Examination of Witnesses (Questions 260
- 279)
WEDNESDAY 20 JANUARY 2010 (morning)
MR ROBERT
ASQUITH, MS
GAYNOR HARTNELL,
MS GEMMA
GRIMES AND
MR PETER
MADIGAN
Q260 Dr Turner:
Several witnesses have expressed concern that, as drafted, the
policy statements would not in themselves prevent more carbon-intensive
generation coming through (more gas, for instance). They are worried,
as you are, about the expression of need not being clearly related
to government policy on low carbon transition. What would you
like to see put in place, probably in the Overarching Statement,
to establish that these statements are a reflection of government
policy and that in the hierarchy of generating capabilities renewables
must come first?
Ms Hartnell: Renewables are in
a unique situation, in that there is a mandatory target for renewables
which does not apply to other technologies within the energy mix,
but the decision on the carbon intensity of proposed generation
projects should not be a planning decision. We have a raft of
environmental policies dealing with carbon emissions. The IPC
should be about judging a proposal in a specific location put
forward by developers. It is doing a different task. If the Government's
policy is to let the market come forward with technologies within
the framework it sets for environmental policy, we would argue
that the IPC should not be doing that job.
Q261 Dr Turner:
You have said in your evidence that you want a further expression
of need in the policies.
Ms Hartnell: I do not think that
is contradictory to what I have just said. Whatever other generating
capacity may or may not get consent, renewables are striving to
meet a certain target. Renewables would not be constrained off
the system, if there was a need to constrain off, because too
much capacity had been consented and was seeking to generate.
It does not affect renewables.
Q262 Dr Turner:
It does if it is all too easy to invest in non-renewable technologies,
does it not?
Ms Hartnell: It would become less
attractive to invest in non-renewable technologies—and this
is a market decision—if the view is that those technologies
or those plants would be constrained off more as a consequence
of meeting the renewables targets than other capacity within the
system.
Q263 Dr Turner:
If there is no constraint in the planning system and they are
cheaper, then they are attractive to investors, are they not?
Ms Hartnell: Not if they are not
allowed to generate because they are constrained off, or not if
they are not able to make enough money through generation—but
it is a market decision and the market can take care of that.
Mr Madigan: We would support the
REA's comments on that. We support a market-based approach to
bringing technologies forward. As Gaynor said, the IPC should
be making consenting decisions and the issues of priority should
be dealt with by other government policies. It is not for the
NPS to pick technologies.
Q264 Dr Turner:
Your faith in markets is very touching but it has not been borne
out by experience so far, has it?
Mr Madigan: If the markets fail
to deliver, then the Government can bring in further policies
to address that. But that should be done separately from the NPS.
There is a danger if you set firm mix figures within the NPS.
It is a very inflexible mechanism and it would be difficult for
the industry to respond.
Q265 Dr Turner:
I am not suggesting that the NPS should set firm figures. Of course
the Committee on Climate Change is also involved in the statutory
consultee, so that point should be covered. I am trying to elicit
from you what both bodies want to see in the NPSs as a firmer
expression of need.
Ms Hartnell: Setting out the context
of the renewable target in terms of the Renewable Energy Directive;
saying things like, for example, "If we fail to move as swiftly
as anticipated on renewable electricity expectations, then the
heat contribution will have to rise", or other contributions
will have to rise. A discussion of that would be useful. Perhaps
some reference to greater efficiency across the board would be
helpful, and a recognition that in the past we have struggled
to meet targets. Perhaps some ranking of where we are in the European
mix in terms of other Member States and the fact that our trajectory
towards meeting our target is steeper than virtually any other
Member State because our starting point is so low and our target
is relatively high.
Q266 Dr Turner:
What you are saying, as I understand it, is that you want to set
out the arguments, for a hierarchy of generation and energy approaches,
and you want the IPC to work out the conclusions, whereas in fact
the IPC is there as a planning body, not as an energy policy body.
Ms Grimes: We are saying that
we want existing government policy in a range of sources condensed
and made clear within the NPSs and the Overarching NPS and the
Renewable NPS. Also, that it is not the role of the IPC to pick
technologies. Their role is to determine whether the applications
in front of it are acceptable in planning terms. It is the role
of the market to bring those applications forward to the IPC,
and we believe from our perspective—and I think the REA
would agree with this—that the market has proved very capable
of putting forward the applications, it is the planning process
historically, particularly in the Town and Country Planning regime,
that has proved ineffective in determining those projects in accordance
with national policy, I think it is fair to say.
Q267 Dr Turner:
That is why we are here discussing these, because the current
planning system has totally failed to deliver and has been an
obstacle to delivery. It is an intention to remove that obstacle.
I am still unclear just what you want the expression of need to
do. Does it need to be, as Gaynor has just suggested, virtually
a thesis on energy considerations, or a clear directive that the
Government sees the desirability of renewables as opposed to carbon
intensive generation?
Ms Grimes: It needs to adequately
express the need for renewables, based on the existing policy
that is already out there. We do not feel that all existing policy
that is out there is currently within these documents—and
I referred earlier to the issues about the 2020 targets and binding
cuts in CO2 emissions not being explicitly referred to in section
2.1 of the Overarching Energy NPS, so those need to be brought
in. It is the fact that in existing planning policy for renewables,
these things are all over the place. The PPS is quite old now—and
we will possibly come to that later in further questions—but
it is that central point to which the IPC can go for the latest
thinking on government policy and then know the weight that they
need to accord to that need. At the moment the direction to the
IPC as to the weight to be given to the need is missing and the
full details to the extent of that need we feel could do with
strengthening.
Dr Turner: It sounds as if you would
be satisfied by a sentence or two and Gaynor would want a few
paragraphs.
Q268 Chairman:
Let me put it another way. The Government has very firm renewable
targets. How is the IPC going to take those into account in its
decision-making?
Ms Hartnell: It is going to start
from the perspective that the need case does not need to be demonstrated
because we have stretching targets, and it will then move straight
on to considering the individual characteristics of the project
being proposed.
Q269 Chairman:
Suppose there is a feeling that many people share that we are
not going to meet these targets, what should the IPC do?
Ms Hartnell: Again, the IPC is
not charged with meeting the targets. This is just a general observation:
the Renewable Energy Association does not have any problem with
this approach, except that we feel it does not really go far enough
and it will not really deliver much difference for the smaller
projects, but previously these projects would have been taken
under the section 36 process, by the Secretary of State, within
the department that is charged with delivering the targets. If
it understood the need very clearly, now it is just expressing
that need via a third party, the IPC, to carry out things that
it could have consented fairly quickly, should it have wanted
to, before.
Q270 Sir Robert Smith:
To sum it up, the key part of the guidance is that there should
not be a barrier holding back those developments. If the Government
are not meeting their target, then the planning system should
not be a barrier to the meeting of that target, but other parts
of public policy, like the price of carbon and various other factors,
should be there trying to bring forward the demand to make those
applications.
Ms Hartnell: The Government sets
a policy framework to try to steer the generation mix in the shape
it wants to be. In relation to Des Turner's comments about us
being very comfortable with markets, I would like to point out
that we are very pleased that we have a mandatory renewables target.
We would not want that to be left to the market. Within that unique
position, our point is that we are comfortable, we have these
targets, we cannot see why they are not expressed more clearly
in this document, but really we are slightly disappointed that
things do not go further to bring efficiency to the rump of the
renewable energy scene which is these smaller projects.
Chairman: Let us move on to another issue,
the Nuclear NPS. The NPSs are not site specific. Mike, would you
like to pursue that.
Q271 Mr Weir:
We have had evidence from other witnesses, the Campaign for the
Protection of Rural England in particular, seeking a more spatial
approach to the NPSs. In particular, they suggested that there
should be a zonal approach for development, particularly of renewables.
What are your views on that?
Ms Grimes: We disagree with the
CPRE on this. We are both aware of one another's perspectives.
We believe that this would be a significant departure from existing
government policy on energy. It would result in a significant
increase in costs all around, both to those carrying out the identification
of zones, and particularly to the industry in having to reassess
all its current projects in the planning system. There is a significant
backlog in the TCPA planning system particularly and we do not
believe that we can afford to brush those aside, given that we
only have ten years to meet our 2020 obligations. The resource
intensive and costly process would also be very time-consuming
for any organisation that does this, whether it is nationally,
regionally or locally. Based on past experience, I would imagine
there will be a significant amount of time spent debating the
public pros and cons of having it here or having it there. The
evolution of technologies and the evolution of mitigation measures
also means that if you identify a particular zone, that zone may
then become less viable for particular technologies or other areas
may become more viable. You limit yourself by making time-specific
proposals that may then need to change later. We would also say
that, based on past experience, a zonal approach has not been
especially effective and there are particular examples that we
could go into relating to a delay in bringing forward the necessary
renewables.
Q272 Mr Weir:
The other side of the coin that has been put forward to us is
that without a more spatial approach it is very difficult to get
people involved in discussing the NPSs, because people only get
interested when it is in their own area—which is the benefit
of the nuclear one. The other problem is that without a more spatial
approach it runs up against the local planning system. You may
have the IPC looking at the development but a local planning system
looking at infrastructure serving that development, and you can
get a conflict between the two. What are your views on that?
Ms Grimes: The system that we
have in place at the moment is a criteria-based approach and that
is the approach that we would recommend going forward, because
that provides the same level of protection without risking the
unnecessary constraints on development that you might get if you
have a zonal approach. Developers and applicants are in the best
position to assess where they feel it is most appropriate to site
their projects.
Mr Asquith: One of the problems
with the spatial type of approach to which you refer is illustrated
by the pace of technological change in various renewable sectors.
I am working in a renewables sector at the moment which is still
quite new, with new technology. Having been involved, some time
ago now, with the original PPG-22 on renewable energy, there is
a realisation that by the time that kind of guidance gets published
it is almost inevitably, to a certain extent, out of date. The
wind sector is a good example, in that the nature of wind turbines
has changed significantly over the period since the early 1990s
when planning for renewable energy started to become as prominent
as it is. That is one objection that we have. Another is the experience
I have had of the amount of time it takes local planning authorities
and other organisations to get to grips with that and then to
produce policy. It takes time and resources, and these are organisations
which are resource constrained. Third, there is the issue that
however you word a spatial policy to say that this is the preferred
area or an area of search, it does immediately, however carefully
you word it, demote all other areas to a lesser status. There
are many examples of projects which have been promoted in areas
which might not have been immediately obvious but which have been
perfectly acceptable projects to come forward.
Q273 Anne Main:
I would like to pick up on what Paul was just saying and on something
Gemma said earlier. You said that immediately constrains other
areas from being investigated, but not if, say, a traffic-light
approach was adopted. Green: absolutely great—this would
be a great area; amber: maybe you need to think about it; and
red: absolutely no. There are other ways of doing it. The zonal
approach has just been touched on. Do you think there could be
other ways of trying to adopt a more spatial approach?
Ms Hartnell: We cannot really
see any particular advantage in that kind of spatial approach
at all. For a start, it takes resources, and there does not seem
to be any particular advantage in doing it. All it would give
is an idea where some planners think projects are more likely
to be proposed than not. Those people living within an area of
search would be sensitised, because their area was zoned for development.
It might give people living outside that area a false sense of
security.
Q274 Anne Main:
Do you accept the public is deeply unhappy about some major infrastructure
projects—not just energy: these National Policy Statements
are going to cover various major infrastructure projects—and
for the public there has been an anticipation that these statements
would be more site specific, more area specific?
Ms Hartnell: It would be simply
misguided for them to be site specific, though. Renewable energy
project developers are the people who know best where a project
should be. A planner could not second-guess all of the numerous
things that a project developer would take into account when considering
where a project should go. It is their day job. That is what they
do. They are very experienced.
Q275 Anne Main:
A renewable energy company may know where the best place to put
it is, but that does not necessarily mean—and you have to
take the public with you on this—that is where the public
will accept it. There has to be a deal between both the public
and developers. That has been a cry across my constituency and
I am sure across many others, that it is greedy developers having
their way. If we are to buy in to some major infrastructure, do
you not accept that there has to be something that the public
can say, "I accept that is a reasonable formula to go forward"?
At the moment it appears to me that you are still saying it should
be a developer-led thing and there should not be anything that
shifts the balance somewhat to more community engagement with
the projects.
Ms Hartnell: There already are
a lot of areas where a developer would not propose a project because
of, say, areas of outstanding natural beauty, national parks or
whatever. When a developer comes forward with a project, they
will have considered a very long list of things, some of which
could be indicated on maps; others may not be very well indicated
on maps.
Q276 Anne Main:
The strength of need that is quoted in many development projects
is going to be very, very high, simply because our targets are
so high. The need is already going to be an overriding concern.
For example, you do not build in the Green Belt unless you can
demonstrate exceptional circumstances. This high level of need
is going to be a determining factor already. Therefore, do you
not accept that there should be potentially some way of writing
into this an agreement, with the community as a whole, as to how
we are going to ensure that the two halves of this equation are
met: what the public want and what the need is and the developer
wants?
Mr Madigan: It might be worth
mentioning the pre-application process and the IPC process. At
that stage there is a greater need to engage with the local community,
so there will be considerable amounts of time devoted to getting
local opinion fed into the process. Within the framework as it
is currently set there is that opportunity.
Q277 Anne Main:
People do often say, "A consultation is that you are going
to ask me my views, and then you are going to determine it anyway
because it says in the rules that this is what could happen."
I understand the pre-planning consultation process but—trying
to put on a public hat now rather than a developer's hat—do
you accept that to ensure that public engagement is enough and
that the public goes with you on these applications there should
be potentially something within the statements that reflects that?
Ms Grimes: We fully understand
the position that you are coming from. We are very aware that
certain elements of the public get very concerned about wind energy
projects. However, based on past experience, because this has
been tried in a number areas—it has been tried in terms
of broad areas of search in England and Scotland, it has been
tried in terms of strategic search areas in Wales, and then we
have different local authorities trying their own thing on their
own patch as opposed to a more regional approach—all of
which have involved detailed public consultation but, nonetheless,
despite that detailed consultation process, those areas, once
identified, whether they are broad areas, whether they are strategic
search areas, whether they are preferred areas—and it is
an issue of semantics to a degree—when placed on maps in
development plans do not resolve any of the debate and contentious
discussion around renewable energy projects.
Q278 Anne Main:
You want to take it out, then, so that if we do not have it in,
we cannot.
Ms Grimes: We do not genuinely
believe, from all angles, that it adds any value. It does not
make things clearer for the public or for the development industry.
It does not make the decision-making process any more streamlined.
It does not increase the number of consents. It does not reduce
the amount of time debating issues about the need, whether there
is the extent of the need and whether visual impact outweighs
the need. All these things are still thrown up in the mix and
we simply feel that it adds another thing on the list of things
to shout about at public inquiry. It is really not something that
aids the process.
Q279 Chairman:
Remind me: what is the threshold for onshore wind farms?
Ms Grimes: Fifty megawatts.
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