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REF Consultation Response to Ofgem on TCLC 2023

The attached document is REF's response to the Ofgem December 2023 consultation on the Transmission Constraint Licence Condition guidance

Utility Scale Solar PV Costs

A new report on the costs of utility scale solar generation by Professor Gordon Hughes, School of Economics, University of Edinburgh is published today by the Renewable Energy Foundation.

The Economics of Utility-Scale Solar Generation

Wind Power Costs in the UK and Denmark

Two new reports on the costs of wind power in the UK and Denmark by Professor Gordon Hughes, School of Economics, University of Edinburgh are published today by the Renewable Energy Foundation.

Wind Power Costs in the United Kingdom and

The Performance of Wind Power in Denmark

The text accompanying the talk "Wind Power Economics – Rhetoric and Reality" given by Professor Hughes to launch these reports is also available on the REF website.

Electric Vehicles in Scotland's Energy Future Consultation

REF has responded to a consultation carried out by the Scottish Parliament's Economy, Energy and Fair Work Committee (EEFW).  The Committee is holding a three-part energy inquiry, linking an overview carried out by the Royal Society of Edinburgh (RSE) on Scotland’s Energy Future with consideration of electric vehicle (EV) infrastructure, and locally owned energy. The submission by REF is as follows:

Transmission Constraint Licence Condition Consultation

REF has responded to the Ofgem consultation on the future of the Transmission Constraint Licence Condition as follows:

1. The Renewable Energy Foundation (REF) is a UK charity that publishes data and analysis on the renewable energy sector. The costs of payments to on- and off-shore wind farms to reduce output during periods of constraints are included in the published data. Since 2010 we have repeatedly expressed our concerns that wind farm constraint payments are an excessive and unfair burden on consumer bills.

2. Although this consultation concerns both import and export constraints, we note that export constraints’ costs exceed those of import constraints by nearly 9 times , and that the majority of the export constraints’ costs arise from the two locations designated by National Grid as Cheviot and Scotland. This problem has clearly arisen because of the large scale deployment of onshore wind farms in Scotland prior to construction of infrastructure capable of exporting the excess generation from these locations. In this response we have concentrated on the impacts of the TCLC on the Scottish onshore wind fleet.

3. In order to respond to this consultation we have analysed two sets of bid price data: the wind farm bid prices accepted by the system operator since 2010 as well as all the bid prices submitted by wind farm operators but not necessarily accepted by the system operator.

IoA Consultation on AM Noise

REF submitted a response to the consultation carried out by the Institute of Acoustics (IoA) on Amplitude Modulation (AM) noise of wind turbines. We made a number of general remarks on the consultation process and further comments on the detailed questions raised by the IoA.

Progress Towards the 2020 Renewable Electricity Target

The UK government expects that renewable electricity will contribute about half of the renewable energy required in 2020 by the EU Renewable Energy Directive of 2009. This amounts, DECC estimates, to about 110 TWh.

Analysis of DECC’s own Renewable Energy Planning Database (REPD) suggests that there is already 35 GW of capacity consented, and now either operational, or under or awaiting construction. This is sufficient to meet the target with a 5% margin.

However, there is a further 18 GW of capacity in the planning system, which would deliver a target overshoot of about 50%, and exceed the Treasury’s cap on subsidy spending.

The Efficacy of the RUK AM Condition

In a study using real wind farm noise data exhibiting significant Amplitude Modulation (AM) we have been able to test the efficacy of the AM noise condition proposed by RenewableUK. The summary of the findings are : 

1.1. The proposed RUK AM condition would not be breached by recorded wind farm noise data with high levels of AM measured at Askam, a site widely recognised to be producing severe AM problems, and at Swaffham, from data where the AM is clear and significant in magnitude. By comparison, data from both the Askam and Swaffham sites would be in breach of the Den Brook AM condition.

1.2. We conclude from these facts that the RUK AM condition is manifestly inferior to the Den Brook condition and does not offer to wind farm neighbours any realistic or significant protection against AM disturbance. 

IoA Supplementary Guidance Notes on Wind Turbine Noise

REF has responded to the latest consultation by the Institute of Acoustics on the Supplementary Guidance Notes designed to accompany their Good Practice Guide to the Application of ETSU-R-97 for the Assessment and Rating of Wind Turbine Noise.  The summary follows and access to the full text of the consultation response is below.

Response to Professor Mackay on REF's UK wind farm lifetime analysis

Following a recent and unfortunately misleading article in the Sunday Telegraph (08.12.13) by Christopher Booker there has been a certain amount of renewed comment on Professor Gordon Hughes’ work concerning the economic lifetime of wind turbines, work that used empirical performance data gathered by REF. This comment includes blog postings by Bishop Hill and Roger Helmer MEP, to which Professor David Mackay, Chief Scientific Advisor to the Department of Energy and Climate Change has responded personally with online comments, by releasing a draft paper criticising Professor Hughes’ work, and also with an extended blog posting on his own site.

The following statement comments on the extent and significance of the disagreement with Professor Mackay. For the avoidance of doubt, readers should be aware that Professor Hughes does not accept Professor Mackay’s criticisms of the statistical methods employed in his analysis, criticisms which he regards as ill-informed, and unconstructive.

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