APPENDIX 9
Memorandum submitted by English Nature
1. INTRODUCTION
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;
— 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. CONTEXT
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. Gaseous emissions, especially carbon dioxide, sulphur
dioxide and nitrogen oxides, have made major contributions to
climate change, acidification and eutrophication. Land take can
also be significant, as can water demands for cooling purposes
and temperature effects from cooling water outflow.
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. RENEWABLES
AND NATURE
CONSERVATION
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 (see Annex 1). 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. EC BIRDS AND
HABITATS DIRECTIVES
4.1 At present in the UK, all identified
marine candidate Special Areas of Conservation (cSACs) and Special
Protection Areas (SPAs), which will form part of the Natura 2000
network, are on or adjacent to the coast. There are no sites that
are wholly at sea. However, the Joint Nature Conservation Committee
is currently undertaking a project to identify further sites in
the offshore environment. This follows a change in policy by the
UK Government to apply both the Birds and Habitats Directives
to the entire UK continental shelf.
4.2 The first phase of the project will
identify suitable sites in waters beyond 12 nautical miles from
land. In relation to the Habitats Directive, sites in this zone
are likely to be for reefs and shallow (under 20 metres in depth)
sandbanks. Sites may also be identified for harbour porpoise and
(under the Birds Directive) for seabirds. It is expected that
the results will be provided to Government by late summer 2001.
In undertaking the study, it is possible that further suitable
sites will be identified within 12 nautical miles of the shore,
but there is uncertainty as to how such sites might be taken forward.
In the period prior to identification of possible new Natura 2000
sites, all potentially suitable habitat must be treated with care,
ensuring that these areas are not damaged or altered in a way
that might prejudice their selection.
5.1 WIDER POLICY
CONSIDERATIONS
5.1 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.
5.2 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.
12 February 2001
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