In guidance under the Environment Act 1995, the Scottish Secretary required SEPA to "contribute to the Government's goal of sustainable development," and to take an holistic, long-term perspective in pursuing this objective. Similar guidance has been issued to the Environment Agency.
Neither regulator has yet got to grips with what these broad, and potentially far-reaching, requirements mean in practice. But SEPA has now begun to stick its head above the parapet.
In July, the regulator gave evidence to a planning inquiry into PowerGen's proposed 700MW gas-fired power station at Gartcosh, Lanarkshire. Opponents of the project point to an existing surplus of generating capacity in Scotland, and claim that it will threaten jobs in the coal mining industry.
SEPA took care to maintain a "neutral stance" over whether the proposal should be given consent. But it expressed concern that PowerGen had made "misleading" statements in its defence of natural gas as a sustainable fuel.
SEPA accepts that the UK's reserves of gas will last at least 50 years - but points out that demand for gas has risen by 20% since 1991. Rob Ebbins, Head of Policy Co-ordination (Air), told the inquiry that SEPA was concerned that natural gas should be "used in the most appropriate way".
Mr Ebbins noted that modern gas-fired stations can generate electricity with high efficiencies of around 55% - but direct use of gas in modern domestic condensing boilers and industrial combined heat and power plants can achieve efficiencies of around 90%. SEPA also noted that gas has "considerable value" as a chemical feedstock and vehicle fuel.
Growth in gas-fired generation is the main reason why the UK has been able to reduce its carbon dioxide emissions below 1990 levels. However, Mr Ebbins argued that this benefit "may obscure the need for investment in energy conservation and renewable sources of energy." Indeed, SEPA said, "it is not evident that [the Gartcosh] station would replace any of the more polluting generating equipment within the UK."
In conclusion, SEPA warned, the "continued increase in available capacity [through new gas-fired stations] will reduce the incentive to use energy efficiently." Furthermore, "it is important that the current availability of gas does not obscure the need to make positive decisions to promote renewable resources on a much larger scale than is currently the case."
SEPA's bid to raise the issue of sustainable development contrasts with the Environment Agency's approach to the power generating sector in England and Wales. The Agency has set sulphur dioxide emission ceilings for companies operating existing coal- and oil-fired plant (ENDS Report 254, pp 18-20 ), but appears content to leave compliance options to the market. Because one way of reducing SO2 emissions is to switch to gas, the emission limits are expected to drive a further expansion of gas-fired capacity.