House of Commons - Energy and Climate Change

The future of Britain's electricity networks - Energy and Climate Change Contents

Memorandum submitted by the Campaign to Protect Rural England

INTRODUCTION AND SUMMARY

1. The Campaign to Protect Rural England (CPRE) welcomes the opportunity to submit evidence to the Select Committee's inquiry on the future of Britain's electricity networks. The development of the nation's electricity network has been a key interest of CPRE since our formation in 1926. We played a central role in calling for the environmental obligations that were placed on the Central Electricity Generating Board, and subsequently National Grid. We were closely involved in discussions of the routing of transmission lines created under the most recent major development of the network, in the 1950s and 1960s. Alongside this we are the leading voluntary organisation engaged in both shaping and engaging with the spatial planning system at all levels. Our network of local branches in every county and our regional groups participate in the planning process on a daily basis.

2. The Committee's Inquiry comes about at a time where major investment in new electricity generating capacity is being proposed, both from conventional and renewable sources. One consequence of this is likely to be major development of the electricity transmission network, on a scale not seen since the 1960s. The recent report of the Electricity Networks Strategy Group (ENSG) confirms this, calling for £4.7 billion of investment in the period to 2020. In response, CPRE has recently issued, in alliance with the Campaign for the Protection of Rural Wales (CPRW), Campaign for National Parks (CNP), and the National Association for Areas of Outstanding Natural Beauty (NAAONB), A Countryside Friendly Smart Grid, a manifesto for the future development of the transmission network in England and Wales. A copy of the full manifesto is included with this submission.

3. CPRE supports moves towards a "smart grid" making use of technological innovation to manage electricity consumption, in order to reduce the need for new generating capacity. Crucially, development of a "smart grid" should integrate the need for a national network, which we acknowledge will remain for the foreseeable future, with minimising or avoiding damaging visual impacts in our most valued areas of rural landscape. In our view, minimising the impact of the grid can be achieved in part through sensitive spatial planning. But we also believe that this will have to be harnessed to measures encouraging greater use of local and decentralised energy networks, as well as energy efficiency, to reduce dependence on national transmission networks in the longer (20-30 year) term.

4. In preparing our evidence we have sought to address the following issues posed in the Call for Evidence: the Government's vision for electricity networks; issues surrounding the regulatory framework; and technological innovation.

5. The structure of our evidence is as follows:

— the role that the spatial planning process, and in particular the proposed National Policy Statement (NPS) on electricity transmission, will play in guiding the future development of the networks;

— the need for the future development of the network to minimise visual intrusion into the countryside, in particular designated landscapes; and

— the role of technological innovation in helping to minimise visual intrusion and allowing the network to better absorb electricity generated from renewable sources.

THE ROLE OF PLANNING

6. The Planning Act 2008 institutes a new planning process for electricity transmission (and potentially also high voltage distribution) networks, through which future expansion of capacity will have to be considered. CPRE believes that some of the reforms contained in the Act are sensible, in particular the proposed new National Policy Statements to guide development and the creation of single development consent order for individual projects. We have grave concerns, however, about the nature and extent of the powers of the new Infrastructure Planning Commission (IPC) to make decisions on electricity transmission and other projects.

7. Although Ministers have argued that the IPC will function as an independent body, its remit appears to be specifically about promoting and approving major infrastructure projects in line with national policy. The experience of developing the electricity transmission network in the UK and elsewhere has shown that it is not simply a matter of facilitating development. It is a highly political process of reconciling the economic arguments for centralised electricity generation and transmission with avoiding or mitigating the significant visual impact that the transmission network has on town and country. Although some may consider the planning process to be a "barrier" to progress, to CPRE it is a vital means of ensuring that the future development of the transmission network takes full account of the public interest.

8. The NPS on electricity transmission, to be prepared by the Secretary of State for Energy and Climate Change, is expected to be issued in draft in June 2009. The Committee will have scope to play a key role in the development of the NPS, through the parliamentary procedure for NPSs set out in the Planning Act.

9. The NPS should seek to ensure that the future development of the network happens in a manner consistent with the wider public interest and the achievement of sustainable development. As our manifesto makes clear, we accept in principle the need for major investment in the electricity transmission network. There will be a need for clear spatial planning, taking into account that certain areas are not suitable for new overhead transmission lines, and that good design to minimise visual intrusion should be paramount. Some of the most obvious methods of lessening environmental impact, such as the use of undergrounding and undersea cables, appear more expensive in the short term but can deliver significant long term savings, in terms of a reduced need for planning inquiries, time savings, and maintaining environmental quality.

10. The most recent major line upgrade project in England, in North Yorkshire, took nearly ½ years from application to final grant of permission. Significant amounts of this time involved the developer in considering ways to lessen the impact of the line on the landscape, not fully addressed in the initial proposal.[14] Ministers often refer to this case in arguing the need to avoid a lengthy planning process. In our view, however, the main lesson to be drawn from the North Yorkshire case is the need for a clear initial policy framework that sets robust standards of environmental protection and clear expectations upon developers.

THE NEED TO MINIMISE VISUAL INTRUSION FROM THE TRANSMISSION NETWORK

11. We fear that the Committee's questions, as set out in the Call for Evidence, miss an important issue with the future development of the network. We agree that development should take place in a manner that addresses renewable energy targets, security of supply and climate change goals. It is no less important, however, that a future vision for the electricity network should fully incorporate other environmental goals, such as minimising damage to the beauty and tranquillity of our finest countryside.

12. To address this issue, CPRE believes that the remit of Ofgem should be widened to consider the most sustainable methods of developing the network to address both climate change and landscape impacts. It should look at possible new power stations and transmission connections in the round. The new NPS process will necessitate a spatial, strategic approach to network development to ensure that designated and other valued landscapes are avoided by new overhead transmission lines where possible. This implies that Ofgem will need to become more flexible in allowing forward investment than under its current remit. This would, in turn, allow National Grid and the distribution network operators to promote demand management on their networks through energy storage and other techniques, and environmentally sensitive network development.

13. A 2003 report by the UK Centre for Economic and Environmental Development found clear evidence that the public find the landscape impacts of overhead lines unacceptable.[15] Alongside this, CPRE has carried out extensive research on the issue of rural tranquillity. A key stage of this research, conducted by Northumbria and Newcastle Universities, was to discover what rural tranquillity meant to people. "Seeing a natural landscape" was the top response as to what tranquillity was, and "seeing overhead power lines" was among the top 10 responses as to what detracted from a sense of tranquillity. We can supply further details, including maps, to the Committee on request.

14. According to a 2004 MORI poll, tranquillity is the main reason why 49% of us visit the countryside. Government data suggests in turn that through rural tourism, tranquillity directly supports 186,200 jobs and 12,250 small businesses, and contributes £6.76 billion a year to our economy. There is convincing evidence of the importance of the natural environment in helping people to recover from stress. A 1998 review of over 100 studies showed that the primary reasons for visiting natural environments included escape from the stress of urban areas and the experience of tranquillity and solitude.[16] Research published by the Campaign for National Parks in 2006 indicated that 69% of businesses in the National Parks in the Yorkshire and Humber Region believe high environmental quality has a positive impact on their business performance.[17]

15. Further recognition of these points, albeit in an urban context, has been shown in the major work that has been recently completed to underground high voltage overhead lines and remove 52 pylons (including both transmission and smaller distribution pylons) in and around the site of the London 2012 Olympic Games. At the beginning of the project, Lord Coe and David Higgins, both leading figures in the delivery of the 2012 Games, respectively stated that "the undergrounding of power lines will provide an uncluttered landscape against which the Games can be staged" and "placing the power lines underground is a vital part of our long term regeneration of East London".[18] This has led to a growing public interest in the possibilities for undergrounding transmission lines in other locations.

16. We recognise that undergrounding the highest voltage lines can carry significant short term expense (for example, £250 million in the case of the London Olympic project), and can also give rise to issues of disruption to subsoil, archaeological and landscape features. Nonetheless, we believe it crucial that National Grid and the distribution companies take their responsibilities seriously. Bill Bryson showed a particular concern for this issue in his maiden speech as CPRE's President in July 2007:

"In 1986, at the time the electricity companies were being privatized, the Economist magazine calculated that if all the electricity generating companies were required to devote one half of one percent of their turnover to burying overhead cables, we would be able to bury 1000 miles of them every year. There are 8,000 miles of high-voltage power lines in this country, so they would all be buried now.

Instead they seem to be a part of nearly every rural scene, nearly always running along hilltops and ridgelines where they ruin views in both directions. Other countries make electricity companies paint their pylons dark green or otherwise lose them against the background. I don't understand why National Grid, the company responsible for erecting pylons, is allowed such freedom. We don't put motorways on the tops of hills. We don't run natural gas pipelines overhead. Why should power lines be permitted to go wherever it suits the distributing company to put them?'

WHERE IS VISUAL INTRUSION A PROBLEM?

17. The relationship of the new NPS to existing Planning Policy Statements produced by Communities and Local Government (CLG) will be crucial. We draw the Committee's attention in particular to statements made by two Ministers (Baroness Andrews and Jim Fitzpatrick MP, respectively) which undertook that all NPSs would reflect existing Government policies protecting designated areas of landscape, such as AONBs, National Parks and Green Belts, from major or inappropriate development.[19] It is important that these undertakings are fully respected.

18. National Grid uses guidelines on the routing and siting of transmission infrastructure (the Holford and Horlock Rules, respectively). Despite these, overhead transmission lines directly intrude into designated landscapes at a number of locations (and indirectly at many more), for example in and around Trawsfynydd in Snowdonia National Park and at two points in the Cotswold Area of Outstanding Natural Beauty, north of both Bath and Cirencester respectively.

19. CPRE, CPRW, CNP and NAAONB are particularly concerned that the existing situation could be worsened by transmission reinforcement plans being considered by National Grid, many of which are referred to in the March 2009 ENSG report. Much of this proposed expansion appears to us to be driven by a desire to accommodate an increased amount of new nuclear generation on existing nuclear sites, alongside clusters of offshore wind farms in most of the coastal regions of England and Wales. Based on the initial indications provided, the strategy for accommodating new offshore wind farms—through underground connections to existing substations on the transmission network—appears broadly sensible and consistent with our vision for minimising visual damage.

20. Our analysis indicates, however, that plans could lead to new overhead lines or larger pylons in Snowdonia National Park as well as in four Areas of Outstanding Natural Beauty—Anglesey, the Kent Downs, the Lincolnshire Wolds, and the Mendip Hills. It is significant that in all these areas (except possibly the Lincolnshire Wolds), the driver for new development may well be the possibility of new or expanded nuclear capacity in the vicinity.

21. CPRE is also concerned to protect the open, undeveloped character of the Green Belt around our largest towns and cities and to improve its value for people to live near them. Overhead transmission lines already damage the appearance of the Green Belt around London and other major cities. Possible new lines in Derbyshire, Essex, Kent, and Somerset, and larger pylons in London and South Yorkshire, could have a further damaging impact on the Green Belt in those areas.

22. If expansion of the transmission network along the lines suggested by the ENSG is unavoidable, then CPRE would call for the NPS to set clear guidelines relating to better design of any new overhead lines, and the avoidance or undergrounding of lines in designated landscapes. We explore the issue of design in more detail below in our comparison with other countries.

THE ROLE OF INNOVATION

23. CPRE is pleased that a political consensus is emerging on the need for a "smart grid" that focuses on the encouragement of renewable energy, and better management of supply and demand for electricity in order to increase energy efficiency. We note with interest that the ENSG report advocates the use of both undersea High Voltage Direct Current (HVDC) cables from Scotland to England and "series compensation" (essentially the increasing of transmission capacity on existing lines) in Cumbria. It appears that the application of such innovations in the network are the direct result of planning constraints forcing National Grid to make the best use of both existing assets and to apply technologies causing less visual intrusion.

24. To encourage continued innovation, we believe that the new NPS could usefully set a policy lead for Ofgem in future distribution and transmission Pricing Control Reviews. Future reviews should promote the statutory environmental responsibilities for the Distribution Network Operators through a rolling programme of undergrounding or minimising visual intrusion from the existing networks.

25. Smart grid technologies can move us towards a more robust mix with less dependence on centralised energy in the long run. We acknowledge, however, that the need for national transmission and overhead distribution networks is likely to remain for the foreseeable future. One way in which this need may be reduced would be through the development of commercially viable means of energy storage, particularly from renewable sources. This has been identified as a particular barrier to allowing supply from renewable sources, which is often intermittent, to match peak periods of demand for electricity.[20] We suggest that the Committee investigates this issue.

LEARNING FROM OTHER COUNTRIES

26. CPRE has noted that the current debate around grid expansion in the UK has parallels in other countries. The most obvious example of this is President Obama's plans for a smart grid in the USA, where major investment is being directed to address the storage and transmission of power from renewable sources.

27. New Zealand has already produced (in March 2008) a National Policy Statement to guide the development of electricity transmission networks through the planning system.[21] This is a short four pages statement of high level principles. It is too early to fully evaluate the effect of the NPS on planning in New Zealand, but CPRE would have concerns if this was seen as readily transferable to the context of England.

28. We would suggest to the Committee that the forthcoming NPS for England will need to be significantly more detailed than the New Zealand NPS. In particular, we would want to see a thorough integration of principles around minimising the environmental impact of network development alongside the expected consideration of the overall need for development. Although the expected NPS will be the first of its kind on electricity transmission in England, there is an extensive history of policy and practice to which CPRE has significantly contributed, and would wish to bring to bear in the forthcoming debate around the English NPS.

29. A more applicable international comparator in CPRE's view would be Denmark. In Denmark, minimising environmental impact is recognised as a high level objective of the transmission network, alongside other operational issues such as robustness, maintaining security of supply and ensuring well-functioning competition in the power market. Significantly, Denmark is also planning a major expansion of offshore wind energy development to meet its target of at least 30% of energy demand to be met from renewable sources. In April 2008, Energinet.dk, the country's equivalent of National Grid, issued a technical study on expansion of the national transmission network, with prominent consideration given to increasing the use of underground cables. The study considered six "principles" for future network development ranging from complete undergrounding to new overhead lines along traditional lines and no expansion at all.

30. The report includes cost analyses of adopting different options. Perhaps unsurprisingly, those involving major undergrounding are significantly more expensive than those involving new overhead lines. Nonetheless, Denmark is setting a clear policy direction of travel towards reducing the impact of the existing transmission network, and has already undergrounded up to 18% of its high voltage (above 132 kV) lines. Part of the policy also involves the use of two less intrusive pylon tower designs, which can be applied where new lines are constructed. These are shown in Figure 1 on the next page along with the more traditional, taller, design in current use.

31. The two new designs in Denmark involve tower designs of a typical height of 33 metres. This is up to one third shorter than a typical tower design for a high voltage line in the UK of around 50 metres. CPRE notes that shorter designs have already been applied on the transmission network in specific cases in England, for example in the Cotswolds AONB at Tormarton, near Bath. We believe that the new designs being developed in Denmark should be investigated for application to new overhead line development in England, or in any locations where lines are being replaced and renewed and where undergrounding is not feasible. We note that although shorter designs can necessitate more towers than under a 50m design, there is still clear potential for visual intrusion to be reduced.

Figure 1 Existing and new tower types—all intended for two 400 kV systems in Denmark. The top tower is used in several places in Jutland. The development of the Eagle tower (middle) has been completed, and can now be used in new projects. The fibre mast (bottom) is currently being developed and is planned to be ready for use in five years. Reproduced with permission from Energinet.dk.