Examination of Witnesses (Questions 100
- 119)
WEDNESDAY 13 JANUARY 2010 (morning)
MS JAYNE
ASHLEY AND
MR JAMES
GREENLEAF
Q100 Charles Hendry:
Are you not opening up the whole process to a much greater risk
of judicial review when you have not got an opportunity for people
to say, "Look, you've made your decision, but, as the IPC,
you've decided that it is not too serious in terms of cumulative
emissions and, therefore, you're going to consent it" and,
therefore, there is a much greater risk that others will come
in and say, "Well, actually we think it is"? There is
a subjective element in here which could actually get the whole
lot back into the courts, which is what we are trying to avoid.
Mr Greenleaf: I suppose the one
way round it would be to look at the way you account for the power
generation carbon budget explicitly. At the moment, because of
the technicalities of the accounting rules and the link to the
EU Emissions Trading Scheme and crediting and debiting accordingly,
it means that it is a non-issue for compliance, but you could
perhaps then state a path or upper and lower boundaries for what
you want the power sector to deliver in line with the CCC's recommendations
and those would form a boundary for what the IPC takes into account.
Q101 Charles Hendry:
But why do you think this is better than having an approach where
you have got an IPC which does not look at those issues in the
same way as you are suggesting? Do you not have a robust carbon
price and then, if people build too many gas-fired power stations
where the emissions are going to be above a level which is deemed
to be sustainable, they will simply be unaffordable to run because
the carbon price will mean that they cannot be operated? Why do
you not use that and allow the market to decide how one then reaches
the carbon goals?
Mr Greenleaf: In an ideal world,
yes, the EU ETS in a more robust, stringent implementation could
do that job to a large extent, but we do not have that at the
moment. The UK has decided where it needs to go and it is much
more rapidly in the policy framework at the moment, so it is actually
using the IPC as a mechanism to help deliver that and that perhaps
acts as a sort of protection barrier to prevent us moving away
from that path.
Q102 Charles Hendry:
But, if one had a floor price on carbon and there was, therefore,
some degree of certainty about the robustness, that might help
to provide that?
Mr Greenleaf: Not necessarily
the floor price, but it is the cap itself within the EU ETS, that
is where we provide the clarity about the environmental effectiveness.
Dr Whitehead: Associated with that is
the question of the appraisal of sustainability and its compliance
with strategic environmental assessments. John?
Q103 John Robertson:
Following on from what you have been saying, I get the feeling
that you feel that the draft NPSs are basically not clear enough,
particularly on environmental impacts. Of all the different energy
schemes, what would you do and how do you think they should be
assessed then?
Mr Greenleaf: Sorry, do you mean
for the appraisal of sustainability within the NPSs at the moment?
Q104 John Robertson:
Yes.
Ms Ashley: The appraisal of sustainability
was a strange beast in the first place because it was basically
created just for the National Policy Statements, so, if I assume
that the appraisal of sustainability is strategic environmental
assessment-compliant, one of the key issues we found with the
AOS process was looking at alternatives, and we were very clear
when we first gave our comments back to the consultation on the
Planning White Paper that, in looking at need and looking at alternatives
for delivering that need, the Government should specifically look
at reducing demand, and that has not been picked up on in the
appraisal of sustainability at all, as far as I am aware. When
they look at the alternatives, the alternatives seem to have defaulted
back to, "Well, we have an NPS" or, "We don't have
an NPS" rather than actually saying, "The country has
a need for energy. How can we meet that need? One is to provide
infrastructure and one is to reduce that demand".
Q105 John Robertson:
Has the Government not really tried to reduce demand by trying
to improve homes and the use of power? Do you not feel there has
been enough done there? Is that what you are talking about, or
do you think that maybe we should just cut off power occasionally
and let people get on with it?
Ms Ashley: For one particular
issue, I do not think there has been enough investment in reducing
demand, even down to something as simple as retrofitting existing
homes. If we could have a significant investment in retrofitting
homes and reducing demand, that could have a more significant
impact on our energy needs and may actually mean that we do not
need as much infrastructure as we are currently planning to put
forward.
Q106 John Robertson:
Yet the forecast for electricity usage is on the increase, not
decrease, in the years ahead.
Ms Ashley: Yes, and we are not
going to meet that if we just provide more infrastructure, so
that almost, in some ways, makes it even more important that there
is a big focus on retrofitting existing homes, so we are looking
at heat and electrical demand within homes.
Q107 John Robertson:
Can I move on to one of my pet subjects, nuclear. The nuclear
NPS states that the plan has potential to have an adverse effect
on the integrity of Natura 2000 sites, but states that this is
outweighed by overriding public interest. What are your feelings
on that, and do you feel that this demonstrates the right balance
being struck between the environment and obviously considerations
of need?
Ms Ashley: I think with some of
these issues it depends on spatial location and this comes back
to this issue where, in a lot of the cases, the environmental
impacts of some of these infrastructure applications are focused
far too locally when they need to be looked at strategically and
because they are a national plan, so in the Natura 2000 it covers
the whole of the UK.
Q108 John Robertson:
You said that there is a variant and I got alarm bells ringing
at that point. Are you saying that the local element is taken
out or do you put the local element in? The strategic national
term is for obviously the need to continue, to keep the lights
on, say, so I am not quite sure exactly what you are saying here.
Are you wanting to learn from the process so that we never actually
get to decisions being made?
Ms Ashley: No, I think what we
are worried about is that the environmental impact of a particular
application is only considered as a local impact and it misses
the strategic issue of, in particular, the Natura 2000 sites because
it is an internationally important process and you cannot just
look at it and say, "Oh, we're going to impact on that one
particular site" because that has a further impact on the
integrity of the entire network.
Q109 John Robertson:
But is that not where the biggest impact is locally and you have
to take the local element in?
Ms Ashley: You have to take both
into consideration.
Q110 John Robertson:
And the need part? Does need override—
Mr Greenleaf: I think that is
part of the issue, that it is not set explicitly within the NPS
at the moment. There is a need for all infrastructure.
Q111 John Robertson:
But should it be explicit in the NPS?
Mr Greenleaf: We would like it
to be more explicit, yes. That would help and then within that
would be the spatial elements, the specificity about different
technologies and different energy mixes. That would then help
provide the guidance on the assessment of the impact, particularly
human impacts.
Q112 Miss Kirkbride:
Can I just take you back to what you were talking about with regard
to demand for energy and just what your assessment is on that.
Is it your assessment that, if we were to make the big gains that
could be achieved in retrofitting houses and other easy hits on
energy, the economy could then grow at the rate that the Government
would like to see it, all of us would like to see it, growing
at in the future, or do you also think that we have to look at
economic growth as well as the easy domestic hits for sustainable
energy in the future? I would like some kind of idea of where
you are coming from on this.
Ms Ashley: If you take the nuclear
power stations at the moment that are going through decommissioning,
we understand that a lot of the infrastructure that we have is
getting old and there is an assumption that some of this infrastructure
will be replaced, but I think our position is that we are concerned
that the automatic assumption that you get through reading the
NPSs is we just need lots more infrastructure, whereas in fact
we need perhaps to step back and say, "Okay, what is the
need? How much energy do we need and are there other ways of meeting
that need?"
Q113 Miss Kirkbride:
And what is your assessment of that? How much energy do we need?
Do we need as much as we have got already? Will we need more?
How much will we get out of, as I say, the easy hits on housing?
From your perspective, we need to know what you are really saying.
Are you really saying that we have to cut the demand for energy
and then we can really knuckle down on this NPS stuff, or do you
accept that the economy should be allowed to grow and that we
can get the benefits of energy reduction from other things other
than the economy growing? That is where I want to have a feeling
of where you are coming from on this.
Ms Ashley: I am not sure I am
qualified to answer that one from my perspective within the organisation.
We might have to come back to you with a written response on that.
Mr Greenleaf: In the case of overall
need, it is being demand-driven which will then lead to projects
being proposed, talking here about a new particular mix of technologies
that meet that demand which are slightly separate issues. If we
achieve greater energy efficiency gains than we expect in the
shorter term, obviously the demand for energy will drop and the
projects coming through will be far fewer. Then there is still
a question within that of what mix of technologies should we use
to meet that demand, so I think there are two slightly separate
things there.
Q114 Dr Whitehead:
We would be happy if you wished to provide an additional note
to the Committee on that particular issue.
Ms Ashley: Yes, we could provide
some further input to that particular question.
Q115 Mr Anderson:
Can I ask just for clarification, within the NPS it states that
the Government acknowledges that the plan has the potential for
an adverse effect on the integrity of Natura 2000 sites, but that
the overriding public interest takes precedence. Can you explain
to me just the process of how you think the Government will have
come to that decision, and is that challengeable in any way?
Ms Ashley: We were concerned,
when we read that, that it was a very sweeping statement that
all the nuclear sites were essential and, therefore, we could
claim IROPI for all of them. We are not legal advisers, but I
think that would need to be tested and I think that will be tested.
That is quite a dangerous statement to make, I think, and a robust
case to meet that statement is not made in the NPS at the moment.
Q116 Mr Anderson:
If the case is not made, which it plainly is not, within the NPS,
do you know if any real work is being done to justify this?
Ms Ashley: Not that I am aware
of, no, and I think that needs challenging, if only just to draw
that evidence out if it is there.
Q117 Anne Main:
Just going back to what you were saying about managing need and
knowing how much energy we have and we may not need as many plants
as are being considered, do you think then, crossing your departments,
that it would be appropriate for other strategic pieces of infrastructure
to show how much they may be generating in renewables because,
if other pieces had an obligation to show not only carbon footprints,
but a carbon reduction strategy or an energy strategy, then they
may be contributing to your energy management and, therefore,
you will not need as many strategic gas plants or coal-fired plants
as has potentially been thought about? Do you think that this
idea that other strategic pieces of infrastructure should show
essentially how much they have got in renewables on site, who
has gone for solar photovoltaics on large pieces of roofs, do
you think that that may be a way forward to ensure that not all
the energy needs are being dealt with just simply through coal,
nuclear and gas?
Mr Greenleaf: To clarify the question,
you are talking about within the other pieces of infrastructure,
ports and rail and so on, to integrate them in terms of actually
putting energy on sites?
Q118 Anne Main:
Yes, because you are saying you are not going to know how much
energy you need and, if it is all going to be delivered all by
energy plants, should they be part of the Policy Statements we
talked about earlier, the fact that each big piece of strategic
infrastructure or each major development has to show that it may
be contributing to our energy generation and, therefore, the need
would then decrease for more power stations?
Mr Greenleaf: I think that might
be helpful, but I think that with probably the size of the infrastructure
we are talking about in terms of incorporating some onsite power
generation on the gas storage sites, that would be fairly small
in comparison to large-scale generation.
Q119 Anne Main:
I am just picking up on the retrofitting where you might say that
each little bit might be more helpful than thinking of big pieces.
I do not know where you are coming from on this.
Ms Ashley: We picked up on the
combined heat and power, for example, which is mentioned in one
of the NPSs and we would really like to see that strengthened
so that with any major infrastructure that is taken forward it
has a commitment that it has to have combined heat and power onsite,
because it just seems a crazy—
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