Memorandum submitted by the Royal Institution
of Chartered Surveyors
ABOUT RICS
The Royal Institution of Chartered Surveyors
(RICS) is the leading organisation of its kind in the world for
professionals in property, construction, land and related environmental
issues. As an independent and chartered organisation, the RICS
regulates and maintains the professional standards of over 91,000
qualified members (FRICS, MRICS and AssocRICS) and over 50,000
trainee and student members. It regulates and promotes the work
of these property professionals throughout 146 countries and is
governed by a Royal Charter approved by Parliament which requires
it to act in the public interest.
RICS members are involved in a wide range of
roles within the energy and planning sectors, including managing
the land required for the development of new energy technologies
and their related infrastructure connections (eg cables and pipelines),
dealing with associated valuation and compensation issues, and
managing the construction of infrastructure projects.
EXECUTIVE SUMMARY
— RICS supports a strategic approach to
land use and planning and the contribution this can make to a
low carbon economy, but is concerned about the disjointed nature
of the Government's overall NPS consultation, particularly as
each of the national policy statements is published for consultation
in isolation from the other statements.
— In the interests of energy security for
the UK, RICS supports the Government's advocacy, through the National
Policy Statements, of a multi-modal energy infrastructure capacity
which can meet demand peaks and troughs, and calls for ongoing
monitoring of emerging low carbon energy technology which could
affect the proposed split between fossil fuels, nuclear and renewables.
— The NPS consultation document's assumption
that much renewable energy technology offers only intermittent
generation is not supported by RICS members' experience in other
European countries, where renewables can be relied upon to generate
a large proportion of electricity demand and in some cases may
respond more quickly to peak demand than conventional plant.
— RICS is cautious over how realistic the
Government's planned nuclear expansion is in the context of national
and international nuclear sector skills.
— RICS welcomes the funding for the carbon
capture and storage (CCS) demonstration projects, but is concerned
that the specified dates for the demonstration projects to be
operational and show their economic and technological viability
do not seem to allow an adequate timescale for operational testing.
BACKGROUND
RICS' response to the Energy and Climate Change
Committee's call for evidence is within the context of RICS' wider
views on the requirement for sustainability and climate change
adaptation and mitigation to be at the heart of spatial planning.
In 2009 RICS published its Global Climate Change Strategy and
UK Climate Change Action Plan, and these both set out key areas
in which the property profession can support the transition to
low carbon economies.
Sustainability at the heart of planning can
significantly contribute to mid and long term carbon reduction,
from the locations of new homes and workplaces to avoid unnecessary
commuting, optimising low carbon public transport systems, and
prioritising energy efficient buildings—all measures which
result in overall energy savings.
RICS views strategic planning as essential to
the vitality of UK Plc, as well as communities and businesses
across the UK who need predictability and consistency in planning
and infrastructure policy and delivery. RICS is concerned that
the right balance must be struck between the needs and views of
local communities and the wider requirements of the UK for its
continued growth. The 2008 Killian Pretty Review promoted the
use of Alternative Dispute Resolution, or mediation, throughout
the planning process, and RICS is actively promoting mediation
as an essential tool to ensure that the views and voices of all
are taken into account. RICS manages a Planning and Environmental
Mediation Service, referring cases to a panel of accredited mediators
from a number of planning and environment professional backgrounds.
TIMING
The likely timescales presented for the delivery
of proposals for nuclear and also other potentially controversial
projects may be unrealistic, given the possibility of legal challenge
which the NPS and IPC system of policy development and strategic
environmental assessment has created.
Although the IPC, supported by the framework
of the NPSs, is intended to streamline the planning process, there
could be a significant delay in the event of a legal challenge
on the basis of a contention that policy has effectively been
decided prior to a full and objective assessment of the options,
particularly with regard to the presumption of need.
JOINING UP
STRATEGIC GUIDANCE
FOR THE
IPC
Given the need for a joined-up approach to strategic
planning in the UK, RICS is concerned that the draft National
Policy Statements for Energy and Ports have been published for
consultation in isolation from the other National Policy Statements
on issues such as roads, rail and airports, which will be published
for consultation later in 2010-11.
Much of the energy infrastructure mentioned
in the NPS, as well as any new port developments, are reliant
on being located on good road/rail links. Until consultees have
reviewed the other National Policy Statements it is difficult
for them to provide strategic comments with only parts of the
full infrastructure policy available. RICS will examine the forthcoming
draft NPS on strategic infrastructure in particular to ascertain
whether there may be any aspects which are not joined up with
this suite of energy NPS.
Similar concerns over the current lack of clear
strategic guidance from Government have been expressed by a wide
range of people involved in the delivery of utilities infrastructure.
RICS is currently collating a research paper, in conjunction with
Arup, for The Northern Way. Entitled Utilities as a barrier to
regeneration, the report, which includes comments from those working
across the utilities sector in public and private sectors in the
North of England, identifies legislation which disincentives energy
infrastructure delivery, as well as poor communication from Government
regarding strategic planning guidance, as some of the key issues
facing the sector.
ENERGY SECURITY
RICS supports national energy security measures
and supports the Government's advocacy of a mixed energy infrastructure
which can handle existing and projected demand peaks and troughs.
In the context of the decline of indigenous gas and oil resources
in the UK, as well as the low carbon imperative, it is critical
that further diverse-source energy generation capacity is developed
in the short to mid term to avoid significant economic challenges
for the UK.
NUCLEAR INFRASTRUCTURE
CAPACITY
As part of its planned mix of new energy supplies,
the Government states that (EN-1, 3.1) "in principle, new
nuclear power should be free to contribute as much as possible
towards meeting the need for 25GW of new non-renewable capacity".
RICS is cautious over how realistic the projected
supplies and new nuclear developments are, given the national
and international shortages of skilled professionals in the nuclear
industry. This view is shared by the House of Commons Innovation,
Universities, Science and Skills Committee, where, in its Fourth
Report on Engineering: turning ideas into reality (2009), it stated:
"We note the Government's optimism that
delivering new nuclear power stations within 10 years is possible.
However, we are not convinced that the skills shortage in nuclear
engineering can be bridged quite as easily as some have suggested."
The UK is one of a number of countries supporting
a nuclear energy expansion as part of their drive to lower carbon
emissions, and competition for limited resourcing—and associated
costs—are likely to be intense.
CARBON CAPTURE
AND STORAGE
RICS recognises the vital role carbon capture
and storage technology can play in reducing overall carbon emissions
for the energy sector, and welcomes the funding being made available
by the Government for up to four coal CCS demonstration projects
which it states will be operational by 2020. However, RICS notes
that in 4.7.15 of EN-1, the text reads that "it is the Government's
expectation that new coal power stations will be fully CCS from
day one once CCS has been shown to be economically and technically
viable, and that this will be possible from 2020". The dates
for the demonstration projects to first be operational and then
show that they are economically and technically viable do not
seem to allow an adequate timescale for testing their viability.
LEVELS OF
ENERGY GENERATION
FROM RENEWABLE
ENERGY
RICS supports the expansion of renewable energy
generation capacity, based on its low carbon attributes and the
rapid development of technology and skills which is allowing it
to contribute substantially to national energy requirements.
In document EN-1, 3.3.25 the text reads that
"many renewable technologies only provide intermittent generation".
RICS international members' experience shows that it is not only
possible to allow renewables to meet a large proportion of regional/national
electricity demand, and even exceed demand by exporting to neighbouring
systems (eg Denmark and Germany), but to also adjust output and
thereby contribute to peak demand times.
Experience shows that if wind output is deliberately
constrained prior to expected demand peaks, or hydro capacity
held in reserve, and instead conventional plant run at a higher
level, renewable energy infrastructure can actually respond more
quickly than conventional plant in meeting rapid increases in
demand when they do occur.
Given the development of energy technology,
RICS supports the ongoing consideration of the evolving low carbon
energy infrastructure and its appropriateness to meet the needs
of higher shares of the UK's energy demands.
January 2010
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