Date: 27 November, 2018
The REA and WHA have responded to BEIS Consultation which proposes to ban biomass combustion in urban areas. Namely, we argue that the proposals will needlessly limit options for the decarbonisation of heat, especially in larger public and private sector buildings, whilst negatively affecting the Government’s ability to meet its decarbonisation targets. Instead, the REA and WHA recommend that the Government focus on raising emission standards, mandating maintenance checks for RHI-accredited systems alongside promoting and enforcing existing air quality regulations.
Date: 26 October, 2018
The REA believe that the EPC process should be changed to better reflect the beneifts from renewable energy and encourage uptake of measures among consumers.
Read our response below.
Date: 12 October, 2018
The Wood Heat Association (WHA) welcomes the Governments focus on addressing genuine air quality concerns arising from the domestic burning of solid Fuels and wood, however, believe proposals will only improve air quality if they focus on stronger enforcement of the existing rules and better public education, especially in urban areas.
Date: 4 October, 2018
The REA welcomes the Welsh Government’s proposals for setting low carbon pathways to 2030. In this response, the REA outline a wide range of possible strategies for lowering emissions in Wales across housing, transport, power and heat. We support a high proportion of renewable energy generation and decarbonisation of the transport sector because of the positive impacts this will have on jobs, investment and air quality in Wales. We also welcome the setting of interim carbon reduction targets before 2050 as an important step towards the longer term target, but note that these must be updated should the Committee on Climate Change’s interim targets also change between now and 2050.
Date: 20 September, 2018
The REA is pleased to see that the EA recognise the important role that the biowaste sector plays in supporting the health of the UK soils through the conversion of biodegradable materials into valuable soil improvers and biofertilisers. The REA recognises that much has been done to improve the performance of the sector in recent years through the promotion of best practice and also through training and education programmes. There is still, however, plenty of scope for improvement and these improvements need to be carried out by working with the regulators so that changes are both affordable to industry and pragmatic in their implementation.
We made our members aware of the call for evidence and ran a webinar outlining the proposals. The views and evidence expressed the response comes directly from REA members who are active in the biowaste sector.
Date: 17 September, 2018
The second part to the 2018 FiT scheme closure consultations. The REA is caling for garce periods, the re-use of unspent funds and allowing the replacement of engines and equipment for unavoidable operational reasons (without losing FiT accreditation).
Date: 16 September, 2018
Our response states
• We don’t feel it is necessary to require a protection grade whilst E10 is not available, but of the options put forward in the consultation we favour option 2
• We believe the number of main household vehicles that are not warrantied to run on E10 to be almost half that suggested by the DfT, representing less than 1% of the vehicle parc by 2020.
• Fuel will still be available for these vehicles
• Our ideal would be a straightforward mandate on all retailers to be implemented as soon as possible (an opinion shared by many relevant stakeholders)
• The Government’s proposal for requiring larger fuelling stations to offer E10 is a deeply sub-optimal way forward in comparison with a mandate. It would entail more investment from fuel retailers and distributors which would inevitably be passed through to final customers. A mandate, however, would result in £76 - 150 benefit which would filter down through the supply chain.
• The Government could compensate drivers of older unwarrantied main household vehicles through a reduced vehicle excise duty if it saw fit.
Date: 3 September, 2018
The Feed-in Tariff is proposed to come to an end on 31 March 2019, for new projects.
Government proposals (autumn 2018) are for the generation and export tariffs to both end at this time. The REA believe this would be fundamentally unfair for new small scale generation as the power they produce would not be compensated for, but could effectively be used on the system for nothing.
We are therefore calling for the rentention of the export tariff as a priority, with the current system (deemed export payments for projects below 30 kW in capacity) being kept in place for a limited time until new system settlement and metering arrangements are in place for such sites.
We are happy to discuss the proposals in this paper more with industry and media.
Our other recommendations are for the tax system to be used to promote renewables, via lower rates of VAT, business rates support, and EIS/ECA support.
Date: 14 August, 2018
The REA & WHA has responded to the Defra consultation on its Clean Air Strategy.
Date: 3 August, 2018
The REA has responded to DEFRA’s consultation concerning proposals for a new Environmental Bill which will legislate for maintaining key Environmental Principles and set up an independent governance body designed to keep Government to account once the UK leaves the EU.
The REA called for a number of essential EU and international environmental principles to be maintained, while also calling for Proportionality Principles to be included to ensure streamlined policy-making that does not constrain innovation.
The response also supported the development of the governance body, calling for it to be provided additional powers to be able to take Government to court. The response states that, while the new body must have a separate remit, it should also have a carefully defined relationship with the Committee on Climate Change to ensure it does not work in a silo. Finally, we also call for it to play a central role in scrutinising the delivery of the 25-Year Environment Plan, with this function being written into the Primary Legislation.
Date: 11 June, 2018
The REA and WHA have submitted their response to the Call for Evidence on "A future framework for heat in buildings". It is the key consultation on the future policy framework and will the grounds for the Government's low-carbon heat strategy.
Date: 8 May, 2018
The REA 's response to the Government consultation on the Future of Food, Farming and the Environment can be donwloaded below.
Date: 16 April, 2018
The DIT issued policy papers on “Stakeholder Engagement Trade Remedies Reviews" and “Stakeholder Engagement Reconsideration and Appeals of Trade Remedies Decisions.” The REA response is attached.
This builds upon the comments made by the Manufacturing Trade Remedies Alliance, which the REA is in the process of joining.
Date: 30 March, 2018
As the UK’s largest renewable energy trade body, the REA has the below positions on the EU trade remedy measures currently in place. In summary, for the reasons outlined in the response, we:
• SUPPORT the continuation of all the biodiesel and bioethanol related trade remedy measures currently in place
• DO NOT SUPPORT the continuation of the measures ‘Solar panels (AD) (IR) AD590’ and ‘Solar panels (AS) AS594’, currently in place
Date: 14 March, 2018
Find attached the REA response to the policy paper setting out proposals on how the Trade Remedies Authority (TRA) will govern the initiation and conduct of dumping or subsidisation investigations. The policy paper itself is attached.
The response notes that should the UK leave the customs union, trade associations will have to take a greater role in the processes of determining the fairness of trade, but that to date those REA members that have been impacted have looked to their memberships of EU representative bodies such as the European Biodiesel Board and e-PURE to safeguard their interests.
The response then asks for clarification on a couple of areas not covered in the paper, before going on to provide answers to the questions posed.
Date: 9 March, 2018
BEIS issued a consultation on tighter CHP efficiency requirements for CHP plants, new conditions for ACT plants, Biomass GHG criteria, and proposals to include 'Remote' wind projects (previously known as Scottish Island Onshore Wind) in Pot 2 of the auction.
Date: 28 February, 2018
The REA Submitted evidence to the EAC inquiry concerning 25-Year Environmental Plan
Date: 5 February, 2018
The REA's response to the Committee on Climate Change's Bioenergy Review (2018) - Call for Evidence.
Date: 30 January, 2018
Please read below the REA response to the EA Strategic Review of Charges Consultation. Contact Jeremy@r-e-a.net if you have any queries about the response.
Date: 26 January, 2018
We make general arguments on the following lines:
Our interest is in using the HGV levy to encourage the uptake of dedicated gas-fired HGVs, due
to their superior environmental performance (GHG, NOx, particulates and noise). These vehicles
are only just emerging on the market, and the pace of innovation is rapid.
Gas fired HGVs have a higher upfront capital cost than diesel equivalents. Therefore, any
additional support to encourage the switch to gas, such as a reduction in the HGV road user levy,
would assist uptake. This could take the form of a straight forward percentage reduction in the
levy for gas-fuelled vehicles.
Date: 12 January, 2018
"Congestion, Capacity, Carbon – priorities for national infrastructure" was launched in October 2017. the interim report examined seven key areas and set out the NIC's vision and priorities for helping meet the country’s needs up to 2050. Those seven areas are:
The REA response to the report can be downloaded below.
Date: 10 November, 2017
Please find the RTFG's response to the consultation on the draft guidance for the new RTFO (expected to come into effect mid April 2018).
Date: 31 October, 2017
See below our response to the recent RHI consultation on further amendments to the RHI
Date: 2 October, 2017
The REA sent a letter in response to the above consultation.
Many of the proposals are not directly relevant to the REA. However, our letter makes a call for the strategy to take account of the benefits of biomethane for transport and to consider the role liquid biofuels can play. It also makes the point that in the longer term over the rolling out of electric vehicles - there needs to be some differentiation between zero-emission battery electric vehicles and plug-in hybrids. The focus needs to be on how and when the latter are operated in zero emissions mode
The section on biomethane is largely drawn from the RTFG group’s report on Use of gaseous fuels in transport.
Date: 29 September, 2017
The REA responded by letter to Western Power Distribution's consultation on the transition to becoming a Distrubtion System Operator. The letter
Date: 27 September, 2017
Please find below the form REA submitted in response to November 2016's RTFO consultation.
Date: 8 August, 2017
Reforming and simplifying the Ancillary services market is a great opportunity to create a market for energy storage, DSR and flexible capacity providers, which is why we support National Grid's proposals to make the system less arcane, more open and transparent.
Date: 26 June, 2017
The REA response to the Defra consultation on the UK Air Quality Plan for tackling nitrogen dioxide attached.
Date: 5 May, 2017
The REA's response to Ofgem's proposals for a review of grid charging and chnages to energy storage grid fee levies.
The REA believe an Significant Code Review (SCR) is necessary of the whole grid fees landscape, including all aspects of the Embedded Benefit, not just those elements proposed.
We support the moves to end double charging of grid fees by storage projects however, as we have called for this for some time.
Date: 5 May, 2017
Date: 21 April, 2017
The REA has been working with other bodies to lead the way opposing the proposed 95% reduction in the 'Embedded Benefit' for small-scale renewable generators and energy storage projects.
We believe this should be looked at holistically as part of a 'Significant Code Review' on grid charging.
Date: 17 April, 2017
The Renewable Energy Association (REA) welcomes the development of the Industrial Strategy and its emphasis on capturing the economic benefits of moving towards a low-carbon energy system. All of the renewable technologies the REA represents have the potential to deliver directly against the ten pillars of the Industrial Strategy - providing innovation, skills, significant export potential (both products and knowledge), as well as being a key infrastructure component for effective regional growth.
To make the most of the expertise and innovation exhibited within the UK's renewable energy industry, the REA has suggested two broad sectors that bring together technologies whose stakeholders share common interests and could benefit from greater industry collaboration and Government support. These are:
1) A deal that ensures effective resource productivity within the UK Bioeconomy - making the most of our biomass and waste resources in power, heat and transport sectors to benefit multiple industries across the UK economy.
2) A deal that promotes growth in the UK Clean Technology - Realising the potential for innovation and commercial growth within renewable technologies to deliver decentralised energy systems.
Date: 10 March, 2017
Members have expressed these specific concerns regarding the proposals:
Date: 15 February, 2017
Ofgem consulted on the closure of the Renewables Obligation in early 2017, the REA's response is below.
Date: 8 February, 2017
REA Response to the Consultation on Improving air quality: reducing emissions from medium combustion plants and generators
Date: 27 January, 2017
This is the response to BEIS' two consultation on the future of heating for domestic and non-domestic buildings.
Date: 27 January, 2017
This is the response to BEIS' call for evidence on the bioeconomy.
Date: 27 January, 2017
REA Response to the Consultation on proposals to amend the Standard Assessment Procedure.
Date: 20 January, 2017
REA Response to the Consultation on the proposed amendments to the Renewable Transport Fuel Obligation.
Date: 20 January, 2017
REA response to the Consultation on The Motor Fuel Greenhouse Gas Emission Reporting Regulations.
Date: 12 January, 2017
This autumn the REA published its updated report, Energy Storage in the UK, A Market Overview, which provides the only listing of energy storage projects in the UK market. Based on this and further assumptions, we believe the UK could see 12 GWh of energy storage installed by 2020 (based on installations co-located at renewables sites, connected to EV charging points, behind the meter at small scale, and larger, grid connected projects), and this forms the backdrop to our response to this consultation as it is only with effective policy in place that this can be achieved.
• Network charging methodology reform is vital, and this should be via a full review of the grid charging mechanisms (a ‘Significant Code Review’). BEIS and Ofgem are supporting the status quo when a move to new methodologies could unlock multiple advantages for the system. Government should consider enabling more innovative new energy system supply options such as local balancing through market platforms and local supply models. Linked to this is the move from DNO to DSO models and the enabling role of the SO.
• A definition for energy storage is essential (the preferred way of implementing this to be determined), and this should be implemented in a timely manner following previous detailed discussions in the area.
Date: 20 December, 2016
The REA responded to the BEIS call for evidence on fuelled and geothermal technologies in the Contracts for Difference scheme.
The REA highlighted issues relating to a number of technologies we represent including Advanced Conversion Technologies, Biogas, Biomass CHP and Deep Geothermal.
Date: 16 December, 2016
The BEIS Select Committee are conducting an inquiry into the Brexit negotiation priorities for Energy and Climate Change . This builds on the previous inquiry conducted by the former Energy and Climate Change Select committee (see REA response below).
Responding to this inquiry, the REA highlighted the importance of putting in place a suitable system for avoiding UK and EU energy system divergence once the UK has left the EU by maintaining a suitable level of access to the Internal Energy Market.
Date: 16 December, 2016
The REA has been campaigning to keep the 'Embedded Benefit' for smaller scale generators.
You can read some of the documents submitted as part of this below. Ofgem's final decision is expected in spring 2017.
Date: 18 October, 2016
REA & WHA response to EFRA Forestry in England inquiry.
The response highlighted how the majority of biomass fuels used in RHI supported boilers originated from the UK and how biomass heating can support the woodland creation and forestry.
Date: 11 October, 2016
REA response to the DCLG Business Rate consultation on the Check, Challenge and Appeal Process for Business Rates.
The key issue highlighted is that proposals wish to bring in a “Reasonable Professional Judgement’ clause which is undefined and would override cases being considered using an individualistic approach. This would threaten a projects ability to challenge their rateable value based on evidence relevant to their specific project.
Date: 23 September, 2016
As members of the Renewable Energy Association we are in full agreement with the joint response submitted by the REA and Association of Decentralised Energy in response to the above. The purpose of this letter is to draw you attention to some issues specific to landfill gas.
Date: 14 September, 2016
The REA responded to the Energy and Climate Change Committee inquiry into the impacts of Brexit on UK energy policy.
The REA response states that the Government must provide the renewables industry with stability during the Brexit process so that project development may continue and investor confidence is maintained. To do this, Government should commit to the transposition of existing EU legislation into UK law at the point the UK ends it's EU membership. Only after Brexit is completed should changes start to be made to the existing energy policy framework. The Government must also make clear their overall domestic energy strategy. This would provide certainty around existing support mechanisms in order to ensure that business as usual can continue during negotiations.
Date: 2 September, 2016
The WHA has submitted its response to BSL consultation on suppliers fees. The new suppliers fee will be introduced for all wood fuel suppliers that register fuel on the Biomass Suppliers List. The consultation proposed three types of fees: Membership fee, application fee, and tonnage fee.
We expect the results of the consultation to be announced at the end of September.
Date: 2 September, 2016
Ofgem consulted in August 2016 on standard industry practice for commissioning plants in the RO scheme. This will gain increasing importance as the RO closure date approaches. Please find attached the REA response, drafted by the Biogas Group.
Date: 9 August, 2016
The REA's response to the above consultation can be downloaded here - we call for energy storage to be a major priority and a low carbon threshold test for new infrastructure considerations.
Date: 3 August, 2016
The REA submitted the below response to this July 2016 consultation.
Date: 22 June, 2016
The REA submitted the below response to this June 2016 consultation.
Date: 21 June, 2016
The REA submitted the below response to this May 2016 consultation - our key message is that the definition of energy storage needs to be fit for purpose and appropriate to the needs of the sector and must be joined up with work on this subject in Europe.
We propose an alternative definition to that proposed (which is taken from the existing Capacity Market definition) and express concerns regarding the State Aid cumulation requirements which do not fully define that which constitutes State Aid.
Date: 20 May, 2016
The Royal Academy of Engineering launched a call for evidence on sustainability issues associated with liquid biofuels in UK transportation.
Date: 10 May, 2016
The European Commission opened an consultation on sustainable bioenergy policy for the period after 2020.
Date: 6 May, 2016
Briefing document for biogas members
Date: 3 May, 2016
The REA submitted the below response highlighting energy storage as one of the great technological innovations likely to revolutionise the energy system.
We believe energy storage technologies (which include batteries, compressed air, flywheels, liquid air, pumped hydro, thermal and a range of developing storage technologies) could revolutionise energy markets. When combined with Demand Side Response and microgrids, these options address numerous energy system issues.
Date: 28 April, 2016
The Department of Energy and Climate Change has opened an consultation to reform the Renewable Heat Incentive. Within the REA response we highlight that:
Date: 19 April, 2016
The Commons Energy and Climate Change Committee (ECCC) are conducting an inquiry into the UK’s progress in relation to the 2020 renewable heat and transport targets. Within the REA response we highlight that:
• Current renewable policies mean we will only reach 6.5% of transport demand coming from renewables by 2020, once multiple counting is taken into account. Similarly within the heat sector, projections included within the recent Renewable Heat Incentive Consultation suggest only 9% of heat demand will come from renewable sources by 2020. This is significantly less than required to meet the Renewable Energy Directive 2020 targets, while also putting further stress on the power sector to decarbonise by up to 40%, at a time when renewable power support has been significantly reduced.
• There has been a lack of progress in relation to the transport sector with the Renewable Fuel Obligation continuing to be capped at 4.75% of all fuels supplied. To grow the market, the RTFO target must be raised in 2017 to at least 6.5% and a straight line trajectory set thereafter to 2020.
• There is a need to support a wide range of liquid and gaseous renewable transport fuels; this includes the introduction of E10, as well as continuing the success of the biodiesel industry and developing the use of biomethane as a gaseous renewable transport fuel. We also make recommendations for promoting the use and deployment of Electric Vehicles, as long as the power grid is suitably decarbonised in order to ensure carbon reductions.
• In relation to heat, the response highlights how proposed reforms to the Renewable Heat Incentive are going to further restrict the deployment of certain renewable heat solutions. This includes dramatically reducing the deployment of biomass heat which is well suited to energy inefficient buildings which are off-gas grid. As such, it is feared that the new proposed RHI tariffs will not deliver the best value for money to achieve significant carbon abatement.
• Support for decarbonising the gas grid, through the production of biomethane from both Anaerobic Digestion and Advanced Thermal Technologies, was also highlighted as essential for meeting our future heat demand. This includes ensuring improved access to food waste, as well as introducing separate AD and Thermal Technologies RHI tariffs.
• Overall, it was made clear that significant progress is required, with long term heat and transport policies to be put in place, if the UK is to get near to meeting its 2020 targets.
Date: 7 April, 2016
The Competition Market Authority (CMA) released their provisional remedies on the 17th March 2016, following a two year energy market investigation. They proposed a broad package of measures for reforming the energy market, many of which are focused on improving competition within the retail sector. However a number of remedies will impact generators, including reforms to CfD allocation and the introduction to locational transmission loss pricing, while putting 100% of transmission loss charges onto generators.
Within the response, the REA state:
• We support the introduction of impact assessments prior to the allocation of a CfD budget, and the division of technologies between auction pots. However, such analysis should consider the whole-system benefits provided by a technology, rather than focusing solely on projected costs.
• The impact assessment should involve Ofgem as an impartial regulatory body.
• Auctions should run on an annual basis, and the budget, set a year in advance, should be considered a ‘minimum budget’.
• The CMA must ensure that the proposed remedy for CfD allocation is not used by DECC to further delay the next CfD auction.
• That suggested locational adjustments for transmission loss pricing, and the transferring of 100% of costs onto generators, will have negative implications for remote renewable generators and embedded projects.
• A far wider review of grid and operation costs is currently underway, which will likely identify the barriers to the development of a decentralised energy system. Locational pricing should be considered within this context and, if required, brought in as part of this process, not in parallel to it.
A final CMA report is expected in June, setting out the remedies which DECC will have to decide whether or not to take forward.
Date: 18 February, 2016
The Environmental Audit Committee has conducted an inquiry into the role of HM Treasury in relation to sustainable development and environmental protection.
The REA response highlights the role that HM Treasury has in providing transparent fiscal boundaries for sustainable policies, around which departments such as DECC, DEFRA and the DfT frame their energy policies. We point out that there have been recent examples where Treasury has gone beyond this role, specifically in regards to their decisions last year to remove Levy Exemption Certificates (LECs) and exclude renewable generation from qualifying for Venture Capital Schemes.
The REA has also used this consultation to reiterate a number of potential fiscal mechanisms that Treasury could use to incentivise the growth in the renewable industry, this includes:
• A commitment from Treasury for renewable energy funding past 2020 and providing a clear trajectory for the future of the carbon price.
• Calling for the reintroduction of LECs, especially for emerging technologies like gas to grid Biomethane.
• Extending Enhanced Capital Allowances to onsite renewable technologies, including solar, Storage and AD.
• Using the April 2017 Business Rate revaluation to provide relief to those businesses installing renewable onsite technologies.
• Reassessing Fuel Duty to provide relief on both liquid and gaseous renewable transport fuels.
• Working with DECC to reform the capacity market to enable renewable technologies which supply base load capacity, such as storage, AD and ACT, to compete within the auction.
Date: 11 February, 2016
The Energy and Climate Change Committee is conducting an inquiry on stakeholder views in order to conduct pre-legislative scrutiny of the Government’s draft legislation on energy as published by DECC on the 21st January 2016. The draft legislation looks at smart metering, supply and switching and competitive tendering for onshore transmission.
The REA's overall view is that the smart energy and onshore transmission network proposals are welcome in order to enable DSR and energy storage services. These will help balance variable renewable power sources and drive down costs in grid connections.
Date: 11 February, 2016
DECC has conducted a consultation which sought views on ensuring new regulation is effective in encouraging new business models and technologies.
The REA have highlighted a series of ‘guiding principles’ the government should adopt to ensure future regulation is appropriate for the non traditional business models now entering the energy market. This includes highlighting where regulation could be used to support the deployment of energy storage systems, facilitating innovation within a decentralised energy system.
Date: 10 February, 2016
In its Energy Union Framework Strategy, the Commission announced a new renewable energy package for the period after 2020, which are to include a new renewable energy directive (REDII) for the period 2020-2030.
The first Renewable Energy Directive for 2010-2020 defined European regulatory framework for renewables by 2020, agreed in co-decision and enshrined in legislation, sat out binding national targets for renewables, was decisive in incentivising Member States to adopt enabling renewable energy support policies, and in attracting private investment in renewable energy assets.
Date: 1 February, 2016
The Energy and Climate Change Committee conducted an inquiry on setting the UK's 5th Carbon Budget.
The Climate Change Act (2008) required the Committee on Climate Change (CCC) to publish their recommendations for the 5th Carbon Budget in November 2015. The budget, which will have to be set in legislation by June 2016, sets the carbon abatement targets the UK should achieve by 2032 in order meet our overall target of an 80% cut in CO2 emissions below 1990 levels by 2050. Along with their recommendations the CCC also published their 'Energy Sector Scenarios', providing their analysis of what needs to happen in each sector to meet the budget.
The REA state our support for the budget as a ‘minimum level of action’ required in order to ensure the UK keeps to its emission abatement commitments. We also comment on each energy sector in turn including Power, Heat, Transport, Agriculture and Waste. We highlight where we believe the CCC has underestimated the potential of certain technologies such as AD, Biomass Boilers, Biomethane, Biofuels and Energy Storage, while calling on the government to recommit to these technologies and realise their benefits for meeting the 5th Carbon Budget.
Date: 29 January, 2016
DECC conducted a Call for Evidence in relation to the effectiveness of the Energy Technology List (ETL); the governments energy efficiency product list which stipulates the technologies which qualify for Enhanced Capital Allowances (ECAs).
The REA has argued for the expansion of the current list to include on-site renewable generation technologies, like Solar PV, AD and energy storage. This will allow them qualify for the tax break, especially in light of the recent cuts to renewable subsidies.
Date: 29 January, 2016
DECC consulted on the support levels for solar PV projects under 5MW in capacity available under the Renewables Obligation (RO) scheme. The proposed rates are 0.8 ROCs/MWh for both rooftop and ground-mounted schemes.
In response the REA highlighted that the industry is working hard to adapt and develop new business models, however this will take time. The skills and supply chains must be retained in the meantime. Lack of deployment in coming years will jeopardise the industry’s otherwise achievable route to grid-parity. It may also hamper the adoption of innovative and beneficial new energy storage technologies, which can balance out supply and demand, while providing grid services such as frequency response.
In particular, we argued:
• The load factors should be revised
• Modelled capital expenditure costs should be increased
• The modelling most likely under estimates the cost of future grid connections
• Hurdle rates should be on the higher rate
• Community Energy and Local Authority projects will likely be unable to commission projects under the proposed rate and grandfathering conditions.
• The decision to remove grandfathering rights should be reversed to retain industry deployment.
Date: 15 January, 2016
Ofgem consulted on changes to be made to the Capacity Market Rules.
As well as support for base load renewables in the mechanism, the REA argued for storage technologies to be better supported by:
• Introducing longer contracts for storage projects
• Allowing revenues to be ‘stacked’ from different mechanisms
• Reduce the minimum power supply period required for contracts awarded to storage providers.
Date: 8 January, 2016
The National Infrastructure Commission (NIC) is a new, independent body tasked with looking at the long term infrastructure needs of the UK. This includes improving how electricity demand and supply is balanced and what role new technologies could play in ensuring an affordable, low carbon and secure energy system.
In December 2015, the NIC launched an initial Call for Evidence inviting stakeholders to highlight key concerns and opportunities in regards to infrastructure development. The REA provided evidence in regards to the role that energy storage can play in transitioning the UK to a low carbon energy system in line with Government targets and legally binding commitments, as well as reducing net costs to consumers.
Date: 20 November, 2015
The Environmental Audit Committee conducted an inquiry on the future of the Green Investment Bank (GIB), focusing on the Governments proposals to sell the bank to private owners. While the REA's response is not fundamentally opposed to the GIB privatisation, it raises significant concerns as to whether a private bank, requiring low risk profiles and high short term returns, will be able to support emerging renewable technologies to the same extent as a publically financed organisation.
We request that appropriate contractual guarantees are put in place with new owners in order to ensure that the bank continues to focus beyond well established low carbon solutions and supports riskier emerging renewable technologies.
Date: 11 November, 2015
HM Treasury conducted a high level consultation examining how best to encourage investment in the low-carbon economy by simplifying the business energy efficiency tax landscape. In response, the REA agreed with the proposals to create a single tax based on the Climate Change Levy (CCL) model and develop a single emission reporting framework for businesses.
The consultation also requested ideas for further encouraging investment in low carbon projects, to which the REA has made a number of recommendation for possible incentives designed around the broader business tax environment. This includes:
• Extending Enterprise Investment Scheme tax relief, Enhanced Capital Allowances and the Enterprise Guarantee Scheme to renewable technologies in line with our proposals for the Feed-in Tariff Review.
• Encourage local authorities to implement the Merton Rule and provide business rate tax relief to organisations implementing renewable technologies and energy efficiency schemes.
• Use embedded benefits to incentivise projects that help mitigate intermittency issues and reduce grid balancing costs– such as through the use of energy storage.
• Ensure that, if a new version of the CCL is brought in, Levy Exemption Certificates for renewable energy across all sectors are reintroduced to facilitate a trading market which can provide an additional revenue stream for developers.
• Incentivise energy efficiency and renewable heat through tax relief on property tax regimes.
Date: 10 November, 2015
The REA believes that effective infrastructure is vital to transition to a low carbon energy system. Grid connections have beocme one of the biggest barriers to new renewable electricity projects in the UK and this needs to be addressed in order to meet our legally binding renewable energy targets.
We responded to the Energy and Climate Change Committee's Inquiry into Low Carbon Infrastructure to make this point and proposed a number of options to alleviate the situation.
Date: 27 October, 2015
The Department for Energy and Climate change has recently conducted a Review of the Feed-In Tariff support for all sub 5 MW renewable generation. The consultation proposed huge cuts to the tariffs for all technologies, as well as introducing tight maximum capacity deployment caps. This is a further change to the scheme following DECC’s decision to remove the ability for projects to be pre-accredited.
Below we have published both REA’s summary and the full response to DECC’s consultation questions.
Date: 27 October, 2015
The Committee on Energy and Climate Change held an inquiry to examine whether increased uncertainty around energy policy is undermining investor confidence.
The REA comment that the government’s recent overhaul of energy policy has been done with such speed and severity that it has greatly undermined energy sector investor confidence in the UK. A recent survey of our members showed that the decisions of the last few months have forced many developers to either put projects on hold or abandon them altogether as organisations are unable to confidently forecast their returns on investment. It is feared that this will also leave a lasting legacy of mistrust in future strategies, as policy risk becomes a major barrier to investor engagement and will increase the cost of capital. DECC and HM Treasury must now act quickly, setting out a new long term, stable and consistent national energy policy in order to mitigate these impacts and ensure the continued growth of renewable industries.
Date: 14 October, 2015
The Committee on Energy and Climate Change held an inquiry to examine what lessons can be learnt from past energy efficiency polices, including the Green Deal and Zero Carbon Homes.
The REA suggests there are numerous lessons to be learnt from the poor design and implementation of previous policies. The response draws on the experiences of Renewable Energy Assurance Ltd., a fully owned subsidiary of the REA, who monitored and maintained the Green Deal Code of Practice as part of the Green Deal Oversight and Registration Body. Effective governance and ensuring access to low interest finance is highlighted as being critical to the success of future home energy efficiency policies.
Date: 15 September, 2015
The REA lead drafted this joint letter to DECC on the proposed FiT cuts.
Date: 10 September, 2015
The REA responded with the below comments to the call for input into the Comprehensive Spending Review 2015.
The Wood Heat Association (WHA) submitted its own response, also below, due to the importnace of the RHI during the review.
Date: 10 September, 2015
The Government consulted on closing the Renewables Obligation (RO) to solar PV projects under 5MW in size in summer 2015.
Our response emphasises the damaging nature of the proposals especially in light of the wider context of other policy changes unveiled by the new Government as of summer 2015. There have been more than 15 detrimental policy announcments for renewables and the green sector since May 2015, including a delay to the Contracts for Difference (CfD) auction, and potential closure of the Feed-in Tariff scheme.
If the proposals are implemented the only avenue for large scale solar projects to build will be the CfD mechanism, however there is huge uncertinaty over the budget and allocation rounds for this policy, leaving large scale projects with no policy support.
Date: 20 August, 2015
REA Biogas response to DECC consultation on FIT pre-accreditation
Date: 20 August, 2015
REA UK Solar response to DECC consultation on FIT pre-accreditation
Date: 4 June, 2015
The Committee on Climate Change held a call for evidence on the proposed 5th Carbon Budget (covering the period from 2028 - 2032), which closed on 2 June 2015.
The REA's response flagged the need for legally binding 2030 renewable energy targets and stable policy and budgets beyond 2020.
Read the response below
Date: 27 May, 2015
The REA submittted the below response to Ofgem's Non-Traditional Business Models Consultation.
This is a wide-ranging consultation with multiple potential implications. Ofgem are seeking views on new business models in the energy sector and how to regulate these, including energy storage, DSR, community energy and aggregators. The REA believe this is an important area and needs further work, and we are seeking member views on the content. In our view, the issues are so broad and far ranging, that a back to principles approach is necessary, rather than becoming embroiled in the details at this stage.
Market participation and regulation need to be simplified and barriers to entry reduced, with a flexible approach to regulating new business models possible so that models offering additional benefits for the energy system can be supported and enabled.
Date: 14 May, 2015
The REA has a dedicated grid expert and welcomed the opportunity to comment on one of the most important issues for renewable projects - connecting to the grid. Ofgem Consultation on Quicker and More Efficient Connections.
These issues form the heart of barriers faced by much of the renewables industry at present. We believe they should be prioritised and expedited within Ofgem.
• On the face of it Scenario 1 appears the most favourable, as DNOs can borrow at a lower cost of capital than developers, but all options could be possible and should be carefully considered.
• We also support the principle of reinforcement ahead of need, as suggested in Scenario 2.
• Better queue management is essential to free up unused capacity.
• Considering how storage could be better incentivised to support constrained and saturated networks.
At heart, the REA believes that the UK needs a coherent, national and strategic approach to grid networks and this is a separate area that the new Government must take a lead in if the situation is to be satisfactorily resolved for the future.
Date: 14 May, 2015
The CfD policy has been fully implemented in the GB market and the first allocation round completed in March 2015.
This consultation seeks views on the implementation of the policy in Northern Ireland.
The REA seek to raise our general suggested improvements to the CfD policy and have concerns regarding grid delays and a possible hiatus in 2017 in Northern Ireland.
Below is our draft response, the consultation closes on 18 May 2015.
Date: 13 March, 2015
Please find the REA & WHA's response to DECC Call for Evidence on Third Party Finance Options.
Date: 3 February, 2015
DECC consulted in December 2014 on removing grandfathering rights from biomass conversion and biomass co-firing plants moving up bands in the RO mechanism in the future.
While we understand the need to protect the Levy Control Framework funds, we are concerned by th epossible precedent that may be set by such a move.
Date: 20 January, 2015
Please click below to download REA's response to DECC's position paper on Non-Domestic Renewable Heat Incentive Tariff Guarantees.
Date: 5 January, 2015
Please click below to download REA's response to DECC's consultation on the transferability of building-mounted solar PV installations under the Feed-in Tariff scheme.
Date: 22 December, 2014
This is the REA's response to DCLG's consultation on exempting small sites from zero carbon homes policy.
Date: 28 November, 2014
Please click below to download the REA Response to consultation on Ofgem and Fuel Measuring and Sampling/Sustainability under the CfD.
Date: 7 November, 2014
Please click below to download the joint REA-STA response to DCLG’s technical consultation on the Housing Standards Review.
Date: 31 October, 2014
With the publication of the Community Energy Strategy in January 2014, the Secretary of State for Energy and Climate Change asked the renewables industry and the community energy sector to work together to establish a voluntary framework to guide shared ownership of renewable energy.
The Community Energy Strategy states: “We expect that by 2015 it will be the norm for communities to be offered the opportunity of some level of ownership of new, commercially developed onshore renewables projects. We will review progress in 2015 and if this is limited, we will consider requiring all developers to offer the opportunity of a shared ownership element to communities.”
The REA is a member of the Shared Ownership Taskforce, which was established to develop this framework in a Report to the Government. The draft Report was published for consultation in the summer and the final Report was published on 31 October 2014.
Please click below to download the final Report and supporting documents, including the REA response to the consultation.
Date: 24 October, 2014
Please click below to download the REA response to DECC’s consultation on further changes to financial support for solar PV.
Date: 26 September, 2014
The government intends to implement sustainability regulation for bioenergy under the RHI, RO and CfD, including sustainable forest management. DECC has released three guidance documents for how to demonstrate compliance. The REA submitted this response expressing the industry's concerns.
Date: 26 September, 2014
Please click below to download the REA's response to DCLG's Technical consultation on planning.
Date: 12 September, 2014
The REA responded as attached to the consultation on transition from the RO, including choice of scheme between the RO and CfDs and a number of grace periods for eligible generators looking to deploy under the RO.
Date: 28 August, 2014
The current grid and network regulation is arguably not working and skewed towards the companies which own the local networks, at the expense of distributed generators and 'demand' customers (for example new commercial developments). The REA have been working to reform the system and the ENA, backed by Ofgem, issued a consultation in the summer (see open letter).
The REA have responded to support these aims and look forward to engaging further with Ofgem on the subject.
Date: 27 August, 2014
Please click below to download the REA's response to DfT's Consultation on proposed amendments to the Renewable Transport Fuel Obligations Order 2007.
Date: 15 August, 2014
Please click below to download the REA's response to DECC's Consultation on Proposal for Underground Access for the Extraction of Gas, Oil or Geothermal Energy.
Date: 31 July, 2014
Ofgem's consultation on the dispute resolution process for CfDs proposes that no new or corrected information may be provided at any stage. This raises the prospect of companies being disadvantaged based on small adminnistrative errors they are unable to correct. The REA submitted this response suggesting an alternative process.
Date: 31 July, 2014
The REA welcome the proposed 12 month grace period for these projects and submitted the attached consultation response.
Date: 31 July, 2014
The REA and independent generators have a number of concerns regarding the proposed Offtaker of Last Resort (OLR) mechanism:
- The discount rate proposed (£25/MWh) is too great and should be reduced.
- The mechanism will start payments too late (in 2016), which wil be after the first payments begin in spring 2015, and should therefore begin payments in April 2015.
Date: 15 July, 2014
The REA's consultation response to the DECC Consultation on biomass sustainability reporting, which closed on 14th July.
Date: 7 July, 2014
Please click below to download our response to DECC's Consultation on changes to financial support for solar PV.
Date: 7 July, 2014
Please click below to download the REA response to DECC's Consultation on support for community energy projects under the Feed-in Tariffs Scheme.
Date: 27 June, 2014
The REA has submitted this response to DECC's Consultation on the RHI Biomethane Injection to Grid Tariff Review.
Date: 13 June, 2014
The REA has submitted this response to DECC's consultation regarding minima and maxima in the CfD allocation process.
In the REA's view minima are essential for ptoviding certainty and stability to generators and developers and preventing damaging stop - start renewables deployment as has been the case with previous support schemes.
Date: 9 May, 2014
Please click below to download the REA's response to the Defra Call for Evidence on the Refuse Derived Fuel (RDF) market in the UK. The REA has responded via our Gasification and Pyrolysis sub-group and Organics Recycling Group.
Date: 8 May, 2014
Please click below to download the REA response to the EFRA Committee Inquiry on Waste Management in England.
Date: 8 May, 2014
Please click below to download the joint REA/STA response to the CLG Committee Inquiry into the Operation of the National Planning Policy Framework.
Date: 25 April, 2014
Please click below to download the REA response to the Environmental Audit Committee Inquiry on the Circular Economy.
Date: 25 April, 2014
The REA have replied to the above consultation regarding the Secretary of State's ability to allocate CfDs on a bilaterally negotiated basis, as set out in the Energy Act 2013.
Date: 23 April, 2014
The REA's response to the consultation on the draft Allocation Framework for awarding CfD contracts.
Date: 28 March, 2014
Please click below to download the REA response to SSE's consultation on Electricity Network Reinforcement on the Orkney Islands.
Date: 28 March, 2014
The REA have been active in calling for support for generators struggling to access teh market in the large scale power market.
The Government's 'Offtaker of Last Resort' backstop PPA proposals aim to address these concerns and more detailed proposals were consulted on in February - March 2014.
We are glad that all technologies will now be eligibel for the support, however have several concerns on the details, particularly the level of PPA discount proposed and contract terms.
Date: 7 March, 2014
REA sets out why DECC's objective of increasing community ownership of commercially developed renewables projects, as set out the Community Energy Strategy, is best achieved by a voluntary rather than legislative approach.
The REA document is in response to DECC's discussion paper, issued in February titled "Community Right to Buy In to Renewable Electricity Generation Developments:
Discussion Document"
Date: 21 February, 2014
Click below for the REA’s response to the DfT’s Call for Evidence on Advanced Fuels. A departmental response will be given later in 2014.
Date: 14 February, 2014
Please click below to download the REA's response to the European Commission's consultation 'European Commission Consultation on draft Environmental and Energy Aid Guidelines 2014-2020'.
Date: 14 February, 2014
National Grid consulted on proposals whcih if adopted could considerably increase costs for generators using the distribution network, potentially meaning they would need to pay for a service they do not use (using the higher voltage transmission network).
Final proposals will be announced in spring 2014, but the REA is working wth other trade bodies to oppose any such move. Attached below is the response we submitted to a consultation in February 2014.
Date: 13 February, 2014
The REA have responded in the attached to DECC's consultation on the high-level proposals for allocating CfD contracts.
The REA propose an approach in order to ensure industry gain certainty of a minimum level of future deployment.
Date: 6 February, 2014
Please click below to download the REA's response to the DfT consultation 'Renewable Transport Fuel Obligation: a draft post implementation review'.
Date: 31 January, 2014
The REA's response to proposed changes to this guidance for generators connecting to the distribution network.
Date: 28 January, 2014
The Consultation on updated CfD contract terms, including FMS arrangemnts closed on 27 January. Read the REA's response here.
Date: 17 January, 2014
Please click below to download the REA response to DECC’s Call for Evidence on EU/UK Balance of Competences – Energy Review.
Date: 17 January, 2014
Click below to download the REA’s response to BSI consultation on the draft PAS 110 specification for whole digestate, separated liquor and separated fibre derived from the anaerobic digestion of source-segregated biodegradable materials.
Date: 10 January, 2014
The REA have responded to the UK Government's EU Balance of Competencies Review- Agriculture, attached below.
Date: 2 December, 2013
Please see attached the REA response to the Consultative Communication on the sustainable Use of Phosphorus from the European Commission.
Date: 28 November, 2013
This is the REA's response to the consultation on proposals for grace period provisions in the Renewables Obligation, prior to the scheme's closure in 2017.
Date: 20 November, 2013
Please find attached the REA's response to Defra's consultation on changes to marine licensing fees and charges.
Date: 29 October, 2013
Please see attached the REA response to the DECC consultation on additional support for Scottish Islands.
Please contact the REA's Head of Marine, Steph Merry, with any follow up questions.
Date: 22 October, 2013
Please see attached the joint REA and STA response to DCLG's Housing Standards Review consultation.
Date: 16 October, 2013
Please see attached the joint REA and STA response to DCLG's Consultation on Next steps to zero carbon homes: allowable solutions.
Members can contact Mike Landy with any questions regarding the consultation or the response.
Date: 11 October, 2013
The REA has responded to National Grid's consultation on the Project Transmit 'Minded to' decision Impact Assessment.
Date: 8 October, 2013
The REA have responded to the Marine Management Organisation's consultation on draft East Inshore and East Offshore marine plans.
Date: 8 October, 2013
The REA's response to the Welsh Government's Third Stage on Waste Guidance consultation.
Date: 25 September, 2013
The REA has today responded to the DECC consultation on the EMR draft Delivery Plan for the period 2014 - 2018, including renewable energy strike prices.
Date: 25 September, 2013
This consultation relates to the arrangements to be put in place during the transition from the Renewables Obligation (RO), the existing large sacle power support scheme, to Contracts for Difference (CfDs), the successor support scheme.
Date: 24 September, 2013
The REA's response to DEFRA’s Consultation on a Waste Management Plan for England.
Date: 23 September, 2013
Please see attached the REA's response to teh Defra consutlation on the Waste Prevention Programme for England.
Date: 23 September, 2013
Please see attached the REA response to the DCLG Consultation on the Government’s proposals to update national waste planning policy, Planning for sustainable waste management.
Date: 10 September, 2013
The REA's response to Consultation on the Review of the European Waste Management
Targets.
Date: 5 September, 2013
REA's response to the consultation on DCP 162: Non Secure Connections in the Common Connections Charging Methodology'.
Date: 2 September, 2013
The REA's response to the consultation on draft CfD contract terms and associated issues including metering, billing, biogenic content and contract allocation.
Date: 6 August, 2013
Please find below the REA's Response to tthe Government's Review of the Balance of Competences between the UK and the EU (Transport)
For any further information please contact Brittany Vogel.
Date: 1 August, 2013
Please find below the REA's response to the Community Energy Call for Evidence.
For any further information please contact Frank Gordon.
Date: 2 July, 2013
Please find below the REA response to the European Commission consultation Green Paper "A 2030 framework for climate and energy policies".
For further information please contact Mike Landy.
Date: 28 June, 2013
Please find below the REA response to the DECC consultation Renewable Heat Incentive: Non-Domestic Scheme Early Tariff Review.
For further information please contact Paul Thompson.
Date: 12 June, 2013
Please see attached the REA response to the Environmental Audit Committee on Energy Subsidies. For further information please contact Mike Landy.
Date: 7 June, 2013
Please see attached the REA response to DECC's RO dedicated biomass notification register consultation launched by DECC on 13th May 2013.
The REA believes that dedicated biomass has an important role to play in meeting our binding renewable commitments. Given that it requires substantially lower subsidies than many other technologies that are not constrained, we do not see the case for limiting it. In addition to its contribution to environmental targets, the power has the advantage of being dispatchable, complementing the intended expansion of intermittent renewables such as wind and solar PV.
Date: 30 April, 2013
The REA response focuses on the position for renewable energy but clearly there is a wider energy context.
See the full consultation paper here.
Date: 23 April, 2013
Please see attached the REA response to the Energy and Climate Committee's (ECC) one-off session on bioenergy. For more information on the inquiry please see the Parliament website here.
Date: 23 April, 2013
Please see attached the REA response to the Energy and Climate Committee's (ECC) inquiry on local energy. For more information on the inquiry please see the Parliament website here.
Date: 28 March, 2013
Please find attached the REA response to the consultation on designation of marine conservation zones.
See the full consultation here.
Date: 15 March, 2013
Please find attached the Ocean Energy Group's response to the Historic Environment Guidance for Wave and Tidal Energy.
Date: 15 March, 2013
Please see attaced the REA's Ocean Enegry Group response to Under Keel Clearance – Policy Paper
Guidance to Developers in Assessing Minimum Water Depth over Devices.
Date: 8 March, 2013
Please see attached the REA response to DECC CHPQA consultation.
See the full consultation here.
Date: 21 February, 2013
Please see attached the REA response to the ECC RHI Inquiry.
Date: 15 February, 2013
Please see attached the REA response to the Energy and Climate Change Committee's (ECC) inquiry on energy prices, profits and poverty. More details on the inquiry can be found on the Parliament website here.
Date: 8 February, 2013