Memorandum submitted by Energy Networks Association (PB 18)
The need for change
The need to develop a more streamlined and responsive planning system has never been more important in the field of energy. Energy developments require large scale infrastructure that inevitably touches on local communities. The need to transport new and diverse energy from remote areas and between communities calls for a new approach to planning. We welcome the fact that there is a clear link between this Bill and the Energy and Climate Change Bills to ensure a coordinated and consistent approach to energy policy.
Planning reform essential to deliver low carbon and energy security objectives
The low carbon agenda and the importance of security of energy supply set out in the Government's Energy White Paper can only be achieved by the construction of new electricity and gas networks. A third of the UK's existing electricity generation portfolio needs replacing over the next ten to fifteen years, and within a decade 80% of the UK's gas will be imported. At the same time development of major renewables including microgeneration will be needed to achieve the 2050 carbon dioxide reduction targets.
The Infrastructure Planning Commission and local accountability
We believe the Infrastructure Planning Commission will have a vital role to play in delivering these objectives provided it is sufficiently and expertly resourced. We welcome the proposal for pre-agreed timescales and urge Government to set time-limits for each stage of the process in order to provide maximum certainty for developers and affected communities. However we also believe that the legitimate needs and concerns of local communities must also be a central consideration. The effectiveness and transparency of decision making are fundamental to underpinning community engagement and ensuring that developments move forward effectively and in a responsive way. As a result local communities must have a full opportunity to express their views and be heard. Central to this will be enhanced duties placed on developers to ensure that local communities are effectively consulted before an application is made. The energy sector continues to strive for the very best practise in this area and has already had discussions with groups such as CPRE about how to ensure standards are continually improved.
The vital role for National Policy Statements
We support the introduction of National Policy Statements to ensure there is a clear policy framework for significant infrastructure. The need to set out at a national level a statement of Government intent will provide clear and unambiguous investment signals to network developers so they can plan efficiently for the future. However the interrelationship between them and the hierarchy of the existing suite of planning policies, statements and guidance must be addressed if they are to be effective. There is also clarity required around how the onshore and offshore consenting regimes will align and interact with the Draft Marine Bill.
A rationalised planning process
Electricity and gas transmission and distribution projects currently require a number of different consents under the Electricity, Gas and the Town and Country Planning Acts. We welcome a rationalisation of the process governing these. We believe this approach will ensure a level of certainty for developers and provide for consistency with National Policy Statements. It will also assist and reinforce the pre-application consultation process by ensuring that local communities and key stakeholders are fully aware of all aspects of an energy infrastructure development thus providing a mechanism to ensure that crucial local issues are addressed at a stage where they can be most effectively remedied.
A national debate
Far from being an enemy of democracy we believe the Bill can ensure a greater national debate of vital policy objectives in a way hitherto unseen. Whilst Government proposals will form the basis of National Policy Statements they must be subject to rigorous scrutiny and full amendment. We believe that robust Parliamentary scrutiny and public consultation of National Policy Statements must be at the very heart of the proposed reforms. Whilst local issues of concern must continue to be addressed locally we believe that the appropriate forum for consideration of national policy objectives should be in Parliament after consultation with the public. To ensure this process delivers effective and appropriate policies it must listen closely, debate in depth and allow all views to be aired. We believe that Parliament and the Government must devise a process that underpins these principles.
Energy infrastructure should be exempt from Community Infrastructure Levy
We are very concerned about the impact on energy development of the Community Infrastructure Levy (CIL). Whilst we do not disagree with its objective to require developers to contribute the additional local and regional infrastructure arising from their developments we believe that energy infrastructure projects should be exempt from it. Firstly energy projects already contribute to community development through S106 Agreements (under the TCPA) and whilst the CIL is predicated upon the there being an uplift in land value following a development this is almost never the case in relation to network developments. As a result energy network developers would be forced to incur unnecessary additional bureaucracy and costs to prove something that is obviously the case whilst at the same time there would be no fiscal benefit to the local or regional authority. Finally energy infrastructure projects do not generally lead to the need for increased community infrastructure, and as infrastructure providers we deliver such services. We believe that an enhanced S106 with greater transparency will deliver a better solution for the communities affected by our works.
The Government's reform proposals are a vital step towards delivering the billions of pounds of investment needed to maintain the UK's energy supplies and moving towards a low carbon economy. However, the reforms also provide the opportunity for enhanced community consultation which must remain a core part of any planning process.