC/MWh in 2015/16 and 1.8 ROC/MWh in 2016/17. This follows the proposals under the DECC consultation for England and Wales.
- Solar support reduced: The support of 2ROC/MWh to remain until 2014 thereafter it will be 1.9 ROC/MWh in 2015/16 and 1.8ROC/MWh in 2016/17.
- Reductions will also be made for hydro, advanced conversion technologies (pyrolysis and gasification), energy from waste, and landfill gas.
The main differences between the DECC proposals announced earlier last week and the Scottish proposals are in relation to the treatment of dedicated biomass and biomass with CHP. The DECC proposals provide for a continued support of dedicated biomass plants at 1.5 ROCS until 2014 then 1.4 ROCS from 2015. DECC has also proposed that Dedicated Biomass with CHP generating stations will continue to receive 2 ROC/MWh, with plans to close this band to new accreditations from 1 April 2015 and for such support to continue under the RHI.
However, Scotland has proposed a cap on the size of dedicated biomass plants receiving support. Smaller, more efficient facilities will be eligible for 1.5 ROC/MWh, with CHP stations getting 2 ROC/MWh until 2015 and then 1.9 ROC/MWh in 2015-16. Plants above a certain generation capacity will cease to get subsidies.A proposed level for the threshold is not stated in the document but they have commissioned research to provide evidence, in carbon terms, on the best use of biomass. There are similar plans to close the Dedicated Biomass with CHP band to new accreditations from 1 April 2015. The Scottish Government is also asking for views on the circumstances under which it may be appropriate to set a threshold for electricity only generation, and what that threshold should be.
Scottish Minister for Energy, Enterprise and Tourism Fergus Ewing notes that "The Renewables Obligation has been absolutely fundamental to the progress which we have made over the last decade in Scotland. And it will remain so as we strive to meet the challenging target which we have set for renewable electricity generation... We need to strike the appropriate balance between an outcome which is cost effective and does not impose an excessive burden upon consumers, while ensuring that the support is sufficient to develop and bring on those technologies, such as wave and tidal, where Scotland has a major competitive advantage."
The closing date for written responses to the consultation paper is January 13 2012. Following the closing date, all responses will be analysed and considered along with any other available evidence to help reach a final position on the proposals identified in the consultation. This will lead to the laying of an amended ROS before the Scottish Parliament next year, prior to the changes to the bands taking effect from 1 April 2013.
The proposals to cap the support of biomass under the ROS is damaging for the Scottish biomass industry. The proposals demonstrate a clear movement from not only the proposed support levels for biomass under the RO in England and Wales but also from the UK Renewable Energy Road Map's belief that biomass is 'one of the technologies that has the greatest potential to help the Government achieve it's 2020 target'.
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