DECC Response ROC Bandings Jan 2012

Response ID ANON-1UBF-K8ME-3
Submitted on 2012-01-03 12:22:27.981655
Name
Name:Peter Jones
Email Address
Email:ecolateraljones@btinternet.com
Contact Address
Contact Address:Ivy HouseNorth Kilworth,LeicsLE17 6HG
Contact Telephone
Contact Telephone:01858880262
Organisation Name
Organisation Name:Ecolateral Ltd.
Organisation Type
Organisation type:Private Company
Other, specify:
Would you like this response to remain confidential?
No
Reason for confidentiality:
Q1. Do you agree with the Arup assessment of costs and deployment potential for onshore wind? Please explain your
response with evidence.
Agree
Please provide your comments:Greater specificity on the cost per Mw/Year to distinguish whether this is theoretical (design) output or probable delivered
values based on availability factor (of 30%??) would be helpful.
Q1. File upload:Not Answered
Q2. Do you agree with the proposed level of support of 0.9 ROCs/MWh for onshore wind? Please explain your response
with evidence.
Disagree
Please provide your comments:I disagree with the fundamentals of your approach insofar as you have funded the Arup and other research in the expectation
that subsidies (ROCs and FITs et al) are necessary to close the gap between fossil based investment and higher cost renewables. I find this approach baffling
and almost certain to be based on over estimates from suppliers to create artificially high returns in the early stages, however good the analysis.In fact your
analysis paralysis with attendant assumptions around economies of scale and elasticity of supply is fraught with predictive risks of the first order.Instead of
creating an Alice in Wonderland system you should instead have championed an inbound Energy Tax at a flat rate per Gigajoule/Btu or similar regardless of fuel
feedstock type but based on standard data from sound science.The energetic conversion technology should then be taxed on the basis of carbon dioxide
emissions ( not footprint) regardless of technology type.This simple and understandable construct is transparent and simple compared to the highly complex and
theoretical construct you propose to unleash.The latter will scare investment funders, represent labyrynthine complexity and liable to the creation of distortions
due to theoretical assumptions rather than sound science. The former system is simple, comprehensible and equitable.
Q2. File Upload:Not Answered
Q3. Do you agree with the Arup assessment of costs and deployment potential for offshore wind? Please explain your
response with evidence.
Disagree
Please provide your comments:As per Q2. The only certainty with this level of complexity is that it will be wrong when tested after implementation.
Q4. File Upload:Not Answered
Q4. Do you agree with the proposed level of support of 2 ROCs/MWh for offshore wind, stepping down to 1.9 ROCs in
2015/16 and 1.8 ROCs in 2016/17?. Please explain your response with evidence.
Disagree
Please provide your comments:See Q2- the entire approach is misguided.
Q4. File Upload:Not Answered
Q5. Do you agree with the Arup assessment of costs and deployment potential for hydro-electricity? Please explain your
response with evidence.
Disagree
Please provide your comments:As Q2
Q5. File upload:Not Answered
Q6. Do you agree with the proposed level of support of 0.5 ROCs/MWh for hydro-electricity? Please explain your response
with evidence.
Disagree
Please provide your comments:As Q2
Q6. File upload:Not Answered
Q7. Do you agree with the analysis on wave and tidal stream by Arup (2011) and their primary source Ernst & Young
(2010)? Please explain your response with evidence.
Disagree
Please provide your comments:As Q2- in the case of tidal the technology could be accelerated if it were classed as tax free in terms of fuel input and CO2
emissions. The accelerants for investment are thus created on competitive cost advantages against carbon based feedstock users.
File Upload:Not Answered
Q8. Do you agree with the proposed level of support of 5 ROCs/MWh for each project up to a limit of 30MW for wave and
tidal stream (and 2 ROCs/MWh above that limit)? Please explain your response with evidence.
Disagree
Please provide your comments:Cost advantage should be the driver, not maximised subsidies. The entire model is “back to front”.
Q8. File upload:Not Answered
Q9. Do you agree that 30MW is an appropriate level for the project cap? Please explain your response with evidence.
Agree
Please provide your comments:Why operate these ficticious caps other than to limit exposure to high subsidy outflows ? Input Gigajoule taxes coupled to
process carbon dioxide emissions taxes are simple and the market is left to decide scale on operational efficiencies specific to the technology rather than arbitrary
cut offs defined by the size of a Treasure allocated pot.
Q9. File Upload:Not Answered
Q10. Do you agree that the proposed level of support will help to drive deployment for the pre-commercial and early
commercial deployment phases? Please explain your response with evidence.
Agree
Please provide your comments:Reference to the EUTs framework and other Traded Pollution regimes in the CO2 intensive sectors has always demonstrated
that those offering data consistently over-egg their costs or other assumptions so that their returns in the early stages are higher. This scheme is unlikely to prove
the exception.
Q10. File upload:Not Answered
Q11. Do you agree with the analysis on tidal range by Arup (2011) and their primary source Ernst & Young (2010)? Please
explain your response with evidence.
Not Answered
Please provide your comments:No experience in this area.
Q11. File upload:Not Answered
Q12. Do you agree with the proposed level of support of 2 ROCs/MWh for tidal range, stepping down to 1.9 ROCs in
2015/16 and 1.8 ROCs in 2016/17? Please explain your response with evidence.
Disagree
Please provide your comments:As per the tenor of prior comments. These numbers have no scientific basis of connection or relevance to the need to reduce
carbon dioxide emissions from whatever source or type of fuel – they are an arbitrary construct.
Q12. File upload:Not Answered
Q13. Do you agree with the Arup assessment of costs and deployment potential for geothermal and geopressure? Please
explain your response with evidence.
Disagree
Please provide your comments:As per prior comments
Q13. File upload:Not Answered
Q14. Do you agree with the proposed level of support of 2 ROCs/MWh for geothermal, stepping down to 1.9 ROCs in
2015/16 and 1.8 ROCs in 2016/17? Please explain your response with evidence.
Disagree
Please provide your comments:As per prior comments
Q14. File upload:Not Answered
Q15. Do you agree with the proposed level of support of 1 ROC/MWh for geopressure? Please explain your response with
evidence.
Disagree
Please provide your comments:An entirely arbitrary construct .
Q15. File upload:Not Answered
Q16. Do you agree with the Arup assessment of costs and deployment potential for solar PV? We would particularly
welcome UK-specific evidence on costs and deployment potential.
Disagree
Please provide your comments:As prior comments
Q16. File upload:Not Answered
Q17. Do you agree with the proposed level of support of 2 ROCs/MWh for solar PV, stepping down to 1.9 ROCs in 2015/16
and 1.8 ROCs in 2016/17? Please explain your response with evidence.
Disagree
Please provide your comments:As per prior comments
Q17. File upload:Not Answered
Q18. Do you agree that we should not exempt existing generators from future changes to the UK’s sustainability criteria
for solid and gaseous biomass? Please explain your response with evidence.
Agree
Please provide your comments:Exemptions always create market distortions and should be avoided.
Q18. File upload:Not Answered
Q19. Do you consider that the 90% biomass purity threshold is still appropriate? Please explain your response with
evidence.
Disagree
Please provide your comments:Although the technology of mass spectrometry systems has radically improved to permit on line evaluation of exhaust gas
analysis I suggest that the differentiation of fossil and renewable based carbon dioxide is an entirely eroneous route we seem to have unwittingly been following.If
1 MwhE from biomass emits more CO2 than from coal then something is wrong in the system. Levels of Global Warming Gas emissions should be the absolute
decider. The 90% purity threshold is thus a meaningless chimera with no foundation in sound science.
Q19. File upload:Not Answered
Q20. Do you agree with the Arup assessment of costs and deployment potential for biomass conversion? Please explain
your response with evidence.
Agree
Please provide your comments:From my experience in the Waste sector their feedback seems to resonate with practical examples already operational.
Q20. File
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-18.5463468949-Q21. Do you agree that 1 ROC/MWh is an appropriate level of support for biomass conversions? Please explain your
response with evidence.
Disagree
Please provide your comments:As per Q2 and other responses.
Q21. File upload:Not Answered
Q22. Do you agree with our proposal for what should constitute a former fossil fuel generating station? Please explain
your response with evidence.
Agree
Please provide your comments:
Q22. File upload:Not Answered
Q23. Do you agree that all former fossil fuel generating stations which convert their entire generation to biomass before
April 2013 should be transferred to the biomass conversion band? Please explain your response with evidence.
Agree
Please provide your comments:
Q23. File upload:Not Answered
Q24. Do you agree that support under the biomass conversion band should be grandfathered at the rate set from 1st April
2013? Please explain your response with evidence.
Agree
Please provide your comments:
Q24. File upload:Not Answered
Q25. We would welcome evidence on the differential in generation costs, the costs of making biomass conversion
economically viable for industrial auto-generators, and deployment potential for auto-generating coal to biomass
conversion.
Please provide your comments:Not qualified to respond.
Q25. File upload:Not Answered
Q26. Do you agree with the Arup assessment of costs for enhanced co-firing? Please explain your response with
evidence.
Not Answered
Please provide your comments:Not qualified to respond
Q26. File upload:Not Answered
Q27. Do you agree that 1 ROC/MWh is an appropriate level of support for enhanced co-firing? Please explain your
response with evidence.
Not Answered
Please provide your comments:Not qualified to respond
Q27. File upload:Not Answered
Q28. Do you agree that generating stations should generate at least 15% of their electricity from biomass in order to
qualify for the enhanced co-firing band? Please explain your response with evidence.
Disagree
Please provide your comments:These break points are entirely artificial and represent a potential bureaucratic paradise for complex regulation and or
monitoring oncosts.
Q28. File upload:Not Answered
Q29. Do you agree that generators should meet this minimum 15% threshold on a monthly averaged basis? Please
explain your response with evidence.
Disagree
Please provide your comments:As Q28.
Q29. File upload:Not Answered
Q30. Do you agree that support under the enhanced co-firing band should be grandfathered? Please explain your
response with evidence.
Agree
Please provide your comments:Grandfathering has been proven to support a de-risking approach.
Q30. File upload:Not Answered
Q31. Do you agree with the Arup assessment of costs and generating potential for standard co-firing of biomass? Please
explain your response with evidence.
Not Answered
Please provide your comments:Not qualified
Q31. File upload:Not Answered
Q32. Do you agree with the proposed level of support of 0.5 ROCs/MWh for standard co-firing of biomass? Please explain
your response with evidence.
Disagree
Please provide your comments:As per above-another arbitrary construct which overcomplicates the issue compared to input taxes on gigajoule ratings and
CO2 emissions.
Q32. File upload:Not Answered
Q33. Do you agree that standard co-firing of biomass should continue not to be grandfathered? Please explain your
response with evidence.
Not Answered
Please provide your comments:No comment
Q33. File upload:Not Answered
Q34. Do you agree with the Arup assessment of costs and deployment potential for dedicated biomass? Please explain
your response with evidence.
Not Answered
Please provide your comments:No comment
Q34. File upload:Not Answered
Q35. Do you agree with the biomass fuel price assumptions for domestic and imported fuel from AEA, and the use of a
10:90 domestic to imported ratio for average fuel costs for large (>50MW) dedicated biomass and 90:10 for small (<50MW)
dedicated biomass based on the Arup report? Please explain your response with evidence.
Disagree
Please provide your comments:It is dangerous to construct a strategy on a current snapshot when there are so many variables impacting on rates of exchange,
biomass yields, food demand, global climate chaos and other factors over the time horizons envisioned.
Q35. FIle upload:Not Answered
Q36. Do you agree with the proposed level of support of 1.5 ROCs/MWh for dedicated biomass until 31 March 2016,
reducing to 1.4 ROCs/MWh from 1 April 2016? Please explain your response with evidence.
Disagree
Please provide your comments:As per Q2
Q36. File upload:Not Answered
Q37. Do you agree that the support level proposed for dedicated biomass manages the risk of locking supplies of
feedstock in to this sector? Please explain your response with evidence.
Disagree
Please provide your comments:Any economist would explain to an Engineer how the vicissitudes of the Markets and the wide variety of exit options for
biomass over the next decade will make the probability of certainty laughable.
Q37. File upload:Not Answered
Q38. Do you agree with the Arup assessment of generation costs and deployment potential of bioliquids, and the
bioliquid fuel prices as set out in the Impact Assessment? Please explain your response with evidence.
Not Answered
Please provide your comments:No comment
Q38. File Upload:Not Answered
Q39. Do you agree that support for bioliquids should be the same as for solid and gaseous biomass under the dedicated
biomass, biomass conversion, enhanced co-firing and standard co-firing bands? Please explain your response with
evidence.
Disagree
Please provide your comments:Your assumptions in relation to future shifts in cost/revenue patterns over decade long cycles are breathtakingly naieve but I
hope your gamble pays off.
Q39. File upload:Not Answered
Q40. Do you agree that ‘fossil-derived bioliquids’ should receive the same level of support as other bioliquids? Please
explain your response with evidence.
Agree
Please provide your comments:As per Q2
Q40. File upload:Not Answered
Q41. Do you agree that a cap should be put in place on the amount of electricity generated from bioliquid that suppliers
can use to meet their renewables obligation? Please explain your response with evidence.
Disagree
Please provide your comments:Caps are nothing to do with market mechanisms.They are a false construct which will distort rather than enhance the market
mechanisms.
Q41. File upload:Not Answered
Q42. Do you agree with the level of the cap being set at 4% of each supplier’s renewables obligation, broadly equivalent to
a maximum level of generation of 2TWh in 2017? Please explain your response with evidence.
Disagree
Please provide your comments:As per Q41
Q42. File upload:Not Answered
Q43. Do you agree that from 1 April 2013, bioliquids should be treated in the same way as solid and gaseous biomass for
the purposes of our grandfathering policy? Please explain your response with evidence.
Agree
Please provide your comments:Consistency of application is essential.
Q43. File upload:Not Answered
Q44. Do you agree with the Arup analysis on costs and potential on EfW with CHP, including the estimates of gate fees
used? Please explain your response with evidence.
Disagree
Please provide your comments:My issue with the Arup analysis centres on possible forward trends in gatefees. A clear divergence is appearing in the market
place between long term contracted local Authority streams and commercially negotited gate fee structures.The former tend to operate at the £85-£110 range
depending on when PFI contracts were signed.Many are subject to onerous price indexation,particularly if the current policy of fiscal easing results in inflationary
pressures on RPI.They were signed against a backdrop of large ,single solution non CHP mass burn with electrical recovery only.The reality in the market is that
as more process facilities open there will be an expanding demand for waste feedstock. Upward shifts in the price of oil, producer responsibility ,innovation in the
reuse of recyclate ,higher prices for high carbon embedded metals in electronics goods are but a few of the factors driving gate fees for waste down toward zero
or negative values in the next decade . Those with i) high energetic conversion efficiency, ii) conversion to outputs with the highest value per gigajoule (whether
as electricity, heat, transport fuels, gas or output products made from recyclate) and iii) low overall process carbon footprints will outcompete those with poorer
parameters for the available feedstocks . This will wreak havoc on any carefully constructed feedin tariff regime based on perspectives created from past
,backward looking observed experience with soon to be obsolescent process capacity.
Q44. File upload
:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.2635750869-filesubquestion&Q45. Do you agree that 0.5 ROCS is an appropriate support level for EfW with CHP? Please explain your response with
evidence. We would particularly welcome evidence relating to levels of gate fees received by generators and additional
capital costs relating to heat offtake.
Disagree
Please provide your comments:Such estimates can only be informed guesswork. Smaller co-located CHP facilities sized at around the 1-2 MwE loading of
large retail users (such as docks,airports,food process centres, prisons ,sewerage works,transport hubs etc ) will have far greater attraction to investors
regardless of the technology employed.They will out compete low efficiency large scale plant dependent on wholesale market sale of product because they will
offer supply certainty, higher efficiency and low or negligible distribution losses. ROC banding based on a technology rather than market driven colocation for
security and low exposure to CRC liabilities will carry far greater weight.To observe the effect on gatefees of shifting supply-demand ratios simply anaalyse the
timber market in 2010/11. To understand the attractions of colocations analyse what supermarkets are doing in relation to co-located anaerobic digestion.The
latter was originally promulgated by Biffa luncheons to the food supply chain in 2004 as well as the BERR/DEFRA supported Distributed energy reports to the UK
Government’s Business Taskforce on Sustainable Consumption and Production in March 2008.
Q45. File
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.3965778425-Q46. In addition to municipal solid waste, do you consider that there are any other types of wastes which could benefit
from provisions deeming their biomass content or benefit from more flexible fuel measurement and sampling
procedures? If so, please specify and provide evidence on how we might determine accurately the renewable content of
these wastes.
Please provide your comments:The Resources KTN,University of Birmingham, University of Oxford, C- Tech and others have access to technology suppliers
for emissions analysis of short cycle carbon. However the point is not to distinguish short cycle from fossil feedstock CO2 since a tonne of the former is as bad as
a tonne of the latter if the absolute limits of impact are reached or the global capacity for biomass growth is at capacity or declining.There is twice as much
biomass tonnage in commercial and industrial streams and far more again ploughed in to fields or lost in the UK food growing cycle. Evidence for those flows was
gathered as part of the Biffaward mass balance programme from 1998 and the suite of relevant reports ( which are still largely relevant) can be found at
www.massbalance.org .The concept of “renewable” CO2 is a chimera and you should be directing your thinking to fiscal instruments directed at low CO2
emission incentives from all energy generation technologies regardless of feedstock.
Q46. File upload:Not Answered
Q47. Do you agree with the Arup analysis on costs and potential on AD and AD with CHP, including the estimates of gate
fees used? Please explain your response with evidence.
Agree
Please provide your comments:They appear to conform to a growing body of evidence based operational experience.
Q47. File upload:Not Answered
Q48. Do you agree with the proposed level of 2 ROCs/MWh for Anaerobic Digestion , stepping down to 1.9 ROCs in
2015/16 and 1.8 ROCs in 2016/17? Please explain your response with evidence.
Agree
Please provide your comments:Subject to the Q2 response-we are starting from an entirely insecure set of assumptions based on an excess of complexity.
Q48. FIle upload:Not Answered
Q49. Do you agree with the proposal to replace the standard and advanced pyrolysis and gasification bands with two new
ACT bands? Please explain your response with evidence.
Agree
Please provide your comments:If you are going to adopt a technology centric reward framework then you have to allow for interesting innovation in these
areas.
Q49. File upload:Not Answered
Q50. Do you agree with the eligibility criteria for the new standard ACT and advanced ACT bands? Please explain your
response with evidence.
Disagree
Please provide your comments:The weakness of your approach in terms of creating a future incentive framework based on past technology frameworks is
amply demonstrated in relation to ACTs.You seem to have fallen into a trap of thinking that all forms of syngas have to be handled by thermo mechanical means
in the form of i) combustion and ii) an internal combustion engine as the “ultimate” CHP conversion route.Who advised you as engineers?Why do you regard the
IC engine as the only means of energy exit? What about gas recovery? Distillation? Hydrogen? Pressure swing absorbtion systems? Gas purification and
fractionation? Hydrolysis of carbon monoxide?I agree that these options may sound like something from Jules Verne but the harsh lesson of the last decades is
that engineering and chemistry will transform the energy space yet you seem keen to accelerate that innovation by creating almost 30 sets of economic
instruments which with hindsight will be seen as the equivalent of supporting the continuation of the stagecoach in the 1840’s.You are surely aware of work
involving routes to hydrogen from waste carbon biomass and other materials (packaging,fabrics,food,crop residues,clothing,furniture etc) with storage in wet fuel
cells. Your definition of advanced band classifications should be set at parameters achieved by CHP IC Engines as a guideline and should not exclude other
routes by their omission simply because they have yet to be discovered or improved otherwise you will ossify and preset the technology rather than stimulate
innovation.
Q50. File
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.8486450726-
Q51. Do you agree with the proposed levels of support for the new standard ACT and advanced ACT bands? Please
provide evidence on the relevant technology capital and operating costs (including levels of gate fees) to support your
comments).
Agree
Please provide your comments:If you adhere to your techno-centric support framework this recommendation is probably as good as it gets but I refer you to the
response to Q2.
Q51. File upload:Not Answered
Q52. We would welcome evidence on the generation costs, deployment potential and gates fees for the ACT technologies
faling within the two new ACT bands proposed above.
Please provide your comments:At this stage this data will not be absolutely realistic until the first production plant goes online in 2014
Q52. File upload:Not Answered
Q53. We would welcome information on the nature and scale of actual or potential air emissions produced in the
generation of electricity from pyrolysis oil.
Please provide your comments:No experience other than knowledge that these high sulphur corrosive streams are generally a source of economic destruction
for those who think low temperature pyrolysis will ever work.
Q53. File upload:Not Answered
Q54. Do you agree with the Arup assessment of generation costs and deployment potential of landfill gas, and the gate
fee assumption of zero? Please explain your response with evidence.
Agree
Please provide your comments:Analysis of input streams to landfill from my time as an operational Director in the sector suggests that Arup analysis of yield
collapses is spot on. Attempts to offload these landfill assets by the sector operators onto unsuspecting buyers with evidence quoting historic yields are unlikely to
prove successful.
Q54. FIle
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.3699380897-Q55. Do you agree that RO support for new landfill gas generation should end from 1 April 2013? Please explain your
response with evidence.
Not Answered
Please provide your comments:No view but landfill is de facto a dead end in 2012.Clear evidence that fiscal instruments applied to drive economic behaviour
are by far a more effective route. If the current approach to feed in tariffs on energy (to shift toward renewable energy) had been offered to the conventional
Waste industry in 1997 (to shift from landfill to other technologies) it would have been met with derision so why is it considered so attractive in the energy
sector?Just tax embedded energy inputs and the CO2 emissions outputs regardless of feedstock and let the market do the rest as Landfill Tax and recyclate
prices did for the waste industry from 1997 to 2007.
Q55. File
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.5145841068-Q56. We would welcome evidence on new technologies that can increase the technical potential of landfill gas in the UK,
particularly from older landfill sites. Information on the costs, potential and viability of new technologies would be
particularly valuable.
Please provide your comments:Your definition of “older” would be helpful.Most cells created from the pre ROC days were capped efficiently -from 1998 in my
experience.This enabled maximisation of gas yields and cashflows.Certainly a combination of economics and Regulatory pressures from 2000 made efficient
landfill gas management a no brainer. Typical large sites of 10 million metre cube void with 0.4 million per annum inputs operated with planned lives of 20 years
and the majority of the remaining sites in the UK commenced fill operations in the heady early 1990’s and are thus past their prime and now suffering substantial
drops in biomass inputs .No major operators ( except foreign owned new entrants ) invested in new void once the £8 escalator was announce in 2003-4 so it is
difficult to understand how there is any economic case for accessing methane flows from the badly run pre 1990 sites (often municipally run) where most of the
gas has vented. A leachate strategy might be more helpful in terms of biodiversity risks.
Q56. File upload:Not Answered
Q57. Do you agree with the Arup assessment of generation costs and deployment potential for sewage gas, and the zero
gate fee used in the analysis? Please explain your response with evidence.
Disagree
Please provide your comments:No experience but see comments below.
Q57. File
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.2216672955-Q58. Do you agree that 0.5 ROCs/MWh is an appropriate level of support for electricity generated from sewage gas?
Please explain your response with evidence.
Disagree
Please provide your comments:I refer you to the final report from the OFT in relation to the OFWAT Referral in relation to the acceptance of biomass from
commercial and industrial streams .My position is that sewerage works,with their access to high voltage transmission lines and gas to grid networks,should be
removed from the Regulated water sector and placed in the waste sector.Moreover ,because of their immense potential as efficient,large scale sites for integrated
resource recovery parks,they should be auctioned off to the highest bidders for development as such by water,waste, electricity,gas,property or other interested
parties.Failure to sieze this one off opportunity will leave the UK with a legacy of dispersed, inefficient,high logistics cost waste resource processing infrastructure
in coming decades.There is also an opportunity for a one off windfall tax from the proceeds which could offset a substantial proportion of the first 2 year funding
cost of the Green Investment Bank.
Q58. File
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.3967381015-Q59. We would welcome evidence on new technologies that can increase the technical potential from sewage gas in the
UK. We are also interested in whether there is potential cogeneration. Information on the costs, potential and viability of
new technologies would be particularly valuable.
Please provide your comments:I refer you to the Report, now under the management of WRAP, into the opportunities for Gas to Grid.This was produced by a
cross interest group of waste, water, electrial,gas,property and other companies comprising senior managers and included local Authorities and NGOs under the
aegis of AWM West Midlands.It is posted on the WRAP website.
Q59. File
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.5709243512-Q60. Do you agree with the Arup assessment of generation costs and deployment potentials for CHP technologies, and
with the fuel prices used in the analysis? Please explain your response with evidence.
Agree
Please provide your comments:
Q60. File upload:Not Answered
Q61. Do you agree that 2 ROCs/MWh is an appropriate level of support for dedicated biomass with CHP? Please explain
your response with evidence.
Disagree
Please provide your comments:Refer to Q2
Q61. File upload:Not Answered
Q62. Do you agree that 2 ROCs/MWh is an appropriate level of support for dedicated energy crops with CHP? Please
explain your response with evidence.
Disagree
Please provide your comments:Refer to Q2.Also your predictions of support mechanisms for energy crops will stand negated by innovation in bio
technology,inorganic nitrogen energy costs, phosphate availability and rising populations with a prediction for meat.Try to think out of a box.
Q62. File upload:Not Answered
Q63. Do you agree that 1 ROC/MWh is an appropriate level of support for standard co-firing of biomass with CHP? Please
explain your response with evidence.
Disagree
Please provide your comments:As Q62
Q63. File upload:Not Answered
Q64. Do you agree in principle that 1.5 ROCs/MWh is an appropriate level of support for standard co-firing of energy
crops with CHP? It would be helpful if you could provide evidence on costs and deployment potential to inform our
decision.
Disagree
Please provide your comments:As Q62
Q64. File upload:Not Answered
Q65. Do you agree with the arrangements for transition from the CHP uplift to RHI support as set out in this chapter (i.e.
no RHI for projects accrediting under the RO; one-off choice between RHI and CHP uplift for projects accrediting between
April 2013 and March 2015; no CHP uplift for projects accrediting after that date, unless the RHI is unavailable for that
technology on 1 April 2015)? Please explain your response with evidence.
Not Answered
Please provide your comments:No comment.
Q65. File upload:Not Answered
Q66. Do you agree that we should adopt a policy of grandfathering the CHP uplift for eligible projects from 1 April 2013?
Please explain your response with evidence.
Not Answered
Please provide your comments:No comment
Q66. File upload:Not Answered
Q67. Do you agree in principle that we should consider extending the CHP uplift to the new biomass conversion and
enhanced co-firing bands until 31 March 2015? It would be helpful if you could provide evidence on costs and deployment
potential to inform our decision.
Not Answered
Please provide your comments:No comment
Q67. File upload:Not Answered
Q68. Do you consider it would be appropriate to introduce a CHP uplift into the RO for ACTs? If so, please provide
evidence on capital and operating costs of plant operating in CHP mode, together with likely deployment potential
between now and 2020 and, if possible, 2030?
Not Answered
Please provide your comments:No comment
Q68. File upload:Not Answered
Q69. Do you agree that we should narrow the definition of energy crops to limit its scope to only the short rotation
coppice and perennial grass species as described above? Please explain your response with evidence.
Disagree
Please provide your comments:All CO2 has the same chemical properties regardless of feedstock of route to manufacture. This obsession with renewable
sources is entirely erroneous in my view and has set us on a course of thinking that there is such a thing as “good” carbon dioxide because it is emitted from the
energetic conversion of short cycle crops. If the planet is now agreed to be at a tipping point any CO2 contribution is a risk regardless of how the energy was
derived-fossil or otherwise.
Q69. File upload:Not Answered
Q70. Do you agree that we should grandfather the energy crop uplift from 1 April 2013, but only for those crops meeting
the new definition? Please explain your response with evidence.
Not Answered
Please provide your comments:No comment
Q70. File upload:Not Answered
Q71. Do you agree with the proposed level of 2 ROCs/MWh for dedicated energy crops, stepping down to 1.9 ROCs in
2015/16 and 1.8 ROCs in 2016/17? Please explain your response with evidence.
Disagree
Please provide your comments:Q2 response
Q71. File upload:Not Answered
Q72. Do you agree with the proposed level of 1 ROC/MWh for standard co-firing of energy crops? Please provide evidence
on costs and deployment potential.
Disagree
Please provide your comments:Q70 response
Q72. File upload:Not Answered
Q73. Do you consider that we should extend the energy crop uplift to the new biomass conversion and enhanced co-firing
bands? It would be helpful if you could provide evidence on costs and deployment potential to inform our decision.
Disagree
Please provide your comments:Q70 response.Why are you introducing market distortions which further skew the food and crops pricing infrastructures at a
time of emergent food shortages and a shift from grain to meat?
Q73. File upload:Not Answered
Q74. Do you agree that the co-firing cap should be removed completely from 1 April 2013? Please explain your response
with evidence.
Not Answered
Please provide your comments:No view
Q74. File upload:Not Answered
Q75. If you think that the cap should be increased (i.e. to allow more co-firing) or restricted to standard co-firing of
biomass, please state what an appropriate level for the cap would be and why? Please support your response with
evidence.
Please provide your comments:Q70 response applies. This is a bureaucratic framework worthy of Alice in Wonderland.
Q75. File upload:Not Answered
Q76. Do you agree with our proposals for a time-limited and strictly defined grace period as described above, including
scope, time limit and criteria? If you wish to suggest a different scope, time limit or criteria, please explain why. Please
support your response with evidence.
Not Answered
Please provide your comments:No comment
Q76. File upload:Not Answered
Q77. Do you agree with the proposed level of support of 2 ROCs/MWh for those microgeneration technologies eligible for
support under the RO, stepping down to 1.9 ROCs in 2015/16 and 1.8 ROCs in 2016/17? Please explain your response with
evidence.
Disagree
Please provide your comments:Technology specific incentives are bad enough in skewing the market.If you further differentiate according to scale based on
arbitrary boundary points you will end up with entirely artificial profiles of supply based on negative GDP support subsidies rather than investments which reflect
engineering realities of efficiency and scale.
Q77. File upload:Not Answered
Q78. In addition to the specific questions asked throughout this consultation document, do you have any other comments
on any aspect of our proposals? In each case, please explain your response with evidence.
Please provide your comments:It hardly seems necessary to reinforce my points but you are starting on a false premise, travelling with the use of entirely
arbitrary break points ( in terms of times and scales) and it will be unsurprising when the UK arrives at 2020 with a mirror image of the artificial and complex
construct you are embarking on.A simple energy tax coupled to a CO2 emissions tax validated by sound science and peer review regardless of fuel type or
technology is all that is needed to drive the market. Your arbitrary hypothetetical guesstimates based on admittedly properly researched data from a fledgling
sector are loaded with risk, are in danger of creating further risk aversion due to their very complexity and conveniently ignore the potential for transformative
scientific innovation of which you have taken no account .Apart from that everything is fine.
Q78. File
upload:https://econsultation.decc.gov.uk/office-for-renewable-energy-deployment-ored/ro-banding-rev/consultation/download_file?squid=question.2011-10-19.1425071975

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