Welsh renewable electricity targets

The Welsh Government has always been useless at energy policy; and when it comes to renewable power generation ambitions, other comparable countries are streaking away.
Below is a precis of my response to the recently closed WG consultation on the amount of Welsh renewable electricity capacity Wales should be aiming for. Their proposal is, enough power production to make Wales self-sufficient: considering the size of the natural resource, this is utterly pathetic.

Q1 Do you agree with Proposal 1, to retain the scope of the previous generation target, focussing on generating electricity to meet future demand?
Disagree. Wales should, like Scotland, be aiming to generate far more renewable electricity than necessary to satisfy its own demand.  The target: as much as possible.
The ethical argument: Wales has a huge renewable energy resource, and better average wind speeds and PV yields than many other areas of the UK: Wales needs to “pull its weight” within the UK by generating as much carbon-free electricity as possible.  This would also set the correct example globally: from each, according to their ability.  In any case carbon-free electricity is a sine qua non for carbon free transport and carbon free heating, i.e. we need enough of it to displace all energy currently supplied by natural gas.
  The business argument: more renewable energy generation means more economic activity; thus more jobs, inward investment, business rates, and tax revenue

Q2 Proposal 2 states: That the Welsh Government use the CCC’s Balanced Pathway as a basis for Wales’ electricity demand projections when setting renewable energy targets. We will also incorporate 9% transmission losses into our projections. Do you agree?
Disagree See my answer to Question 1: Wales’ electricity demand projections present far too low a renewables generation target figure.  The Welsh Government must be far more ambitious, in line with the country’s green power production potential.  This is the ambition of comparable countries e.g. Scotland, Ireland, and Denmark.

Q3 Proposal 3: The Welsh Government sets a target for us to meet the equivalent of 100% of our annual electricity consumption from renewable energy by 2035 and to continue to keep pace with consumption thereafter.  Do you agree?
Disagree As stated in my answer to Question 1, the intention to have renewable electricity generation capacity match Welsh electricity consumption projections is far too unambitious on both ethical and economic grounds.

Q4 Proposal 4: The Welsh Government sets a target for at least 1.5GW of renewable energy capacity to be locally owned by 2035, excluding heat pumps. Do you agree?
Agree – on the understanding that “at least” should be interpreted as, as much as possible. 

Q5 Proposal 5: Welsh Government sets a target of 5.5GW of renewable energy capacity to be provided by heat pumps by 2035, contingent on scaled up support from the UK Government and reductions in the cost of technology.  Do you agree?
I both agree and disagree Explanation: hand in hand with efficiency measures e.g. insulation of existing buildings, heat pumps are definitely the right technology to pursue in nearly all heat demand sectors. They offer a far better a solution than burning green hydrogen, except for ultra-intense demands such as steel making.
  But, except for industrial applications, people or businesses should not be expected to buy heat pumps: for replacing gas central heating boilers, this is the wrong commercial model.
  Space heating heat pumps should be provided by energy companies on a rental basis, inclusive of maintenance and repair/replacement as required; furthermore, to ensure that heat pumps are always run at maximum possible efficiency, energy companies should be required to provide the electricity to run the heat pump, and charge the customer per kWh of heat supplied.  N.B. such an arrangement is essential to realising large scale smart grid operation.

Q8 We have asked a number of specific questions. Do you have any other issues that you wish to bring to our attention, which are not captured by the above questions? Please provide evidence to support your answer.
ISSUE 1
In all of the discussions about Welsh renewable energy policy, nothing has been said about the balance of payments implications.  This country aspires to continually strengthen its national identity and, regardless of the politics of independence, to be recognised as a country within the UK and not just a region.  In this respect, though, it continues to fall further and further behind Scotland and indeed the English South-West.   Without its own Welsh Digest Of Energy Statistics and its own Welsh Balance of Energy Payments, progress is impossible: you cannot control what you do not measure.  And you cannot understand how our current consumption of fossil fuels causes such a huge drain of money from the Welsh economy.   Furthermore, such information is crucial to understanding just how much Welsh renewable energy generating capacity is not owned within the UK, never mind Wales itself: only once we have such statistics can we start to make the general Welsh public realise exactly where we stand at the moment – and get their support to start making the changes necessary for Wales to be properly, and profitably, in control of its own energy future.

ISSUE 2
Nothing has been said in this document about the means by which additional renewable energy generation capacity might be secured.  Even if this is not within the scope of the current consultation, it would surely have been relevant to remind consultees that the Welsh Government could easily and with great economic benefit make any renewable generating targets much more readily achievable by using its planning powers.
The Welsh Government should
1) Require all new houses and commercial buildings to have roof fitted PV.
2) Require all existing houses / commercial buildings undergoing major repairs or refurbishment, or being extended, to have PV fitted on their roofs.
3) Expand the scope of permitted development rights for wind turbines and PV – such that any house or business (including most importantly all farms), would not require planning permission to install renewable energy (NB not just renewable electricity) generating equipment sufficient to make it at least net zero based on annual carbon emission calculations.