Select Committee on Environmental Audit Written Evidence

Memorandum submitted by CPRE

  1.  CPRE welcomes the opportunity to comment on the above inquiry, which is both wide-ranging and timely given the discussions over the future security of supply. We exist to promote the beauty, tranquillity and diversity of rural England by encouraging the sustainable use of land and other natural resources in town and country. It is from this standpoint that we wish to comment on a number of the questions raised by the Committee.

  2.  There is a lively debate over how future energy needs should be met, and the place of nuclear within any future energy supply mix. We believe that it is important that this debate is informed by the implications of any decision on the countryside. CPRE recognises that climate change is already occurring, that the rate of change is a consequence of human activity, and that it has the potential to damage irreversibly the character of the countryside and coastline. This should be a central consideration in guiding Government policy, and we believe this warrants re-examining the objectives that underpin the Energy White Paper.


  3.  When publishing the Energy White Paper, Ministers referred to the importance of tackling four issues simultaneously. These were increasing competitiveness in energy markets (through lower prices), tackling fuel poverty, reducing carbon emissions, and ensuring security of supply. Few would dispute the desirability of achieving these objectives. Yet, it is important that the inter-action between these is considered. In particular, we question the extent to which lower prices for gas and electricity (as a policy objective) are consistent with achieving energy efficiency and a low carbon economy. The minutes of the Government's Sustainable Energy Policy Advisory Board (SEPA) meeting of 8.6.05 illustrate this dilemma stating that "Although high energy prices undoubtedly posed challenges for UK commerce and industry they also offered additional stimulus for energy efficiency measures and opportunities for CO2 reduction" (DTI website).

  4.  A related issue is the importance of tackling what DEFRA called in its consultation paper on the Climate Change Programme, the "comfort or rebound" effect. Specifically, it said "Policies that enhance energy efficiency make it cheaper to heat our homes or to travel and past experience is that people respond by heating homes or travelling more. Such comfort or rebound effects tend to offset the initial gain from policies designed to reduce overall energy demand and carbon dioxide emissions" (Review of the UK Climate Change Programme, paragraph 3.21). Such rebound effects were estimated to be between 10-30% for example, as a consequence of improved fuel efficiency.

  5.  CPRE believes the Energy White Paper needs to address the potential conflict of falling prices for energy and improving its efficient use, and moving beyond energy efficiency to actually reducing consumption and overall carbon emissions. This should be at the heart of any new energy policy. The leaked briefing by a senior DTI official to incoming Ministers following the 2005 General Election includes the comment, "continuing high or rising consumer prices will make it harder to achieve fuel poverty objectives". CPRE believes this demands a more intensive targeted approach to tackling those in need, rather than a strategy that tries to reduce costs across the board. Given the growing data which exists on climate change, and evidence that the Government is unlikely to meet its domestic targets for reduction of CO2, the need for a review is urgent.

  6.  We are encouraged that the new Secretary of State for Trade and Industry, Alan Johnson MP, in his speech to the Labour Party Conference said, "We have put energy conservation and the development of renewables at the heart of our approach". He went on to say "the challenge now is to consider what we can do to reduce still further CO2 emissions while ensuring our energy remains both secure and affordable". This further highlights the tensions between the Government's policy objectives and we urge the Committee to examine the compatibility of these aims.


  7.  The Terms of Reference for the Inquiry consider the extent of the "generation gap" (question 1). CPRE believes this places an emphasis on how the energy mix can meet growing demands for electricity and fuel. If we are to deliver significant savings in carbon emissions, we believe it is essential that the debate moves on from how energy supply (eg gas or electricity) can be provided, to how energy services (eg heat or light) can be provided in ways which reduce carbon emissions. We welcome, in this respect, the discussion within Government of a renewable heat obligation but believe much more needs to be done if we are to secure significant improvements in energy efficiency.

  8.  A commitment to reduce energy consumption needs to be shared across Government if a coherent programme for reducing emissions is to be delivered. CPRE is concerned that other departments, such as the DfT, ODPM and HMT have not embraced this agenda sufficiently. The minutes of the SEPA meeting (quoted above) say "it was noted that revenue-neutral congestion charging (the subject of a recent announcement) might actually have the effect of increasing emissions, by making rural driving cheaper". Meanwhile the ODPM and Treasury's plans for a significant increase in market housing provision will have considerable implications for energy consumption.

  9.  The effect on energy use of tackling problems of low housing demand are also significant. Yet, calculations on the net energy balance from demolishing existing properties in northern communities have generally failed to incorporate the embedded energy contained within the house. And as the Sustainable Development Commission note in their submission to the Government's review of its climate change programme, "Refurbishments pay 17.5% VAT, whereas new build is VAT free. This is distorting the economics of developments in favour of demolition and replacement rather than refurbishment. This is causing unnecessary destruction of communities, and destruction of older buildings which could be refurbished to immensely higher standards of efficiency". In addition, the very act of demolition releases CO2, as well of course as the emissions released through the construction programme.

  10.  Recent Government statements illustrate the absence of a coherent approach to energy conservation. The response by the Chancellor of the Exchequer to the events following Hurricane Katrina included a call for increased production (ie extraction of fossil fuels and processing). This illustrates well the dependence we have allowed to occur on fossil fuels. Reducing this dependency will assist in reducing emissions, and improve security of supply. It is an uncomfortable truth that frequently the hard decisions over reducing consumption come in times of acute shortage. A good example of this is the way in which motorway speed limits were reduced during the oil crisis in the 1970s. We believe that the Government should focus on using the opportunity of high fuel prices to address how overall energy consumption can be reduced, rather than look to ways of increasing supply.

  11.  The Director-General of the DTI's Energy Group, Jan MacNaughton, in her (widely leaked) memo advised "we need to push DEFRA and other Government departments hard on the scope for more vigorous energy efficiency measures, including on transport, buildings and the domestic sector'. Areas where we believe action by Government is needed include:

    —  working towards ensuring all sectors are covered by fiscal instruments which aim to reduce the consumption of carbon;

    —  requiring all new housing development in the Government's Growth Areas to be "excellent" in terms of the Eco-Homes Standard;

    —  developing an "energy conscious" approach to securing sustainable communities;

    —  strengthening guidance to OFGEM so it has a clear objective of reducing energy consumption rather than just improving energy efficiency;

    —  turning the proposed report on the implementation of the Air Transport White Paper into a full scale review which has demand management at its centre;

    —  ensuring proposals for road pricing contribute to emissions reduction;

    —  reviewing the Government's Targeted Programme of [Road] Improvements in the light of the need to reduce CO2 emissions; and

    —  taking the necessary measures to ensure the cost of public transport falls, and the cost of motoring increases.

  12.  Government has a key responsibility in creating the right framework for businesses and members of the public to reduce their patterns of consumption. It has an important role too in encouraging the development of new technologies through research and development. CPRE is concerned, however, that the need for behavioural change in order to address the challenging targets for climate change has not been sufficiently appreciated within Government. There appears to be a reliance on technological fixes to address climate change. In CPRE's view this will be insufficient on its own for the task.

  13.  This emphasis on technology is underlined by an on-line question and answer session that the Prime Minister had during the Labour Party Conference. During this, he was asked about climate change. He remarked, "my honest view about this is one that no government is going to sacrifice economic growth for the environment. Short term economic growth for the long term problems of the environment, and therefore you have to find the ways both in energy efficiency and in science and technology and renewables and all the rest of it, of managing to grow sustainably without damage to the environment". CPRE believes this sits uncomfortably alongside the Government's Sustainable Development Strategy, Securing the Future, with its emphasis on recognising environmental limits, and seeking to influence behaviour. Indeed we believe the science amply demonstrates that climate change cannot be viewed as a long term environmental problem. The effects are already being felt, and need an urgent response. This was underlined during the Climate Change conference in Exeter earlier this year which was organised by the UK as part of its Presidenicy of the EU. We are deeply concerned that this urgency is not being reflected in the decisions being made by Government. The danger of catastrophic climate change as feedback loops reinforce the effects from human induced emissions reinforces the need for a precautionary approach. We urge the Committee to address this issue of urgency during the course of its inquiry.


Is there the technical and physical capacity for renewables to deliver the scale of generation required? If there is the capacity, are any policy changes required to enable it to do so?

  14.  CPRE supports the development of a broad range of renewable technologies in contributing to meeting our energy needs. It is important to recognise, however, that all forms of producing electricity have some environmental impact. We have been concerned that the Government's approach, to date, has focused heavily on the use of onshore wind farms to deliver the Government's 2010 target. Onshore wind is assumed by the DTI to contribute between 7-8% of the target for 10% of electricity generation to be by renewables by 2010. While this is a consequence of the maturity and relative investment that has gone into different technologies, we believe this approach is posing a considerable threat to the character of the countryside. We attach particular importance to the question of whether there is sufficient physical (as opposed to technical) capacity for renewables to deliver the generation required.

  15.  To answer this question requires agreement on the relative contribution of renewables to meeting society's needs. This needs to be informed by an assessment of how energy consumption will be reduced. It should also be informed by a proper understanding of the consequences of policy decisions on the landscape of the countryside. We do not believe the adequate answers have yet been provided to either question.

  16.  To our knowledge no Strategic Environmental Assessment (SEA) was undertaken of the Energy White Paper, its renewable energy targets, or other proposals. Unlike offshore wind, where a national SEA was undertaken by the DTI, responsibility for undertaking any appraisal has been left with regional planning bodies. Furthermore, there seems little opportunity for the results of any assessment to feed back into national policy. Indeed, the Energy Minister, Malcolm Wicks MP, has stated to the House of Commons (21.7.05) that regional and local planning bodies should consider the targets for renewable energy as "floors" and should not restrict further development even if targets are exceeded. Given that SEA should be about considering the potential impact of development on the environment, one is left wondering what the purpose of the SEA may actually be, or how a regional planning body is to use the findings of the SEA in coming to decisions over what is an appropriate level of development.

  17.  The failure to appreciate properly the impact of onshore wind on the landscape has contributed towards the heated debates that now exist over the topic. Nobody benefits from the current situation. To some degree, this conflict is an inevitable consequence of blaming the land use planning process as an obstacle to progress with renewables. The wording in the Energy White Paper, new Planning Policy Statement 22: Renewable Energy, a subsequent statement by Energy Minister Malcolm Wicks MP (see above), and the fact that DTI have charged officials with overcoming "barriers" including planning, all weaken the planning process.

  18.  In fact, the land use planning process is the principal mechanism by which proposals can be considered in the context of the land, its environmental and cultural qualities, and other competing uses for it. Normal planning arrangements allow for this to be done in an open way, enabling members of the public to have a proper say, with decisions made by democratically elected local authority members. This is in contrast to how projects with a theoretical capacity of 50 mega-watts or more are considered. Here, the decision is taken outside of the control of the local planning authority and handed directly to the DTI. Although local authorities can trigger the need for a public inquiry, the ultimate decision rests with the Government department that holds primary responsibility for meeting the target for renewable energy. This highly questionable arrangement arises from Section 36 of the Electricity Act 1989 and adds to the criticism of the way in which renewables are planned in this country. CPRE believes amendments should be made to this legislation to ensure more projects are considered under normal planning procedures.

  19.  One of the criticisms levelled at some renewable energy technologies is its intermittency. While there appears little consensus over the degree to which this is a problem, it seems apparent that to reduce intermittency would be a positive step forward. We would urge that serious consideration be given to how to develop less intermittent renewable technologies (like wave/ tidal) so that these may contribute towards the achievement of Government targets. Sensitively planned offshore wind projects too, have a very important role to play.

What contribution can micro-generation make?

  20.  CPRE warmly welcomes the growing interest in the contribution of micro-renewables to energy provision, that is micro wind, PV, solar thermal panels, micro CHP and ground heat pumps. We believe these are a more benign way of ensuring we are able to meet society's needs. Important aspects of what makes them valuable is their ability to be retro-fitted to existing developments, the potential which exists in urban areas, and for the areas of electricity generation and consumption to be located very close together. It also places greater responsibility upon individuals in relation to understanding their own patterns of energy consumption.

  21.  We believe there is an urgent need for the Low Carbon Buildings Programme to be implemented. This needs to be carefully integrated with proposals for housing growth (such as in the Thames Gateway) as part of implementing the Communities Plan. We believe that Government needs to move towards a goal where all new build is, as far as possible, carbon neutral. But even if all new housing development were carbon neutral, its proportion compared to the whole building stock would be small. It is critical, therefore, to address what can be done to improve performance in existing buildings through micro-generation and energy efficiency measures. In order that micro-generation plays a bigger role in future, CPRE also recommends that:

    —  a review should be undertaken of the current regime of Permitted Development Orders to see if micro-generation can be further supported (particularly outside Conservation Areas) while ensuring existing policy objectives concerning design, conservation, the historic built environment and other environmental issues are effectively addressed; and

    —  the Government should support a series of locally organised road shows for local authority planners and councillors to provide information on micro-generation technologies.


  22.  CPRE has a long history of involvement in relation to scrutinising proposals for specific new nuclear plant. We neither advocate, nor object to nuclear power on principle. Our starting point is the impact which it, alongside other alternative measures, may have on the countryside. Because of the sensitivity of these particular developments, they are often proposed in rural landscapes, especially remote coastal ones. We objected to a number of proposals for nuclear power plants and waste disposal facilities in the 1980s on the grounds of insufficient justification of their need, their significant impact on the landscape, and the unresolved problem of nuclear waste. This included proposals for drilling boreholes in the Northumberland National Park.

  23.  In considering the place of nuclear power plants in the overall energy mix we believe it is important to consider the different timeframes involved. Over the short term, the approval of new nuclear power plants would not be able to address the "generation gap" identified by the inquiry. The Performance and Innovation Unit report, The Energy Review 2002 estimated that new nuclear plant would require 10 years to build. Crucially, this estimate was made "on the assumption that the projects concerned do not face major planning obstacles". Given the sensitivity of the public to nuclear, particularly in the absence of an agreed way of addressing nuclear waste, this would seem to be an optimistic assumption. Therefore, new nuclear power will not "keep the lights on" in the short term. The contribution of existing plant, however, could become more important.

  24.  Looking to the longer term, the Government faces a crucial decision concerning how energy is both generated and supplied in this country. We have an established energy distribution network which is predicated on a relatively small number of generators of electricity. There is, however, a recognition that if we are to move towards a scenario where renewables, and in particular micro-generation, are to play a bigger role, then a more localised distribution system would be required. The development of a more localised model would also reduce leakage caused by the long distance distribution of electricity—leakage that benefits nobody. We urge the Committee to look, therefore, not just at the impact of a decision to invest in new nuclear build on energy and renewable energy, but also on the distribution network and any changes which might be needed in future.

  25.  CPRE is concerned by references to planning and new nuclear plant in the leaked memo by Jan MacNaughton (Director-General of the Energy Group at DTI) to incoming Ministers. Specifically, she asks the Minister, "if we wanted to encourage new build, what steps might we take eg on planning issues regarding sites and pre-licensing of reactor technologies?". We urge the Committee to explore what may lie behind this statement.

What impact would a major programme of investment in nuclear have on investment in renewables and energy efficiency?

  26.  It is CPRE's judgement that investment in new nuclear build would have important influences on investment in renewables and energy efficiency. To some extent renewable energy as a whole may be cushioned from the effects of investment in nuclear more than it has in the past because of the commitments made in the Renewables Obligation. However, even with an extension of the Obligation it is likely that investing in nuclear would deter investment in less mature renewable technologies, such as wave power. This is likely to mean a continuing domination by wind in renewable energy generation. The impact of investing in nuclear is likely to be more severe in terms of its impact in undermining efforts to promote energy efficiency and energy conservation.

  27.  The initial cost of new nuclear build is substantial. It is important to consider the effect of providing electricity from a new programme of nuclear reactors on energy efficiency. But it is also necessary to consider the opportunity costs associated with putting that money towards major new generating plant, compared with boosting substantially measures to help consumers reduce their energy demands.

How carbon-free is nuclear energy?

  28.  Although we do not possess the expertise to answer this question specifically, we believe that it is a very important question to pose. If we are to tackle climate change, then it is important that our sources of energy are as low carbon as possible. We endorse the need to consider this in the form of a life-cycle analysis, and we believe this should be applied to all forms of supply, and not just nuclear.

Should nuclear new build be conditional on the development of scientifically and publicly acceptable solutions to the problems of managing nuclear waste, as recommended in 2000 by the Royal Commission on Environmental Pollution?

  29.  CPRE has supported the recommendation of the RCEP, and believes it would be irresponsible to build new nuclear plant until a solution had been found to how to deal with radioactive waste in the long term. The scale of waste generation may indeed be less through advances in technology; if so, CPRE welcomes this. It does not, however, address the problem that the overall legacy has still not been addressed. The Committee on Radioactive Waste Management (CoRWM) will report on nuclear waste containment solutions in June 2006, and its chair, Professor McKerron, has warned that preparing for a new generation of nuclear stations will hamper attempts to find a solution to the nuclear waste problem.

  30.  The latest estimate by the Nuclear Decommissioning Agency of £56 billion highlights the huge opportunity costs associated with this technology. CPRE is also concerned by speculation that rather than re-converting decommissioned plants to greenfields (as previously planned), areas may come under "indefinite institutional control" (ENDS August 2005). In effect this could mean land being blighted for many many years to come, tightly controlled and without public access. This would reduce the financial costs associated with decommissioning. The Government has established a process for considering the issue of tackling nuclear waste. We believe that this needs to be able to run its course.


  31.  CPRE believes that the threat of climate change means that concerted action is needed to move towards a low carbon economy. While the Energy White Paper has focused principally on the generation and consumption of electricity and fossil fuels, we believe a vital contribution to tackling overall emissions can come from action taken in other sectors. These include in particular the aviation, surface transport, and housing sectors. The Government should take a stronger lead in setting a suitable framework which will not only seek to improve energy efficiency, but actually deliver reductions in energy consumption and carbon emissions. This must be the first priority for Government if it is to promote a sustainable energy policy.

5 October 2005

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