Select Committee on Environmental Audit Appendices to the Minutes of Evidence


Memorandum from The Council for National Parks


  The Royal Commission on Environmental Pollution has recommended a 60 per cent reduction on CO2 emissions by 2050 in order to begin to overturn the increasingly negative impacts of climate change, acidification and pollution. CNP considers that we all need to play our part and take responsibility for facilitating a reduction in emissions of this magnitude. The National Parks, which are designated because of their exceptional landscape qualities and cover 10 per cent of the land of England and Wales, are no exception. Indeed:

    —  National Parks are in a strong position to influence the way we care for our countryside, to be models for the sustainable management of the wider countryside, and to help further understanding of the means by which development and conservation can be better balanced[1].

  CNP advocates the use of our National Parks as exemplars in the sustainable use of energy. Good examples of how this can be achieved in a way that contributes to sustainable development already exist (see below), although there is still a long way to go. The wise use of energy must, however, be developed with the wider goal of sustainable development in mind, such that:

    —  The countryside should be protected for the sake of its landscape, natural resources and its agricultural, ecological, geological, physiographical, historical, archaeological and recreational value[2].

    —  The Government's policy is that the countryside should be safeguarded for its own sake[3].

    —  Government planning policy towards the National Parks is that major development should not take place in these areas save in exceptional circumstance. Because of the serious impact that major developments may have on their natural beauty, wildlife and cultural heritage, applications for such developments must be demonstrated to be in the public interest before being allowed to proceed[4].

  Areas of high/national landscape value such as National Parks should thus be avoided for large-scale renewable energy schemes, as these would conflict with their statutory purposes[5], which include the conservation and enhancement of their natural beauty. There is nonetheless a whole range of measures and practices that are desirable and suitable for adoption in National Parks. This short submission gives a flavour of what more could be done.


  Electricity demand is expected to double by 2020. A greater policy emphasis is needed on promoting energy conservation and efficiency across all sectors (to deliver the prudent use of natural resources element of the UK Sustainable Development Strategy) accompanied by targets for demand as well as supply. The UK Government has recognised that a "step change" in thinking is overdue, and is now aiming for a tenfold improvement in energy efficiency[6]. Energy efficiency measures should therefore be central to the UK's energy strategy.

  We consider that links between renewable energy, energy conservation and demand management are vital. National Parks are well placed to be role models for the development of small-scale sustainable energy schemes. They should be encouraged to facilitate more sustainable energy schemes in their areas and to provide greater information on the possibilities for these. We will say more about this below.


  There is a need for the development and stimulation of a broad mix of renewable energy technologies both because of the benefits of renewable energy and to increase the diversity of energy supply and avoid the renewables market (and the debate) continuing to be monopolised by large-scale onshore wind generation. There is a need to consider the clean-up costs of projects which reach the end of their useful life—reversibility and whole life costing.

  If it is to be successfully deployed UK-wide without public opposition, renewable energy development needs to be taken forward at a scale appropriate to its siting and surroundings. This could be assisted by the adoption of a sequential approach. This would be particularly beneficial for onshore wind generation. Urgent consideration should be given as to how onshore wind schemes can be developed in transport corridors, areas of low wind speed and brown field sites and away from areas of great landscape value. Adopting a sequential approach in guidance would help in this respect and for this reason CNP would very much support the introduction of a sequential approach along similar lines to that advocated by the Countryside Agency.

  In such a sequential approach, it should be made clear that areas of high/national landscape value such as National Parks should be avoided for large-scale schemes, as these would conflict with their statutory objectives, particularly the conservation/enhancement of natural beauty.


  A strategic approach to planning for renewables which takes greater account of National Park statutory purposes at earlier stages is necessary. This is because the development of renewable energies can have adverse impacts on National Park purposes.

  Development of small and domestic-scale projects in the National Parks is already underway. These are good examples of how renewable energy can be developed in ways that support the delivery of National Park purposes. For example, CNP supports the efforts of the three National Parks in Wales in facilitating appropriate solutions locally, particularly through the Environment Development Fund[7], for example:

    —  Tidal Power Generation—groundbreaking project being pioneered by Tidal Hydraulic Generators Ltd—a consortium of local engineering contractors.

    —  SEED (Sustainable Energy and Environmental Development)—raising the profile of small-scale renewable energy in Pembrokeshire.

    —  The Pembrokeshire Biofuel Partnership—heating conversion feasibility study.

    —  Penpont Biomass Project—feasibility study into energy-generation using local wood.

    —  Brecon Beacons Solar Club—currently working to evolve into an all-Wales Solar Club.

  These schemes also have the benefit of being advertised publicly, which helps raise public awareness about the need to develop renewable energy and to reduce energy consumption.


  Local Planning Authorities (including National Park Authorities) should be encouraged to adopt best practice and positive policies on sustainable energy including through their Development Plan, internal housekeeping policies and work with local communities. Consideration should be given to establishing locally administered funding streams for the development of small-scale community-based sustainable energy schemes (eg solar clubs). Local Planning Authorities are well placed to advise on possible funding streams. This could be done on a joint basis (eg between National Park Authorities and other Local Planning Authorities). This would help raise public awareness about the need to develop renewable energy and the availability of renewable energy in the area. The Countryside Agency's Community Renewables Initiative (see Annex 1) has great potential to deliver appropriate schemes.


  National Parks have a significant capacity to promote small-scale energy solutions and energy efficiency initiatives. National Parks are ideal settings for promoting sustainability issues, including energy issues. Our uplands often receive severe weather. If buildings in the uplands can conserve energy and can be showcased as energy efficient while retaining comfort (warmth) levels, and get planning approval too, then this might provide the good practice examples that can inspire and help motivate people and raise awareness of what is possible and feasible. People also tend to be more receptive to environmental issues in a beautiful setting in open countryside.

  The Environment Development Fund administered by the three National Parks in Wales has facilitated the funding of a number of energy-related projects including:

    —  Idwal Cottage Youth Hostel near Llyn Ogwen has received grant assistance from the Environment Development Fund through the Snowdonia National Park Authority to develop the Youth Hostel into a model "Green" Youth Hostel and promote wider understanding of sustainability.

    —  Local communities are working with the National Parks in Wales in developing a three-Park initiative that is considering how to use energy more wisely. In the Brecon Beacons National Park, the community of Talybont on Usk is developing a project to look at how homes, businesses and community buildings in Talybont can become more energy efficient. The community will link up with residents of Ysbyty Ifan in Snowdonia National Park, who will be undertaking a similar venture. The initiative has been made possible with funding from the Environment Development Fund.

  There is clearly an interest among the public, but good practice examples and showcasing of practical possibilities need to be encouraged. The Environment Development Fund has given a hint of what is possible. More could be done on Park-wide or community-wide basis in this respect.


  That is, increasing the productivity with which we use natural resources, eliminating waste and reinvesting in the renewal of natural resources so that the raw material, the natural "capital" remains "in the bank" and is available for reuse without depreciation. In short, it means taking less natural resource to deliver more at lower cost. Resource efficiency saves, for example, wasted Kilowatt-hours and travel hours, barrels of oil, and forests of ancient trees discarded as paper and pulp.

  Practical example of resource (energy) efficiency:

    —  A 107,000 square foot engineering laboratory built at De Montfort Univeristy in Leicester eliminated all of its chillers and fans, maintained comfort and cut about £1 million out of its construction costs.

  The Welsh Development Agency has made a start on the lean technology agenda through its Lean Methodologies Programme, which uses "a rigorous methodology to improve processes, reduce waste and increase customer satisfaction". CNP asks the Committee to consider how the Government can further promote the development and main-stream integration of lean and closed-loop technologies, and how the significance of energy efficiency and sustainability will be positively promoted in this context.

  Competitive advantage from such superior performances does not evolve gradually, but needs to be a deliberate effort to create a resource efficient or "closed loop" technology.

  Closed loop innovations include:

    —  A highly efficient method of removing and reconstituting ink from printed paper in a continuous loop. Manufacturing using primary products is therefore minimised. Further, the de-inked and recycled paper from this process lasts 10-13 times longer than conventionally recycled paper. This results in huge natural resource savings whilst increasing labour and resource productivity.

    —  Continuous recycling of synthetic carpet back into itself results in a closed manufacturing loop, where the use of natural resources is minimal. Leasing carpet tiles rather than selling them allows the company to retain control over the life of the product, and hence ensure that the product is continuously recycled rather than wasted/thrown away when worn. Net employment has increased (less manufacturing but more upkeep).

  The principle of closed loop technologies could apply to a host of industries, eg white goods and cars. For instance, Daimler Chrysler, in conjunction with other companies, is researching to develop new processes that can recover as much reusable material as possible from end-of-life vehicles. The project is subsidised by the German Federal Minister of Education and Research.

  In Wales, Cymad has been researching the potential for Welsh wool to be used as insulation and has discovered that it is in fact the best wool for the job! The project is also in the process of setting up a centre to produce fertiliser from the waste wool in a "closed loop" system that would use the waste wool from the insulation plant. This is being made possible with a grant from the Environment Development Fund (administered by the Snowdonia National Park Authority).


  CNP is calling for:

    —  A step change in resource productivity and energy efficiency.

    —  Introduction of a broad mix of renewables to encourage diversity of supply.

    —  A recognition that we all need to take responsibility for our energy consumption. We should not rely solely on large-scale technological fixes that will allow the rest of us to think that we can continue with "business as usual". A very wide uptake of small-scale applications and energy efficiency measures would have a hugely beneficial impact overall.

    —  National Parks to be used as exemplars in the sustainable use of energy and a recognition that National Parks will continue to be protected from large-scale developments that are incompatible with their statutory purposes.

    —  The establishment of locally-administered funding streams for the development of small-scale community-based sustainable energy schemes.

    —  More emphasis to be given to the need for public education on the importance of using energy more sustainably.

April 2002

1   NAW Circular 13/99, DoE Circular 12/96. Back

2   Planning Guidance [Wales] Planning Policy First Revision, para 5.1. Back

3   PPG7, para 2.14. Back

4   Welsh Office Circular 13/99, PPG7 (para 4.5). Back

5   Section 61, Environment Act 1995. Back

6   Speech by the Rt Hon Margaret Beckett MP, Sec of State for Environment, to Environment Forum, 24-10-01. Back

7   The Environment Development is a £3 million fund set up by the National Assembly for Wales to test-bed initiatives that contribute to sustainable development. The three National Parks in Wales are administering the fund in their areas. Back

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