This consultation response has been submitted to The Scottish Parliament in respect of The Energy Efficiency and Micro-Generation Bill, which is a private members bill proposed by Sarah Boyack MSP. The details of the consultation are available online from the Scottish Parliament website.

The Mountaineering Council of Scotland [MCofS] is the representative body for hillwalkers, climbers and mountaineers in Scotland. We are a membership organisation with well over 2000 individual members plus over 7000 affiliated members via some 140 associated clubs. We have several committees, one of which is the Access and Conservation Committee. This committee is very involved with all aspects of energy supply and sustainability, the Scottish landscape, especially initiatives to conserve and enhance it, and the implications of climate change. All of these issues have an influence on the quality of life and enjoyment of the Scottish landscape heritage for current and future generations. We welcome this consultation document and the opportunity to respond to it.

We share the frustration expressed by Sarah Boyack over the lack of progress in the development of technologies contributing to micro-generation. Micro-generation has a place in an overall portfolio of energy strategies and could contribute significantly to the economy of Scotland, achieving climate change targets and addressing fuel poverty objectives. The potential of micro-generation is being overlooked in the rush to identify sites for large wind turbine farms and other large schemes. Ideally, we should have a mix of energy sources and small scale renewable sources should be an important component of this.

Small scale renewable installations are expensive despite grant schemes to encourage their incorporation into individual houses, and they are not yet mass-produced. There is a need to support companies involved in this technology and to identify projects which could be marketable, using wind and solar energy. The urgent need to support this particular industry sector is being sadly overlooked by the Scottish Parliament. There is a need to be pro-active to prevent this becoming another missed opportunity for economic progress and achieving carbon reduction targets and climate change objectives.

Incorporating micro-generation technologies is only one of several revisions that should be made to building regulations. The current regulations set minimum standards; hence that is all that is achieved. In reality, there has been little significant progress in energy efficiency in the construction industry in the last 30 to 40 years, and this is directly due to the low expectations imposed by the current regulations. One has only to visit the average showhome in the Central Belt and to ask a few searching questions of the salesperson to appreciate this fact. There is lack of planning towards a sustainable future in energy supply; energy inefficient buildings built now will involve expensive remediation in the future.

The Consultation paper mentions the lack of available information for householders. An awareness raising campaign to educate and advise householders, communities and small businesses is essential at an early stage if a micro-generation industry is to be successful and the concept of local generation is to be embedded in the overall energy culture of the country. The lack of trained staff to install and maintain renewable facilities offers to those with enterprise skills a huge opportunity for providing training and associated services – again, business support is vital.

Page 6. What is being proposed: In general this is acceptable but there are reservations about sellers surveys

Page 6. Climate change targets – the need for a Bill: This illustrates the lack of “joined up thinking” and the need for Scotland to have its own Energy Strategy. The examples of funding streams available are inadequate and do not reflect the commitment there should be to recognition of the potential of micro-generation initiatives.

Page 7. Background: This illustrates that there is recognition in many quarters of the potential role of micro-generation technologies. It is obvious that realistic targets must be set if sufficient confidence is to be raised for investment to be secured.

Page 8. The Mayor's Energy Strategy for London: It is noted that this did not consider local renewable schemes in isolation but the Strategy coupled this with energy efficiency; this has to be a major factor addressed in all energy strategies and yet energy saving methods currently get a low profile in Government thinking and policies. Some laudable initiatives are described and this Strategy could be an exemplar for others to adopt and evolve as local circumstances require.

Page 9. Barriers to take up: it is clear that these barriers must be overcome.

There is a lack of awareness and demand from the public in these matters. It is noted that point 5 in the Benefits of Micro-generation recognises the need to engage consumers in climate change issues.

Questions

1. A viable industry with consumer confidence and demand would possibly need to be established before a legislative approach is implemented.
2. A disadvantage of a legislative approach would be that work would be done to minimum standards – to avoid this the necessary standard would need to be finely judged.
3. Amendment of building standards is long overdue in these respects. They should be reviewed and updated on a fairly regular basis as new technologies come on stream. Target setting and reporting are potentially valuable, providing reviews are not too onerous and bureaucratic. Local Authorities should be encouraged to engage constructively in these developments. Financial incentives will be required for businesses to incorporate these technologies. The area where most investment is urgently needed is in supporting the micro-generation industry.
4. MCofS is not qualified to comment on this.
5. MCofS is not able to comment on or estimate precise potential financial costs.
6. There would need to be safeguards to ensure these technologies, which are expensive at the moment and will be for some time to come in all probability, do not exclude some of those who would benefit and thereby possibly reinforce fuel poverty. There is a role here for both Government and local authorities.
7. The Consultation Paper should emphasise the need for energy efficiency more explicitly. Even such a simple measure as using low energy light bulbs makes a significant saving and should be encouraged. The bulbs are currently relatively expensive [but long lasting] and this is another area to explore. The paper largely deals with micro-generation on individual buildings or establishments; however, there is also a case for using small brownfield sites for small-scale windfarms and clusters/areas of photovoltaic units to generate electricity for communities and businesses. Some local generation would reduce [but not, of course, entirely eliminate] the need for large-scale generation in locations remote from communities to meet baseload demands. These have associated extensive and controversial transmission lines.

The Consultation paper is very comprehensive and well referenced and researched. The Mountaineering Council of Scotland strongly supports this Member's Bill and is prepared to engage in any further deliberations.

Yours sincerely

On behalf of the Mountaineering Council of Scotland

Beryl Leatherland
Vice-president and Chair of the
Access and Conservation Committee

March 2006