APPENDIX 13
Memorandum from English Nature
1. BACKGROUND
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
protected species and the special nature conservation sites in
England;
— enabling—helping 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 duties for nationally
and internationally important nature conservation sites including
Sites of Special Scientific Interest (SSSIs), the most important
of which are managed as National Nature Reserves (NNRs), Special
Areas of Conservation (SACs), and Special Protection Areas (SPAs).
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. INTRODUCTION
2.1 English Nature has provided much advice
to Government over the last five years through its responses to
a host of climate change and energy-related consultations. The
principles of this advice are embodied in our Position Statements
on "Electricity generation, transmission and use" (March
2000) and "Climate change and nature conservation" (September
2002), and more recently an ancillary statement "English
Nature and renewable energy" (January 2003), all of which
can be viewed at www.english-nature.org.uk (under "About
us"). We are encouraged to note that much of this advice
is reflected in the contents of the White Paper.
2.2 Whilst this response gives consideration
to energy policy in an holistic sense, particular emphasis is
placed on issues relating to renewable energy.
3. POLICY CONTEXT
3.1 English Nature's position is to advocate
policy measures to mitigate for the impacts of climate change
and acidification/eutrophication on biodiversity by reducing emissions
of greenhouse gases (particularly CO2) and acidifying gases (SO2
and NOx) to the atmosphere. As such, we have consistently supported
policies which promote the development of less polluting fuels,
cleaner combustion techniques, renewable energy schemes and more
energy-efficient industrial processes, consumer products, building
design and transport systems; we have also encouraged planning
policies which support emissions reduction.
3.2 All forms of energy, including renewables,
can have negative impacts on the natural environment (terrestrial
and maritime). These impacts might relate to the production of
fuels, the location and construction of generating plant, the
associated infrastructure, or the by-production of waste during
operation or post-decommissioning.
3.3 English Nature, therefore, believes
that all energy projects must be subject to the same imperatives
and safeguards to protect the environment as any other development.
The key challenge is to ensure that, in the drive to meet energy
targets, the quality and diversity of England's wildlife and geological
features are maintained and enhanced.
3.4 The positive environmental benefits
of renewable energy projects must be weighed against any possible
negative effects, which must be carefully assessed in the context
of an otherwise environmentally beneficial development. We will
articulate our views so as to contribute positively to the sustainable
implementation of renewable energy rather than as an obstacle
to progress. However, consideration of wildlife, geological features
and the natural processes which support them must be central in
the decision-making process.
4. LOCATIONAL
ISSUES
4.1 It is not English Nature's policy to
object to energy projects within or near designated nature conservation
sites or which interact with protected species per se.
However, we emphasise the need to adhere to relevant statutory
provisions, and related guidance. Projects which compromise or
are not consistent with the objectives for a designated site or
protected species or the general provisions of the legislation
under which they are identified should be refused consent.
4.2 Nature conservation value is not restricted
to designated sites. Objectives and targets in the UK Biodiversity
Action Plan apply across the wider environment, where there is
a need to protect functional linkages between habitats and sites.
Site protection mechanisms are poorly established at sea. Nature
conservation interests in the wider environment must be taken
into account in all energy projects.
4.3 Whilst it is not part of our remit to
be proactive in identifying and promoting sites where energy projects
would be acceptable, we will contribute to discussion at a national,
regional and local level on guidance on locations and locational
principles.
5. RECOMMENDATIONS
5.1 In relation to the Energy White Paper
and our positioning on climate change and energy issues, English
Nature advocates that:
— Regulatory and economic instruments
are used to maximise positive, and minimise negative, environmental
effects of energy schemes, so that the cost of energy reflects
the environmental costs of its generation.
— Strategic environmental assessment
of energy policies and new projects is undertaken to ensure that
nature conservation obligations and objectives, and potential
cumulative and in-combination effects, are recognised at the outset.
— Full consideration is given to the
potential impacts (positive and negative) of new energy projects
on wildlife, geological features and the processes that support
them.
— Projects which compromise or are
not consistent with the objectives for a designated site or protected
species or the general provisions of the legislation under which
they are identified are opposed.
— The effective management of risk
in establishing new technologies where little is known about their
effects, ensuring that there are mechanisms in place to avoid
or counter negative effects on wildlife, geological features and
the processes that support them.
— The results of environmental assessments,
monitoring and research are maximized to inform policy making
and consenting of individual projects.
— The positive benefits of renewable
energy developments to nature conservation at a local and regional
level are explored.
— Research into the impacts of alternative
fuel crops (biofuels) on wildlife is undertaken and advice and
guidance provided accordingly. English Nature will be responding
to the Environment, Food and Rural Affairs Committee's current
consultation on the subject (Press Notice No 24, Session 2002-03,
27 February 2003).
March 2003
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