Select Committee on Environmental Audit Memoranda


Memorandum from English Nature


  1.1  English Nature is the statutory body that champions the conservation and enhancement of the wildlife and natural features of England. We work for wildlife in partnership with others by:

    —  advising—Government, other agencies, local authorities, interest groups, business, communities and individuals on nature conservation in England;

    —  regulating—activities affecting the special nature conservation sites in England;

    —  enabling—others to manage land for nature conservation through grants, projects and information; and

    —  enthusing—and advocating nature conservation for all and biodiversity as a key test of sustainable development.

  1.2  We have statutory responsibilities for nationally important nature conservation sites—Sites of Special Scientific Interest (SSSI), the most important of which are managed as National Nature Reserves.

  1.3  Through the Joint Nature Conservation Committee, English Nature works with sister organisations in Scotland, Wales and Northern Ireland to advise Government on UK and international nature conservation issues.


  2.1  English Nature's interest in the electricity sector derives from the impacts of emissions from electricity generation, and from the location of generating plant and associated infrastructure (including transmission), on biodiversity and natural features. Land take can be significant, as can water demands for cooling purposes and temperature effects from cooling water outflow. Gaseous emissions, especially carbon dioxide, sulphur dioxide and nitrogen oxides, have made major contributions to climate change, acidification and eutrophication.

  2.2  The severity of these impacts is clearly linked to the prevailing policy context under which electricity is generated. In the 1970s and 1980s, the focus was on large coal-fired power stations, supplemented by nuclear, but subsequent privatisation has led to important changes. Contemporary energy policy is becoming increasingly gas-based, with moves towards more local energy production, greater use of renewables and less reliance on nuclear.

  2.3  The policy shift from centralised coal-based electricity generation towards distributed generation based on gas and renewables is, on the whole, beneficial to biodiversity, as the environmental burdens of carbon, sulphur and nitrogen from the industry continue to decline. However, the potential environmental impacts of schemes which could be proposed under the renewables umbrella should not be overlooked, as some may pose threats to the nature conservation resource.


  3.1  English Nature believes that investment in renewable energy, coupled with standards that include environmental protection, will support Government's environmental objectives and energy policy aims. Renewables can make a considerable contribution to sustainability and the achievement of targets for the reduction in emissions of greenhouse gases (Kyoto and domestic) and acidifying gases, both of which have damaging impacts on wildlife.

  3.2  English Nature recognises that all sources of energy will have some form of environmental impact. There will be critical limiting factors relevant to renewables, and these must be considered in relation to environmental protection and management, including the conservation of wildlife and natural features.

  3.3  The potential impacts of establishing, operating and decommissioning renewable energy schemes is, therefore, of concern to English Nature, and environmental assessment of project proposals in relation to sensitive and protected sites is clearly necessary. The renewables industry must ensure that the special interest features of SSSIs, particularly those of international importance, are not threatened by their operations, and that appropriate management is delivered to maintain these features in favourable condition. English Nature also recommends that the technical development of renewables should be accompanied by monitoring and research programmes, in which assessment and mitigation of impacts would be a key part.


  4.1  English Nature advocates that sustainable development principles should underpin all areas of policy development (which should also be subject to strategic environmental assessment) and believes that the concept should be placed at the heart of policies for all sources of energy, including renewables. Biodiversity is a key indicator of sustainability, and gives a measure of the extent to which environmental sustainability has been achieved.

  4.2  The land use planning systems requires modification to accommodate renewables adequately, and clear guidance, including information on environmental considerations, needs to be provided for developers, regulators and planners. Although not in Government's programme for revision, English Nature believes that PPG22 Renewable Energy (February 1993) should be amended to give clearer guidance for development plans when considering the "contribution their area can make to meeting need on a local, regional and national basis". Encouragement should also be given to addressing renewable energy projects strategically through the forward planning process, rather than through development control.

  Plans should identify areas where, because of environmental considerations, renewable projects would be difficult to reconcile with other policy considerations. The recent Government initiative to develop regional targets for renewable energy through Government Regional Offices is welcomed in this context. Here, early identification would best be made through Regional Planning Guidance, drawing on the new Regional Sustainable Development Frameworks.

  4.3  The development of renewable energy technologies in the UK since 1990 has been greatly assisted by the protected market niche provided through the Non Fossil Fuel Obligation (NFFO). English Nature was concerned, however, that the NFFO contracting process appeared to be sealed from the environmental policy framework promoted by Government, in which all policies and programmes are appraised for their environmental implications. English Nature believes that continued support is needed to "force the pace" in the renewables industry and equip suppliers for the eventual transition into the open electricity market, but recommends that contracts under the new Renewables Obligation should be awarded in the light of the environmental costs attached to each.

  4.4  Finally, English Nature believes that the cost of electricity should reflect the environmental impacts of its production. English Nature therefore supports, in principle, economic instruments to control the business use of energy, provided that these are designed to achieve environmental objectives. Economic instruments should be aimed at reducing overall levels of energy use and providing incentives to support more environmentally acceptable methods of electricity generation.

January 2001

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