Consultation question: Considering the information presented in this call for evidence paper, and your own knowledge and experience, what are your views on the extraction of coal in Scotland?
Our response: The Welsh Government's most recent policy statement on coal should provide a starting point for the Scottish Government to build upon (https://gov.wales/coal-policy-statement-html) in developing its own policy, as there are clear and relevant parallels between both Governments.
Both Wales and Scotland has a long legacy of suffering the localised impacts of environmental blight and hazardous conditions of coal mining, with nearby communities rarely seeing a significant share of the economic benefits. Wales is still littered with unrestored or poorly restored coal mines. It was reported that only this year are the final abandoned coal mines in Scotland being restored - again, often to revised, lower standards that what was promised nearby communities due to insufficient restoration bonds.
Now more is known about climate change, both Wales and Scotland have led the way in developing progressive policies and practice to realise their ambitious targets. This cannot include viably include coal, which is worse in CO2 emissions than natural gas and oil in its conversion factor to energy. The EIA Pathways to Net-Zero report make this very clear, underscoring that no new coal mining for any purpose can be part of a pathway to Net-Zero by 2050.
A critical part of that report is no new coal mining for any purpose. The report goes further to explicitly include coking coal for steel in this prohibition. Port Talbot Steelworks in South Wales and British Steel in England are the 2nd and 3rd largest single-site sources of CO2 in the UK - because they burn coal. Any policy that differentiates between the extraction of coal for energy production and coal for steel production, ignores this growing threat to meeting climate targets across the world. It would also ignore the rapidly escalating developments around the world in decarbonising the steel industry. Green steel is on its way, with the first delivery of commercial quantities made from Sweden in 2021. Unfortunately, once investors have opened a coal mine, they will seek return on that investment and find alternative markets for the coal, or laggard steelworks that still rely on coal in the future. So permitting new coal mining for steel will prop up the biggest polluters and discourage transition to new technology and practices.
There is no viable future for any of us that relies on coal to get us there. Scotland should be using its just transition fund to skill its inhabitants in the industries of the future, not ploughing people into the industries that destroy that future.
Coal Action Network is concerned by the content of the proposals:
The independent verification of applicants’ fossil fuel emissions was to be introduced to improve the reliability of this important information, and give confidence to the data reported by companies given access to the UK energy generation market. The postponement of this introduction therefore lengthens the doubts cast over the claims made by applicants to the capacity market. The Government claims the reason for the postponement is that there may not be enough independent verifiers in time for applicants to meet this condition. This is a failure in preparation on the part of the UK Government, to rigorously implement the climate policy it created and meet its own targets. We would expect this to be resolved well before the next capacity market auction as non-independent accounting for carbon emissions cannot become normalised or it will risk under-representation of the emissions of the CMUs and the UK overall.
The amendment to allow mothballed plants to bid in the upcoming capacity market auction is concerning where it may increase the potential for recently mothballed coal power plants to come back online and result in a higher proportion of coal within the UK energy mix 2023-24, until the 2024 coal phase-out date begins to have effect. We categorically oppose any move that slows down or reverses the declining use of coal for power in the UK—including the recent announcement by BEIS to delay the scheduled closure of West Burton coal fired power station. The UK Government states that it is necessary to allow mothballed power stations to participate in the upcoming capacity market auction to increase competition, which it hopes will reduce the cost of electricity generation—particularly when there are greater demands on the grid, such as during the winter months.
If the UK Government invested in renewable technology development and deployment to the same extent that it historically subsidised the fossil fuel industry, competition might realistically be fulfilled by renewable power generators instead. The current challenges are due, to an extent, the policy failure of this government and successive governments to put glib speeches on climate change into action. Moving forward, we urge the UK Government to avert this energy generation challenge recurring with a package of climate-friendly measures, including:
We are concerned that the 2024 coal phase-out date is being used by the UK Government to deflect criticism for its support of using coal up until that date, when what we need is the most rapid phase-out of coal that is possible as the UK careers further from its climate targets. This attitude has been captured in comments made this year by two leading cabinet Ministers, “Net zero is by 2050. We are not at 2050 yet.” – Jacob Rees-Mog, and “Give over. We’re still committed to phase out by Sept 2024.” – Kwasi Kwarteng (in relation to extending the coal powered operations at West Burton).
Finally, as we have commented before in previous consultations, the 2024 phase-out date should be legislated on, to ensure that it happens. As this consultation and other recent moves by this government show, this or any future administration is not currently prevented from taking steps which cast doubt on or undermine that commitment.
