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REVOLT'S Comments on the Environmental Action Plan - A Discussion Paper prepared by Ofgem, July 2000


  The Chapel Field,

e-mail cunniffe @tesco.net

Rural England
Versus Overhead
Line Transmission


28 September,2000

Mr. John Neilson,
Deputy Director General,
Customers and Supply,
16 Palace Street,

Dear Sir,

Environmental Action Plan A Discussion Paper July 2000.

This discussion paper is a welcome start in developing an action plan. Our comments are attached. There seem to be too many Government fingers in this particular pie and we can only encourage you to take the lead, to be proactive and coordinate and positively manage the environmental actions of the Electricity Supply Industry.

Yours faithfully,



Science, Engineering and Environmental Sub Group.

REVOLT'S Comments on the Environmental Action Plan
- A Discussion Paper prepared by Ofgem, July 2000

The paper is a welcome start to displaying the problems which exist and need to be addressed.

The extent that Ofgem feels constrained to work within the existing Governmental organisation is not clear but hopefully Ofgem will press for the necessary powers where these can be shown to be required to have a coherent Environmental plan which can be monitored and whose results will be published in a factual form annually.

The comments on the document fall into four categories:

1. Comment on the existing responsibilities of Ofgem and other bodies with suggestions on changes for improvement.

2. Suggestions in arrangement of the document to make it easier to read

3. A review of the questions posed by Ofgem in the document . The paragraphs in bold typeface.

4. Apparent errors / omissions / editing suggestions.

1. Comment on the existing responsibilities of Ofgem and other bodies with suggestions on changes for improvement.

The key section is Table 2.1 Summary of Government Environmental and Related Policies affecting Gas and Electricity Markets

The problem this table exposes is that the main elements are controlled and reported on by other departments/agencies of State and there is not one body preparing a focused report on the gas and electricity supply industries and making recommendations for environmental improvement.

Pollution Control

Environment Agency

Planning, Local

Local Authorities

Planning, National


Clean up of Contaminated land



Environmental Agency


Nuclear Inspectorate

Environmental reports

Operating companies

Ofgem should be required to examine the reports made by other bodies, have the reporting format modified where Ofgem believes there are omissions or inadequacies and incorporate their reports into one Environment Report covering Electricity and Gas. Ofgem should offer an opinion on the rate of achievement in meeting statutory and voluntary goals and make proposals for future actions. Operating companies do prepare environmental reports but these also cover other non UK Regulated interests of the companies and are prepared in the style of the written portion of company reports designed to be reassuring with emphasis on the good bits. Companies should report on their regulated businesses separately and all use a common format to aid aggregation by Ofgem.

As pollution is not an issue affecting only England, Wales and Scotland and legislation is UK wide, Ofgem should report on UK situation with the NI Regulator providing data in the Ofgem required format for inclusion in the Ofgem report.

To put the UK efforts in context Ofgen should compare the results with world best practice.

The Electricity Act requires companies to prepare Schedule 9 Amenity Statements and revise these from time to time. These Amenity Statements should be subject to Ofgem approval and become the highest level document in a cascade of documents showing the company approach to the environment, its policies, the strategies, annual targets and the methods it proposes to employ to meet the stated aims. As part of their environment report companies should report on the achievement of their stated aims.

Ofgem should consider producing model Schedule 9 Statements as a minimum requirement.

When operating companies apply for accreditation to BS/ISO14001, the scope covered should be approved by Ofgem.

The present DTI planning powers and procedures are flawed and undemocratic. They should mirror the requirements of Local Authority Planning. (A separate submission can be made on this subject if required). Ofgem should review all Government departments powers over the production and distribution of Gas and Electricity, publish their views about their consistency and appropriateness and whether these powers are effective in protecting the environment.

2. Suggestions in arrangement of the document to make it easier to read

3. A review of the issues highlighted by Ofgem in the document (the paragraphs in bold typeface).

Document Para. Comment



For example Ofgem will consider what use might be made of Codes of Practice. We will also encourage all companies we regulate to report annually on their environmental activities (many already do), and publicise examples of good practice

A more positive approach is required of Ofgem, see 1 above




In developing our policy response Ofgem will consider how we interpret our new primary responsibility to protect the interests of consumers. For example, how far does this extend to protecting the interests of future consumers as against those of present consumers?

In order to show that environmental implications are properly addressed in our internal decision-making processes, Ofgem might consider developing a checklist to assist us with our work.

In addition Ofgem might consider whether it would be helpful to draft guidelines for each of the economic, environmental and social elements of sustainable development.

Ofgem needs to prepare or have others prepare fuel availability scenarios showing price and global warming consequences. The Government of the day will have to determine what is politically possible

Ofgem should prepare such a check list, if it is helpful Ofgem should seek to spread the use of similar check lists to other Government departments.

Ofgem should develop draft options for each of the economic and social elements of sustainable development. Ofgem should try to ensure the options are understood and let the Government of the day decide what should be implemented.


Document Para.



Ofgem will consider facilitating the development of energy services options, for example by supporting Energy Saving Trust's programme to promote energy services and investigating evidence presented to us of barriers, and monitor this development.

Regret cannot comment, have no knowledge of EST programme.


Ofgem also intends to report annually on our activities in relation to the environment, including progress towards commitments made in the Environmental Action Plan.

Agreed but Ofgem should do more rather than less. See Item 1


Ofgem has started to discuss with the Environment Agency whether they might take over the responsibility for analysing and reporting on the gas and electricity companies' statements.

Good but Ofgem should be pressing hard to do this.


Ofgem will consider how quickly to act on any relevant recommendations of the Embedded Generation Working Group.



Ofgem will therefore have a number of important roles in relation to renewables. We will continue to investigate potential barriers to generation of electricity from renewables and take justifiable steps to eliminate any that are identified.



Document Para. Comment


Ofgem's view is that it should continue to operate price controls to ensure efficiency on the part of the companies involved.

Agreed, but with some caution. It has to be worthwhile for companies to be in the business.

Ofgem should satisfy itself that each major proposed items of capital expenditure should be properly justified and not "lost" in overall system value of capital employed.



In general Ofgem attempts to ensure that charges levied for the use of Transco, NGC and the PESs' services reflect costs.

True costs are the only basis for sensible decisions.


Ofgem will continue to consider how price controls on distribution and transmission companies can best provide incentives for companies to reduce transmission losses, including as part of our Information and Incentives Project. Including?? as part of our Information ....Is there a word missing?

Ofgem might undertake to develop a checklist to assist us in ensuring that environmental implications are properly addresses in our internal decision- making processes; this would be expected to mirror the way we take account of safety and other risk considerations, taking into account the need to balance the interests of present and future consumers.

Ofgem should undertake this check list but it will need to be reviewed as peoples expectations change.



This weighting as between social and environmental considerations was broadly backed by stakeholders during Ofgem's consultation on the EESoP3 during 1999, we intend to ensure that this balance is maintained during its implementation.



Document para.




Ofgem will continue to provide information on suppliers' energy efficiency schemes to organise in regular contact with consumers, and especially those in fuel poverty.

We will also encourage companies to do more to link the provision of energy efficiency advice with their debt prevention and management policies, and make clear and explicit the links between the environmental and social objectives of the current and future Energy Efficiency Standards of Performance.

With Government Ofgem will continue to work to demonstrate the links between the Energy Efficiency Commitment and other schemes promoting energy efficiency(for example, the New Home Energy Efficiency Scheme, Local Government responsibilities under the Home Energy Conservation Act etc.).


Ofgem might undertake to issue guidelines to companies on how they may best fulfil their social and environmental obligations consistent with the promotion of competition in supply. Ofgem should issue guidelines.



Ofgem is committed to promoting opportunities for all customers to improve their energy efficiency, including through these revised Codes of Practice, and in the way we monitor and enforce compliance with them.




Ofgem will continue to evaluate and approve suppliers green tariffs beyond the introduction of the percentage obligation for electricity from renewable


N.B. Absence of comment indicates agreement with the stated intention.

4. Apparent errors / omissions / editing suggestions.

Page 8 Para. 1.7

A personal opinion but it is better to be brutal and say "likely to be ambiguous" rather than "unlikely to be unambiguous".

Page 34 Para. 4.6

Should not ;" by Substituting high sulphur British coal for lower sulphur imported coal."

read "by substituting low sulphur imported coal for high sulphur British coal"

Page 34 Para. 4.7

Expand further on "The Environmental Agency requires that FGD units are run ahead of the non FGD units within portfolios" Surely the order merit rating governs (i.e. price).

Also comment on the proposal to run Drax with reduced emission control to increase generating efficiency and thereby reduce price bid. An explanation of the low rate of fitting FGD equipment to UK generating stations would be helpful and what Ofgem views are on this matter.

The above Document is available in word format as a zip file here

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