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TRANSCRIPT
Key Challenges for the UK Energy Sector Post-Election
Simon Virley CB
02 July 2015
UK Chair, Energy and Natural Resources
3 © 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
The Energy Trilemma The balance between priorities is shifting…
Security of supply
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Security of Supply – import dependence Britain’s import dependence is rising…
Source: DECC ‘Digest of UK Energy Statistics 2014’ (31 July 2014)
Net exporter
Perc
enta
ge o
f ene
rgy
supp
ly
Net importer
2010 2000 1990 1980 1970
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-‐30
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40
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10
0
-‐10
-‐20
5 © 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
North Sea oil & gas Prices below breakeven for many operators…
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r Ene
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ccid
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onoc
oPhi
llips
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aers
k O
il &
Gas
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ange
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usky
To
tal
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onM
obil
BH
P B
illito
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er
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vron
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etro
nas
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atho
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acifi
c R
ubia
les
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robr
as
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toil
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field
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oble
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rgy
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bury
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alifo
rnia
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ourc
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OO
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phy
Oil
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ll D
evon
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OIL
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enov
us
Gaz
prom
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TTE
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il S
earc
h A
pach
e P
etro
Chi
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Enc
ana
Ros
neft
Sin
opec
Cor
p
US
D/b
bl
Brent price required for upstream portfolio to be cash flow neutral
Average 2015 price to date
Source: Capital IQ, Wood Mackenzie, KPMG analysis
6 © 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Power margins Capacity margins are tightening…
Loss of load expectation
Source: Ofgem ‘Electricity Capacity Assessment Report 2014’ (30 June 2014)
7 © 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Decarbonisation – carbon budgets UK Carbon Budgets are legally binding…
UK GHG emissions against legislated budgets and 2050 target
MtC
O2e
2050 target (inc. IAS) UK GHG emissions Legislated carbon budgets
Source: Committee on Climate Change, Reducing emissions and preparing for Climate Change: 2015 Progress Report to Parliament, July 2015
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Renewable electricity Deployment is increasing…
Source 1 (Actual): DECC Statistics Source 2 (Forecast): Target range for 2020 is based on DECC estimates
Target range for 2020
0%
5%
10%
15%
20%
25%
30%
35%
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Renewables share of electricity generation
Actual Forecast
9 © 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Affordability – CfD costs The race is on…
Source: KPMG estimates based on first CfD auction outcome (February 2015)
140
114 115
79 90
82.5 89.5
160 160
[CELLRANGE] [CELLRANGE]
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Administrative price
Auction price Administrative price
Auction price Administrative price
Auction price Price Price Price
Offshore wind Solar Onshore wind Hinkley Point C (nuclear)
Carbon capture and storage
Tidal
£/M
Wh
Costs of different renewable technologies under the CfD regime
Estimated range
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Levy Control Framework (LCF) The cost of green energy on energy bills…
Source: DECC ‘Annual Energy Statement 2014’
7.6
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Levy Control Framework
Actual expenditure Planned expenditure Projected expenditure (KPMG estimates)
11 © 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
CMA recommendations Potential outcomes….
CMA ‘Statement of Issues’ in February 2015:
• Vertical integration – no major competition issues
• Wholesale liquidity not distorting competition
• Generators do not have ability or incentive to exercise market power
But CMA have expressed concerns about:
• Weak competitive pressure on standard variable tariffs (the ‘sticky customers’)
• Regulatory complexity may be a barrier to entry
• Some market rules may be distorting competition
12 © 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Technology Disruptive change is coming…
13 © 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Conclusions
• ‘The State is Back’ in energy
• Affordability is key
• Real challenges ahead on security of supply
• What is the plan now for decarbonisation?
• The ‘Agile Utility’ – can the utilities respond?
• Solutions may be both local and international
The KPMG name, logo and “cutting through complexity” are registered trademarks or trademarks of KPMG International.
© 2015 KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Click to add title
Strategic energy challenges for the UK: a research perspective
Jim Watson, Director, UKERC
Westminster Energy, London, 2nd July 2015
3. Innovation systems & development
Analysis of Committee on Climate Change emissions pathway to 2030: § Methods for appraising uncertainty § Instrumental uncertainties for CCC
pathway in power, heat and transport § Systemic uncertainties: natural
resources, public attitudes and ecosystem services
§ Some attention to ‘alternative’ higher carbon pathway
Energy strategies under uncertainty
3. Innovation systems & development Energy strategies under uncertainty
Source: Funtowicz and Ravetz
Click to add title Energy strategies under uncertainty Instrumental uncertainties, e.g.
Complexity Impact Actions By who? Commercialise low carbon electricity technologies
• Long term policy support
• Demonstration funding for CCS
• Evaluations and learning
• Govt and innovation funders
• Businesses • Research
community
Heat pump performance
• Demo & deployment incentives
• Learning & engagement with consumers
• Government • Innovation
funders • Citizens /
businesses • Research
community
Click to add title Energy strategies under uncertainty Instrumental uncertainties, e.g.
Complexity Impact Actions By who? Commercialise low carbon electricity technologies
• Long term policy support
• Demonstration funding for CCS
• Evaluations and learning
• Govt and innovation funders
• Businesses • Research
community
Heat pump performance
• Demo & deployment incentives
• Learning & engagement with consumers
• Government • Innovation
funders • Citizens /
businesses • Research
community
Click to add title Energy strategies under uncertainty Systemic uncertainties, e.g.
Complexity Impact Actions By who? Fossil fuel availability and price
• Energy efficiency • Diversity • Carbon pricing
• Governments and regulator
• Businesses • Citizens /
businesses Ecosystem service impacts
• Stronger evidence base
• Decision making tools
• Government • Businesses • Research
community
Public attitudes to energy system change
• Genuine engagement with public on energy system change
• Government • Citizens
Click to add title Energy strategies under uncertainty Systemic uncertainties, e.g.
Complexity Impact Actions By who? Fossil fuel availability and price
• Energy efficiency • Diversity • Carbon pricing
• Governments and regulator
• Businesses • Citizens /
businesses Political commitment to a low carbon transition
• Reinforce long-term policy framework with specifics
• Confirm the fourth carbon budget
• Government & Parliament
• Businesses • Citizens
Public attitudes to energy system change
• Genuine engagement with public on energy system change
• Government • Citizens
Click to add title Energy strategies under uncertainty Systemic uncertainties, e.g.
Complexity Impact Actions By who? Fossil fuel availability and price
• Energy efficiency • Diversity • Carbon pricing
• Governments and regulator
• Businesses • Citizens /
businesses Political commitment to a low carbon transition
• Reinforce long-term policy framework with specifics
• Confirm the fourth carbon budget
• Government & Parliament
• Businesses • Citizens
Public attitudes to energy system change
• Genuine engagement with public on energy system change
• Government • Citizens
Click to add title UK energy security assessment
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Energy Security ‘defined’…
• ‘There is no perfect definition of energy security’, DECC 2012 • Energy security has different dimensions
– Short-term vs. long-term – Physical vs. price – Different fuels vs. electricity – Production/generation vs. transportation/transmission – Demand volatility / predictability short and long term for transport,
power and heat
• ‘When discussing energy security the Government is primarily concerned about ensuring that consumers have access to the energy services they need (physical security) at prices that avoid excessive volatility (price security)’, DECC 2012
WEF 2015-16 Structure & Actions
WEF Network Industry Members Trade Associations NGOs Academia
Government liaison DECC BIS + Infra UK Cabinet Office Ofgem
Parliament liaison DECC SelCom EAC SelCom POST All Party Parl. Groups
Policy Pillars for Energy Security
• Resilience to systemic and network shocks
• Energy efficiency measures and innovation
• Maximising economic production of oil & gas • Reliability of global energy markets
• Reliable, diverse networks for reliable supply
• Decarbonising the strategic supply mix
WEF Series 15-16: Issue Coverage
1 - Cross-Cutting Policy Preview 2 - pre-COP-21 Carbon Assessment 3 - Annual UK Oil & Gas Review 4 - Supply Risks, Security & Resilience 5 - Review of Nuclear Delivery & Risk 6 - Review of Smart Energy: Smart Cities, 7 - Review of Renewables Deployment 8 - European Energy Risk Summit
Westminster EnergyTM
Energy Security Strategy
UK Energy Security Strategy – key questions WEF has raised around risk: The suite of risks which affect UK energy security are becoming increasingly dynamic and interconnected. The need to understand and to manage an increasingly interconnected range of energy security risks also raises a number of questions for policymakers and industry: 1. What risks lie outside business-as-usual planning that would materially shift UK energy
security? 2. What fundamental industry and market shifts could create new risks? 3. To what extent are similar risks, or patterns of risks, affecting a number of UK energy
sectors? 4. How can policymakers, industry and NGO sectors better identify and share information
concerning the range of strategic risk factors affecting UK energy security? 5. What political and corporate actions does the UK have the capacity to take to manage
these risks?
Outputs from ‘Risks to UK’s International Gas Supply Security’ Research (May ‘15)
Top 5 Issues to track // for HMG to focus on in the next 6 months… • We cannot yet be confident that UK Continental Shelf (UKCS) gas production will
develop, or even endure, at the levels aspired to by Government or industry.
• We are confident that, overall, the UK will be well-supplied with gas in the long term given its diversity of supply sources. However, there is a risk that key elements of the UK’s gas network may deteriorate in the next 5 years.
• There is a risk that significant declines in investment in Russia’s existing gas infrastructure could result in gas supply interruptions and / or shortages within parts of Europe during the next 5-10 years.
• There is a risk that the UK’s unconventional, shale gas industry will not develop at a
commercially viable rate. • There is widespread concern that the new Parliament’s ‘knowledge base’, and time
constraints, may hinder the balanced analysis and support that UK energy strategy requires, given the complexity of the issues ahead.
Questions to address in today’s discussion
Market challenges
Research focus
Upstream: production & decommissioning
Refining challenges
Downstream, and the demand side
Cost & Operational challenges
Talent & Skills requirements
Regulatory challenges
Policy priorities
Key Reason for Decline • Ageing infrastructure
• Designed for 25 years, has been in place for 40 years • Working in a hosDle marine environment • Much equipment is obsolete
• Decommissioning liability remains largest barrier to transfer of key infrastructure plaIorms • Decommissioning Deeds have lowered security requirements by reducing tax uncertainty
• Cost uncertainty remains huge • Need for comfort to current owners makes security provision more burdensome
North Sea Cost Estimate
• EsDmates of UKCS spend on decommissioning tripled in five years • $16bn in 2006 • $50bn in 2011 • Oil & Gas UK Survey
• AcDvity will ramp up to 2020 • Timing is becoming less sensiDve to oil price
• Survey for 2012 shows 15% increase in costs
• This equates to $90bn for the whole of the NW Europe
One Reality A major part of the decommissioning cost will come from the UK tax payer in the form of PRT refunds and CT allowances. This reality has come into sharp focus with the
recent issue of Decommissioning Deeds securing current levels of tax relief.
Two Responsibilities We have a responsibility as an industry to decommission the North Sea as cost effecEvely as possible. This will only happen if we opEmise learning between projects and maximise co-‐ordinaEon
of facility removal campaigns.
Two Responsibilities We have a responsibility as an industry to maximise recovery from the North Sea before we remove its precious infrastructure.
This will only happen if we can reduce the amount of dead capital Eed up in
decommissioning security.
Three Questions
How do we maximise the learning from all decommissioning acEvity to the benefit of all Operators?
Three Questions
How do we ensure that human resources and major equipment are deployed efficiently in well co-‐ordinated campaigns of acEvity?
Three Questions
How do we build on the Decommissioning Deeds to further reduce the cost of
decommissioning security?
A Radical Solution
• A new generaDon of Owners of super-‐mature fields • Primary business is decommissioning • In-‐house capability for:
• Well P&A • PlaIorm Removal and Disposal
• Li]le or no outsourcing of key acDviDes • Ability to provide adequate decommissioning security to previous owners without hindering investment
Hurricane Downers • Hurricane Katrina summer 2005 • Seven bp plaIorms destroyed • Grand Isle and West Delta fields GOM • Operator managed recovery for a year • Then brought in Wild Well Control Inc. • WWC managed recovery & remediaDon • Turnkey contract • Transfer of operatorship and license
Bullwinkle • Gulf of Mexico • Green Canyon Block 65 • Installed in 1988 • 150 miles from New Orleans • 1,353 c water depth • Shell operated
• Deepest fixed leg producEon pladorm on the Outer Shelf • A total of 29 wells to plug and abandon
Bullwinkle
• Superior Energy Services took 100% ownership in Feb 2010. • Superior is Wild Well Control parent company. • Field was producing 4,000boepd. • Sold 49% to Dynamic Offshore Resources. • Dynamic operate the field. • At the end of economic field life:
• Superior will P&A 29 wells. • PlaIorm will be removed. • Shell will pay Superior a pre-‐agreed undisclosed amount.
Current Heavy Lift Stock
Vessel Lic capacity Build date
Hereema Thialf 14,200t 1985
Saipem 7000 14,000t 1983
Hereema Hermod 8,100t 1978
Hereema Balder 6,300t 1978
• The heavy lic vessels acDve in NW Europe are:
• By 2015, every vessel will be beyond its 30 year design life • The lic capaciDes shown are maxima at minimum load radius
• None of these could remove the 3000t Dunlin main support frame • These vessels can only lic small jackets clear of sea level • They cannot lic jackets designed for barge launch
• NW Hu]on jacket removal required >40 lics • TML could accomplish this with 2 lics
• An average jacket and topsides requires 150 days of barge Dme • Limits a barge to one asset per summer season
The TML System
• The Twin Marine Licer System (TML) is designed to install and remove topsides, jackets and subsea structures
• The system has a maximum licing capacity of 34,000 tonnes • PlaIorms are removed in far fewer lics than with crane barges • Offshore manhours are reduced by about 80% • Cost overrun risk is constrained • HSE exposure is significantly reduced
• Water depth independent with a 2.5m significant wave height • TML can remove almost all North Sea topsides in a single lic
Role of Insurance
• TML transfers most deconstrucDon from offshore to onshore • Cost overrun risk is significantly reduced • The Decommissioning Company has an insurance product:
• designed and led by Munich RE • provides performance guarantee for system capability • underpins fixed price plaIorm removal offering
• Price certainty will be used to build TML market share: • a]racDve to Operators both large and small • can be used to fix financial security provision • can be purchased by buyers or sellers of mature oil producDon
United Kingdom Petroleum Industry Association
2nd July 2015
Issues of refining in the UK: challenges ahead
A key issue is that to 2030 and beyond, oil is a major source of energy in the UK..
Industrial
Transportation
Power Generation
Nuclear
Coal
Energy security and resilience risk: UK
Net imports
Net exports Net exports
High Risk MOSES line
% inland consumption required to be covered by imports in a 6 refinery scenario after 2015.
% inland consumption required to be covered by imports in a 3 refinery scenario after 2015.
Net imports
Scenarios based on the IEA's Model of Short Term Energy Security (MOSES) -‐ 'net import' indicator -‐ developed to evaluate national energy security risks and resilience. 45% import dependence benchmark = high risk
A burdensome legislative background for UK refiners
Crude costs and income from products UK refining operating costs
Indicative graph. Margins shown are indicative, obtained under favourable market conditions. Source: UKPIA, Wood Mackenzie
By the end of 2016 UK Refining capacity will have reduced by one third compared to 2006.
Closure of UK refineries increases global emissions
(Source: VividEconomics Report “Carbon leakage prospects under Phase III of the EU ETS and beyond”, Refining Case Study, June 2014. CO2 emissions calculated using methodology and factors included in JEC – Joint Research Centre-‐EUCAR-‐CONCAWE collaboration report “Well-‐to-‐tank Report”, Version 4a, April 2014.)
UK and EU refining is on average less emissions-‐intensive (0.21 tCO2 per tonne of product) than non-‐EU refining (0.29 tCO2 per tonne of product) = Carbon leakage exceeds output leakage: every 100 units of CO2 emissions reduced in the EU are replaced by 135 units outside the EU
Quantity leakage
Emissions intensity differential
Emissions leakage
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NaEonal Grid | Balancing the System
Cordi O’Hara, Director UK Market OperaDon, System Operator
Commercial and DomesEc Customers
Electricity DistribuEon Networks
NaEonal Grid Gas DistribuEon UK
Other Gas DistribuEon Networks
NaEonal Grid Transmission UK (Electricity & Gas)
NaEonal Grid | who are we?
Electricity Generators Gas Producers and Importers
System Operator
2014/15 | a milder winter than expected
§ Mild weather; lower than average demands at peak Dmes
§ Actual demand vs available generaDon was adequate across winter
§ Full imports from Europe § New balancing services were not
needed § Gas Supplies from the UKCS and
Norway close to our forecasts and similar to levels experienced in 2013/14.
§ Tension between Russia and Ukraine did not lead to any disrupDon to supplies to the UK.
2015/16 | it was always going to be Dghter…but we have the right tools
1 Market Actions
Communication (NISMs) Interconnector trading
Market provision of capacity
Non BM STOR
2 New Balancing Services DSBR and SBR
3 Emergency Actions
Voltage reduction
Max gen service
Interconnector emergency assistance
Demand reduction
Demand
Margin
De-rated Generator capacity
Tools & products available
§ Secured 2.56GW of addiDonal electricity reserve (DSBR/SBR)
§ Lower cost per unit than the previous winter.
§ The tender round also shows growth in the market for demand side balancing reserve
Embedded GeneraEon
Demand Side Response
Industrial DomesEc
Passive Demand
DomesEc Industrial
Future balancing | challenges and opportuniDes
ConvenEonal GeneraEon
Inflexible GeneraEon
Intermioent GeneraEon
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InterconnecEon
Our world is changing| so is the energy system that powers it
§ NaDonal Grid led demand side seminar – a significant audience from the demand side market
§ We will revoluDonise the way we balance the UK's electricity system -‐ by 2030 we will rely on well over 50% of the Dme on demand-‐side measures for securing supplies
To conclude|the UK’s energy future is changing
§ Stakeholder engagement is key to ensure a wide range of scenarios are planned for.
§ We have the right tools in place to balance the system.
§ There are opportuniDes for innovaDve soluDons e.g. power responsive
Age profile of the power sector • Overall, 33% of the power
sector’s workforce is aged over 50 years
• This proportion increases for higher skilled job roles
• The contractor supply chain employs about half as many people as the asset owners
• Two-thirds of them in Level 1 and 2 roles and with a slightly younger age profile
Leavers from power sector (technical & engineering workforce only)
• The number of retirements during each year will double by 2026
• From 345 in 2015 to 700 in 2026
• Natural wastage is modelled to run at a steady 2.6% per year
• But this could increase as competition for scarce skills intensifies as capital investment programmes crank up across a number of adjacent sectors
• Added to this increasing replacement demand year-on-year will be the additional labour demands by smart grids, electric vehicle infrastructure, etc. in the early 2020s
Skills shortages already exist...and more to come??
• Increasing competition for talent • From within the energy
sector • £275bn investment over 8
years in infrastructure new build and refurb
• From outside of the energy sector
• Engineering and infrastructure construction
• Rail electrification • Advanced manufacturing
• From overseas • Many developed countries in
the same situation as the UK • Developing countries
building energy infrastructure for the first time
• Job titles on the UK’s Shortage Occupation List relating to the electricity transmission and distribution industry:
• Project Manager; Site Manager • Power System Engineer; Control
Engineer • Protection Engineer; Design Engineer • Planning/ Development Engineer • Quality, Health, Safety and Environment
(QHSE) Engineer; Project Engineer • Proposals Engineer; Commissioning
Engineer • Overhead Linesworker; Substation
Electrical Engineer • There are other job titles on the list
relating to adjacent sectors • eg. geo-science related roles,
mechanical engineer, chemical engineer • Total demand across these job roles =
c150 per year • Low volume / high cost to replace
Supply-side issues – Engineering in general
• UK economy will need 182,000 people per year with engineering skills through to 2022
• To meet this demand, the number of engineering apprentices and graduates entering the industry will need to double
• To address the shortfall: • Double the number of young people studying
GCSE physics as part of triple sciences • In 2014, 61,641 girls achieved Physics A*-C grade
GCSE • Yet only 5,916 (9%) achieved an A*-C grade at A level
• A two-fold increase in the number of Advanced Apprenticeship achievements
• Provision of careers inspiration for all 11-14 year-olds
Source: EngineeringUK
Supply-side issues • Sector image
• Poor for attracting new young talent • Market certainty
• Particularly in renewable energy technologies • Difficult to invest in long-term skills development (e.g. 3-
year Apprentices) • STEM education
• Need to increase number of students following STEM subjects
• Especially females and BME groups • Need to increase number of STEM graduates that enter a
STEM job (rather than financial services, consultancy, etc.)
• Multi-utility solutions • More flexibly skilled workforce
Building by numbers • Value of infrastructure investment = £466bn over eight years • Energy sector’s share of this = £275bn • The infrastructure construction sector is forecasting wage
inflation of 3.8% per year (double that forecast for the economy as a whole by EY)
• Over the next decade, the entire energy and utility sector will need to recruit around 180,000 workers (c16,000 per year)
• The cost of maintaining the electricity distribution workforce alone over the next eight years (13,000 recruits) is estimated to be £370million
• Cost of not renewing the workforce: • Increasing competition for talent amongst partners • Increased delivery costs • Delays in delivery
So… what are we doing about it?
• Address the market failure by: • Greater and clearer focus on:
• Attraction and sector image – especially of young people • Recruitment – using a more targeted and diverse range of entry
routes • Diversity – increase female and BME representation
• Collaboration • Working together, with the supply chain, to identify collective
challenges and solutions • Procurement Accord
• Use the procurement process to promote and recognise the importance of skills across the sector
So… what are we doing about it?
• Energy & Efficiency Industrial Partnership • Energy & Efficiency Independent Assessment Service • National Skills Academy for Power • Talent Source Network • Think Power • SME Networks • Workforce Planning • EUSR
The Manifesto: Key Commitments • A focus on energy security (diverse supplies; domestic shale extraction;
gas; nuclear and good value renewables)
• Stopping subsidy for on-shore wind
• Safe development of shale with focus on community benefits and sovereign wealth fund
• Pushing for more new investment in UK; continue to support North Sea oil and gas production
• Driving competition to get a good deal for consumers and keep bills low: implementing the recommendations of the CMA review
• Targets for Smart Meters for homes and businesses and for energy efficiency in homes
83 Westminster Energy
Announcements so far……. • An Energy Bill announced in the Queens speech
• Bring forward primary legislation to close the renewables obligation for on-shore wind early (a grace period for those who have already got planning permission, grid connection and land rights);
• Devolve planning decision making for on-shore wind to local authorities • Establishing the Oil and Gas Authority as an independent regulator
• Energy Elements of the Scotland Bill
• Commitment of existing funding of £50m to the Climate Development Finance Facility for renewable projects in developing countries
• Heat network projects are being tested across the UK part of DECC’s Heat Network Small Business Research Initiative
• Parameters for the Capacity Market Auction
84 Westminster Energy
Early priorities and commitments • Securing a global climate deal in Paris is the Secretary of States highest
priority this year. Taking every opportunity to press for an agreement that is ambitious, with regular reviews to further increase ambition and effective rules to allow us to track progress.
• A focus on consumer bills - keeping bills down while decarbonising at the lowest cost possible
• Commitment to the Climate Change Act
• Delivering Manifesto commitments
85 Westminster Energy