The proposals for national policy statements on energy - Energy and Climate Change Contents


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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