That is the stark warning contained in energy union Prospect's response to the consultation on changes to the RO for the period 2013-17. While supportive of the scheme's aim to encourage low-carbon technology, the union says the proposed banding structure dis-advantages co-firing biomass with coal or gas. This combination would be a short-term solution to the twin challenges of climate change and security of supply.
On behalf of 21,000 professionals in energy, Prospect negotiator Mike Macdonald said: "Prospect supports the principle of encouraging different technologies to reduce carbon dioxide emissions – so different rates for tidal power and offshore wind have a benefit. But we do not believe it is helpful to give different banding rates for different mechanisms using the same fuel.
"With the development of clean coal and carbon capture and storage (CCS) technologies, fields in which the UK could lead the world, we believe all three mechanisms for the use of biomass fuel – co-firing, conversion and new plant – should have a role to play in the UK's short and medium-term energy provision."
The union argues that the co-firing of biomass provides a relatively swift mechanism for reducing the carbon intensity in the short-term while retaining a solid base of plant capable of complementing intermittent renewable generation and the declining nuclear fleet.
Yet the proposed bandings disadvantage co-firing, or converting existing stations to biomass generation, compared to the support offered to new smaller scale biomass plants. Prospect believes this will put the industry in the perverse position of abandoning existing generation sites with established grid and transport connections.
Said Macdonald: "Under current plans the Drax plant near Selby would be disadvantaged as it is the biggest user of biomass in the EU. It is a co-firing facility using 15% biomass to 85% coal therefore providing 600MW of green electricity – several times larger than any stand-alone plant. The proposals could also impact on plans to convert E.On's Ironbridge plant in Shropshire and Centrica's gas plant at Brigg.
"Given the delays in developing economically viable CCS technology to support the continued use of coal, co-firing provides a valuable mechanism to provide a reliable electricity supply while sustaining an employment sector with the expertise and ingenuity that will be needed in the shift toward new low-carbon forms of generation."
The union's submission also calls for support for hydro-electric to be maintained at current levels and for measures to encourage new nuclear build.