House of Commons - The proposals for national policy statements on energy

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

3 TECHNOLOGY SPECIFIC ISSUES

43. The five draft NPSs that sit under the overarching energy NPS, EN-1, contain additional information on specific types of energy infrastructure, which provides further direction to the IPC on the factors it will need to take into account when considering planning applications. They are meant to be read in conjunction with EN-1, which contains guidance on generic impacts and assessment principles that apply across various types of energy infrastructure. We heard a range of views on different aspects of EN-2 to 6. Though not exhaustive, this Chapter examines the main specific issues raised during our inquiry.

Carbon capture and storage

44. The Government's policy on carbon capture and storage (CCS) is set out in EN-1 with further guidance in EN-2, the Draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure. We took evidence on two specific issues relating to CCS. First, the criteria for demonstrating carbon capture readiness (CCR); and second, the need for guidance on future carbon dioxide transportation networks.

CARBON CAPTURE READINESS

45. The draft NPS requires that all combustion-powered generating plants over 300 MW that are subject to the EU's Large Combustion Plant Directive (LCPD) will need to demonstrate 'carbon capture readiness' (CCR). This includes coal, oil, gas and biomass-fired plant. The draft NPS states that, among other criteria, the IPC will have to assess the technical and economic feasibility of retrofitting the developer's chosen CCS technology at some point in the future. If the IPC is not satisfied that it will be technically and economically feasible to retrofit CCS, the Commission should reject the application.[74] The requirements reflect the Department's recently published guidance on CCR, which is meant to implement one aspect of the EU Directive on the Geological Storage of Carbon Dioxide.[75]

46. Some witnesses expressed concern at the need to demonstrate CCR.[76] Scottish and Southern Energy, for example, argued that given CCS is still at the pre-demonstration phase it would not be possible to conduct a meaningful technical and economic CCR assessment, and that the effect of the requirements would be equivalent to a "moratorium" on all fossil fuel-based generating capacity other than the four plants to be developed under the Government's CCS demonstration programme.[77] Scottish Power agreed, noting that the requirement to show economic feasibility was "an over-implementation of the directive and [...] should be struck out".[78] The UK Business Council for Sustainable Energy argued for a phased approach, stating: "Until you can prove that it can work at commercial scale, then the industry is just not in a position to comply".[79] Elsewhere, RWE Npower told us: "The Government's intended light touch approach, in that developers should demonstrate no barriers exist to an eventual CCS retrofit, must be retained and requirements must reflect the early stage of CCS technology development".[80] On the other hand, the Institute for Environmental Management and Assessment (IMEA) pointed out that: "there is no certainty that CCS will prove to be technically and financially feasible at the scale required to mitigate emissions on the scale of fossil fuel generating stations" and that a failure to deliver "would lead to significant problems in achieving the UK's long-term legally binding carbon reduction commitments".[81]

47. In evidence, the Department noted that the requirement to demonstrate CCR had already been in place for a year and that it did not seem to have deterred applications from coming forward under the old planning regime.[82] Officials told us the criteria were more about ensuring that applications were not submitted where it was clear it would never be feasible to retrofit CCS.[83] This was the view of the Environment Agency whose responsibility under the guidance is to assess technical feasibility.[84] The IPC also told us: "it is not for us to consider the economic viability of the individual project; that is a matter for the promoter".[85]

48. We recommend the Department looks again at its criteria for assessing carbon capture readiness (CCR) as set out in the draft NPS to examine whether they reflect sufficiently the EU Directive on the Geological Storage of Carbon Dioxide. The IPC's interpretation of the criteria will be crucial in determining the success of applications before it. We therefore also recommend the Government provides further clarification in the NPS on how it expects the IPC to assess applicants against the CCR requirements, having regard to the risks this might pose for the Government's carbon reduction targets. Clarity is also required about the necessity for the IPC to assess the economic feasibility of CCR, given the Commission's assertion to us that it is primarily a matter for the developer. This appears to contradict the draft NPS and the Government should settle the matter conclusively. We also recommend that the Government looks again at the wording of the NPS in relation to gas CCS, as concerns have been raised that the need to demonstrate economic feasibility could prevent its development.

CARBON DIOXIDE NETWORKS

49. A further CCR requirement is that applicants must demonstrate the technical feasibility of transporting the captured carbon dioxide to the proposed storage area.[86] The Government has also said that at present only storage projects offshore are to be considered.[87] Apart from these references, though, there is relatively little discussion of the future development of carbon dioxide networks in either EN-1 or EN-2. For example, there is no reference to carbon dioxide transportation in section 2.2 of EN-2, which considers the factors influencing site selection by developers.

50. In evidence to the Committee several witnesses highlighted the lack of attention given to carbon dioxide networks.[88] For example, the Energy Networks Association told us: "carbon dioxide pipelines are not included in the NPSs, and these are [...] vital to carry carbon dioxide from power stations to a secure underground storage place".[89] Prof Dieter Helm emphasised the fact that the market would not be able to deliver a carbon dioxide network in an efficient and integrated way, which therefore made the role of the NPSs particularly important in providing a strategic overview.[90] Elsewhere, the Environment Agency said "it was an omission that should be rectified".[91] Some argued that "a separate NPS should be developed that addresses the carbon transport infrastructure and carbon storage infrastructure, to allow effective planning of these strategic resources, and for the right market signals to be sent for power plant siting decisions".[92] In response, the Department accepted this broad criticism, noting it did not think that at present there was sufficient guidance in the draft NPSs, for example, on the consenting of the pipelines.[93]

51. The development of a future carbon dioxide network will be integral to the future deployment of carbon capture and storage. It is at present a glaring omission from the draft energy NPSs, which we recommend the Department rectifies.

Biofuels and energy from waste

52. The Draft National Policy Statement for Renewable Energy Infrastructure, EN-3, sets out the specific assessment criteria for biomass and energy from waste. In evidence, some witnesses raised concern at the current treatment of the fuel source for both these technologies. For biomass, EN-3 stipulates: "the IPC does not need to consider the source or sustainability of the proposed biomass fuel to be used within the proposed plant".[94] It states this is because operators of biomass plants already have an obligation to report annually on the sustainability of their fuel sources, including the volume, type of biomass used, country of origin and previous land use. However, under the UK Low Carbon Transition Plan the Government expects a large increase in the level of biomass generation, and the Environment Agency told us the majority of the fuel source for this would be from North and South America or Indonesia.[95] The Agency said it did not believe the provisions were in place to ensure that, for example, imported wood-chip for biomass plant use would be sourced from Forestry Stewardship Council-certified wood. The Agency described the current requirements as "weak" and "essentially [...] voluntary".[96] The Royal Institution of Chartered Surveyors (RICS) shared this concern, stating the origin of the fuel source for biomass should be a factor the IPC considered.[97]

53. In response, the Renewable Energy Association countered that the emissions arising from the ocean transport of biomass did not significantly increase the carbon footprint of the technology when comparing against coal.[98] It is worth noting, though, that transportation is just one aspect of the sustainability of an imported fuel source. As the Minister noted, the general principles on this should be "first of all, that it delivers carbon dioxide savings, second, that it uses land responsibly, third, that it does not undermine global food supplies or inflate prices, and overall [...] that it is sustainable".[99] Officials also told us that although EN-3 currently reflected Government policy on biomass fuel sources, the Department was negotiating at a European level with the aim of agreeing a set of standards, which they hoped could be incorporated into the designated NPS.[100]

54. On energy from waste, Friends of the Earth argued that this technology should not be included in EN-3 because a large proportion of its fuel source was non-renewable. Instead, it should be part of the fossil fuel NPS.[101] A further concern from the NGO was that greater development of energy from waste would result in direct competition with recycling and re-use as alternative waste options. In support of this argument, the organisation noted that while total waste arisings had now either stabilised or begun to fall, recycling rates were still increasing.[102] This could therefore create a problem over time as energy from waste plants would wish to have long-term contracts with local authorities for their fuel source. In response, the Renewable Energy Association told us the fuel feedstock for energy from waste would be of too low a quality to be available for recycling.[103] Nevertheless, the Environment Agency told us the NPS should "identify [...] that waste is not diverted from re-use or recycling where those are feasible options".[104] In evidence, the Minister agreed that energy recovery was near the bottom of the Government's hierarchy of preferred approaches to dealing with waste.[105] EN-3 does draw the IPC's attention to the waste hierarchy, and requires: "the proposed waste combustion plant is of an appropriate type and scale so as not to prejudice the achievement of local, regional or national waste management targets".[106] However, the Department acknowledged that it may need to re-consider the issue to ensure it had said what it intended in the draft NPS.[107]

55. The current draft NPS on renewables, EN-3, reflects the Government's current policy on the fuel sources for biomass and energy from waste power plant. However, we are concerned that the IPC is directed not to consider the sustainability of biomass fuel. Although to do this would require a change of policy, we believe the existing draft guidance would mean the IPC would not be able to examine fully all adverse environmental, social and economic impacts as it is required to do in paragraph 4.1.1 of EN-1. We therefore recommend the Department revises EN-3 to require all biomass power station applicants to make a full assessment of the sustainability of their fuel sources. We also recommend that the Department re-assesses whether its current guidance on energy from waste ensures that only waste that cannot otherwise be economically recycled or reused is sourced as feedstock for energy from waste production.

Other renewables

56. EN-3 provides guidance for the IPC's consideration of biomass and waste combustion projects, as well as onshore and offshore wind. It does not include other renewables such as wave, tidal, and solar power because no onshore projects over 50 MW or offshore projects over 100 MW are expected in the near future that do not use any of the technologies already dealt with in EN-3. This could change later in 2010 if the Government decides to pursue one of the proposed Severn tidal projects. The British Wind Energy Association (BWEA) told us it was happy with the exclusion of wave and tidal power from the current draft renewables NPS, although it believed a section dealing with these technologies would need to be added at an appropriate time.[108] In contrast, the Renewable Energy Association felt wave and tidal power had been "dealt with poorly" in EN-3, and argued the current guidance was not sufficient.[109] Any wave and tidal projects under 100 MW will be consented by the Marine Management Organisation (MMO). The BWEA also emphasised the need for consistency between the approaches taken by the MMO and the IPC for different sized projects, in the same way that this will be important for the two onshore consenting regimes, which we discuss later in this Report.[110]

57. We agree that at this stage there is no urgency to include technologies such as wave and tidal in the renewables NPS. Nevertheless, EN-3 should set out the Government's intentions for how these technologies will be dealt with in future versions of the NPS. We note too that a decision over whether to pursue one of the proposed Severn tidal projects will require a substantial revision of EN-3, if not a new NPS in its own right.

Combined heat and power

58. EN-1 states that: "In developing proposals for new thermal generating stations, developers should consider the opportunities for combined heat and power (CHP) from the very earliest point and it should be adopted as a locational criterion".[111] The IPC is also told to give "substantial additional positive weight" to applications that incorporate CHP.[112] Applicants not proposing to use CHP will be expected to show: why it is not economically feasible or practical; potential future demand sources for the heat load; and demonstrate provisions within the proposed scheme for exploiting any such demand should it arise.

59. We heard evidence from the Institution of Civil Engineers (ICE) and the Environment Agency (EA) that argued strongly for the NPS to give greater direction to the IPC to favour planning applications that proposed CHP.[113] The EA told us: "We see an absence of any strong statement on the priority of energy policy being about energy efficiency and using energy well".[114] The ICE went so far as to suggest the Commission should not consent new infrastructure unless it made use of the waste heat produced.[115] Both organisations acknowledged that to do so would introduce a spatial element in guiding developers' decisions on where to locate plant because they would need to find a suitable demand load.

60. We accept that, in the absence of a targeted policy to encourage combined heat and power, it is difficult for the NPSs to indicate a greater preference for CHP than that which is already present in the current draft. If in the future, the Government decides to introduce a more spatial approach to the non-site specific NPSs, we recommend it considers whether it could use this to promote further deployment of CHP where it is cost-effective to do so.

New nuclear build

61. The Draft National Policy Statement on Nuclear Power Generation, EN-6, is arguably the most controversial part of the proposed NPS framework and the area on which the Committee received most evidence. As noted in Chapter 1, we have not examined in depth each of the sites proposed for potential nuclear development. However, several issues emerged, which we believe merited particular comment. In this section we consider the treatment of radioactive waste management in the draft nuclear NPS, and the relationship between the IPC regime and the other regulatory processes that will take place alongside future planning applications. We also examine the Department's decision to exclude Dungeness from the draft NPS.

RADIOACTIVE WASTE

62. EN-6 states that: "Having considered this issue, the Government is satisfied that effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stations. As a result the IPC need not consider the question".[116] It bases this conclusion on the consideration of three factors. First, it believes that deep geological disposal will be technically feasible. Four years ago, the Committee on Radioactive Waste Management (CoRWM) reported that: "within the present state of knowledge, geological disposal is the best available approach for the long-term management of all the material categorised as waste".[117] EN-6 also quotes a finding by the British Geological Survey that up to 30% of the UK has suitable geology for such a facility. Although the Government already requires a solution to the UK's existing radioactive waste legacy, it believes the waste arising from a new generation of nuclear power stations will not present significant new issues in terms of its disposability. This approach has also been adopted in Finland and Sweden, which are already developing geological disposal facilities that are expected to begin operation by 2020.

63. A second factor is that the Government believes a suitable site can be found to host the facility. In 2008 it published a White Paper on Managing Radioactive Waste Safely, which set out the framework for site selection. The process is based on the principle of voluntarism and partnership between the project and the local community as recommended by CoRWM. Because of this, there is no fixed timetable for delivery. EN-6 notes the Nuclear Decommissioning Authority's (NDA) assessment that a facility could begin operation around 2040, although it might not start to receive high-level waste until 2075.[118] The third factor underlying the Government's conclusion on waste is that "geological disposal will be preceded by safe and secure interim storage".[119] The NDA told us new nuclear power stations would have a higher rate of fuel burn-up that would give rise to waste that was hotter and more radioactive. This would require on-site storage until it had cooled sufficiently to be moved to a long-term disposal facility.[120] EN-6 states that interim storage on-site may be required for up to 160 years from the commencement of the power station's operation, although the NDA told us this was a conservative estimate and that the actual time required may be some years less.[121] Overall, the Minister told us: "I am confident we have the right policies for dealing with waste, both in terms of interim storage and eventual disposal in a geological disposal facility".[122]

64. The NDA strongly supported the Government's assertion that effective arrangements will exist to manage future radioactive waste.[123] The Nuclear Industry Association also said: "We are confident that the arrangements are now in place for a satisfactory resolution to the waste issue".[124] Yet in evidence a large number of organisations and individuals questioned both the Government's conclusion and its underpinning evidence.[125] For example, Prof Blowers, who was previously a member of CoRWM, told us he believed the Government had misrepresented the Committee's conclusions on the feasibility of deep geological storage, stating: "in fact it is unknowable whether effective arrangements will be in place".[126] He said there had not yet been sufficient research to conclude definitively that geological disposal would work. Others raised concerns over the cost of a facility, which is as yet unknown. The Sustainable Development Commission noted, for example, that the complexity of dealing with high-level radioactive waste could prove so expensive that it undermined the commercial viability of new nuclear build.[127] The Government has already set out that the developers of new nuclear power stations will have to pay the full cost of dealing with the waste they produce.[128]

65. Witnesses also questioned whether the Government had made sufficient progress in identifying a site. The NDA told us it was at the first stage of the process set out in the 2008 White Paper. To date three communities have expressed an interest in hosting the facility—Copeland Borough Council, Allerdale Borough Council and Cumbria County Council.[129] The British Geological Survey would now look at the areas proposed to determine their suitability. The NDA also said it was not possible to define the timeline for delivery because this would depend on the local community.[130] However, the Sustainable Development Commission told us it did not believe there had been much tangible progress since 2008, stating: "we do not think that just having the documentation in a White Paper [...] really cuts the mustard".[131] Prof Blowers argued there was no guarantee that a community would be willing to host a facility, despite the current expressions of interest.[132] Greenpeace noted too that even if communities did come forward, their geology may prove unsuitable.[133] Both the SDC and the Environment Agency believed that as a minimum the Government should establish a timetable with milestones for the various stages required for the delivery of a geological disposal facility.[134]

66. Witnesses also criticised the treatment of interim storage in EN-6. As noted already, high-level radioactive waste could remain on-site for up to 160 years from the commencement of a power station's operation. Nuclear Waste Advisory Associates argued that the draft nuclear NPS provided little information on how spent fuel would be stored and managed at the reactor sites, and whether a spent fuel packaging plant would need to be built on-site at some point in the future.[135] This concern was also shared by Prof Blowers, who contrasted the Government's voluntary approach for a geological disposal facility with that for nuclear new build sites, noting that the latter would still be hosting high-level waste for many generations. He highlighted CoRWM's original recommendation that voluntarism should "be applied to new central or major regional stores at new locations if they are to inspire public confidence".[136] However, he told us: "communities hosting spent fuel stores will be given no opportunity to consider whether they wish to volunteer to host a long-term radioactive waste facility".[137]

67. One issue underlying the concern over the length of time for interim storage was the potential risk of flooding due to rising sea levels. The Nuclear Consultation Group noted it was almost impossible to predict what the impact of climate change would be across the period when nuclear sites would be active, and that the draft nuclear NPS did not consider adequately the risks over the likely lifetime of a project.[138] In evidence, however, the Minister said he did not believe that the length of time nuclear sites would have to provide interim storage of high-level waste should be a relevant consideration for the IPC.[139] Greenpeace told us: "It is almost as if somebody outside Hinkley Point could have a discussion in front of the IPC about whether they wanted the gates painted blue, green, or yellow, or the reactor dome pink, but these major issues around nuclear spent fuel [...] would be outside of its remit".[140]

68. In 2006, the then Trade and Industry Committee was told by the chief executives of E.ON UK and EDF Energy that achieving a long-term solution to the UK's existing radioactive waste legacy was vital, not only from the perspective of helping gain public acceptance of new build, but also to reassure potential investors and operators in the sector.[141] In evidence to this Committee those companies supported the Government's position in EN-6, stating there were "no apparent technical show-stoppers" to delivering deep geological storage, and highlighting their existing experience of managing on-site interim storage.[142] EDF Energy also said that there had been sufficient progress towards developing a long-term facility to give them confidence to move ahead with the company's plans, although it would want to ensure the Government was still making progress at the time it submitted a planning application for a new nuclear power station.[143]

69. Finally, we received conflicting evidence on the question of whether the planning application for a geological disposal facility would be dealt with by the IPC or by the Local Planning Authority for the community that would be hosting the depository. The Nuclear Decommissioning Authority told us it believed the decision would be made by local communities as this would be in line with the voluntarism approach used to identify the site.[144] However, the Minister said he was minded for the consenting process to be the IPC's responsibility. He told us, though: "we have not made a firm decision, and, frankly, we are not really anywhere near having to make a decision".[145]

70. Planning consent from the IPC for new nuclear power stations will entail the storage of high-level radioactive waste on-site for up to 160 years. From the perspective of the community affected, it is a misnomer to describe this as interim storage as it will be several lifetimes between the commencement of a power station's operation and the eventual removal of waste from that site. A key objective of the new NPS framework is to focus discussion on planning applications on site-specific issues. As such, we believe on-site storage cannot be ruled out from the IPC's deliberations and that the nuclear NPS should contain significantly more detail on what interim storage will entail for local communities and for the integrity of any site chosen.

71. We do not dissent from the process adopted by the Government for identifying a site for the eventual storage of radioactive waste deep underground. However, we received conflicting evidence over whether this process would yield a suitable site and if the proposed approach of geological disposal was technically feasible. We are not convinced that the progress to date supports the Government's robust assertion that suitable arrangements will be in place to manage the UK's waste legacy. However, we note too that the Government has no choice but to find a solution, regardless of a decision on nuclear new build. Furthermore, we agree that the waste arising from new nuclear power stations will not pose a significant additional challenge in terms of finding a permanent storage solution. Therefore, as this is an issue of national policy, the political and ethical elements of which have been debated widely over the past five years, we agree that this should not be a consideration for the IPC with regard to individual applications.

72. Nevertheless, we believe the Government must continue to demonstrate progress in delivering a geological disposal facility for radioactive waste. Accordingly, we recommend the Department now sets out key milestones in EN-6 and reports progress against these to Parliament on an annual basis. This should include establishing which body will be responsible for consenting the site.

PARALLEL REGULATORY PROCESSES

73. EN-6 states that: "the IPC should make its decisions in relation to a development consent application on the basis that: the relevant licensing and permitting regimes will be properly applied and enforced; it does not need to consider matters that are within the remit of the nuclear regulators; and that it should not delay a decision on whether to grant consent until completion of the licensing or permitting process".[146] For example, alongside the consultation on the draft NPSs, DECC has also been consulting on the Regulatory Justification of new nuclear power stations, which is required under EU law.[147] Elsewhere, the Environment Agency and Health and Safety Executive are conducting a generic design assessment of the two reactor types proposed for use in the UK. Greenpeace, however, expressed concern that the IPC might begin to consider a planning application for a new nuclear power station while these and other processes had not yet completed.[148]

74. We believe it is not the role of the IPC to concern itself with the regulatory processes relating to new nuclear build that may be conducted in parallel to its own decision-making on planning consents, and which might otherwise lead to confusion and a duplication of efforts. However, the Commission should at least have cognisance of the wider regulatory framework as it is likely that it will receive submissions on issues outside of its remit when considering applications. We would therefore expect regular and open communication between the IPC, the Environment Agency, the Health and Safety Executive and other relevant bodies on these matters.

DUNGENESS

75. The sites proposed as suitable for nuclear development in EN-6 represent the outcome of a strategic siting assessment (SSA), which took place in 2009. Out of the 11 sites nominated by developers, one failed the assessment—Dungeness. This was on the basis that it would be unlikely to be possible to mitigate the adverse effects on a Natura 2000 (N2K) site, which overlaps with the footprint of the proposed site.[149] N2K sites are designated because of their importance to habitats and species of importance to European conservation.

76. Several witnesses voiced concern at the exclusion of Dungeness from EN-6. The Nuclear Industry Association (NIA) argued that a new power station would not pose substantially different impacts to those already created by the existing two power stations at the site. The NIA also noted that most of the sites included in EN-6 posed potential adverse effects on adjacent N2K sites, stating: "it is not clear why the Dungeness site alone should be excluded on this criterion".[150] EDF Energy and Scottish Power also questioned the ruling-out of the site. Both believed the list of sites available for the IPC to consider should not be constrained at this stage, with Scottish Power noting that: "the issues around the sites of special interest can be adequately addressed".[151] The site's exclusion has also disappointed representatives of the local community. Both Shepway District Council and Hastings Borough Council provided extensive arguments as to why it would be wrong, at this stage, to reject any new nuclear build at Dungeness: "[…] there are good reasons to believe that any environmental impacts at Dungeness can be mitigated and managed successfully. The Infrastructure Planning Commission (IPC) could take any site-specific decision on the suitability of Dungeness for nuclear build, based on a full project-level application for development consent […] Dungeness should be reinstated as a nuclear build site within the finalised nuclear NPS for approval by the Secretary of State".[152]

77. Natural England, whose evidence influenced significantly DECC's decision not to pursue Dungeness, told us that for all the other sites there was some potential either to mitigate or compensate for the likely environmental impacts. The organisation said, however: "Dungeness is a very special place and is the result of 5,000 years' worth of interaction between the sea and land and it is simply not possible to recreate it anywhere else".[153] The proposed site, along with the existing power stations, are on the largest example of a shingle beach in Europe.[154] The SSA had also highlighted concern regarding flood risk, although this on its own was not felt to be sufficient to rule out the site. Acknowledging that the decision was controversial, the Department defended its position, citing the unique nature of the shingle beach, and the fact that given the potential availability of 10 more preferable sites, there was not an Imperative Reason of Overriding Public Interest (IROPI) for developing there.[155] The Minister told us: "I certainly do not have a closed mind to this issue, but equally the advice I received [...] would suggest that development in Dungeness would be very, very difficult indeed".[156]

78. We note the reasons for the Government's exclusion of Dungeness from the draft nuclear NPS and the arguments against this decision put by the industry and the local community. We recommend the Department maintains an open mind throughout the current consultation, that it considers carefully the evidence submitted to the Committee by Shepway District Council and any other evidence submitted during the consultation and, if necessary, reconsiders its position.

74 EN-1, para 4.7.3 Back

75 Department of Energy and Climate Change, Carbon capture readiness-A guidance note for Section 36 Electricity Act 1989 consent applications, November 2009 Back

76 Q 450 (RWE Npower); also DECC consultation responses 0042 (Mersea Island Society), 0063 (John McGough) and 0247 (Ian McFarlane) Back

77 Q 500 (Scottish and Southern Energy) Back

78 Q 501 (Scottish Power) Back

79 Q 504 (UK Business Council for Sustainable Energy) Back

80 Ev 491 (RWE Npower) Back

81 Ev 378 (Institute of Environmental Management and Assessment) Back

82 Q 812 (Department of Energy and Climate Change) Back

83 Ibid. Back

84 Q 637 (Environment Agency) Back

85 Q 658 (Infrastructure Planning Commission) Back