Memorandum submitted by the Campaign for
National Parks
CNP considers that there are some fundamental
issues to be addressed before the NPSs can be designated and considered
sound. This submission focuses on EN-1 (overarching energy),
EN-5 (electricity networks infrastructure) and EN-6 (nuclear).
1. NATIONAL POLICY
STATEMENT FOR
OVERARCHING ENERGY
(EN-1)
Assessing nationally significant infrastructure
projects in National Parks
1.1 The guidance in the draft NPS for assessing
projects in National Parks must be altered so that it reflects
properly the rigorous examination required for such projects and
the test that must be satisfied before such projects can be considered
to be acceptable (exceptional circumstances and public interest
must be demonstrated).
1.2 We are concerned that the guidance within
para 4.24.7 is at odds with current Government policy for
assessing major development proposals within National Parks, as
set out in para 22 of Planning Policy Statement 7. The draft
NPS attempts to define exceptional circumstances as those where
development can be demonstrated to be in the public interest.
This is in contrast to existing Government policy which is that
both exceptional circumstances and public interest must be demonstrated
(the two are not always necessarily equivalent) in order for a
major development proposal to be considered acceptable. Footnote
68 also changes existing Government policy as it attempts
to redefine national considerations as including the contribution
of the infrastructure to the regional economy. Nor is there any
reference to the requirement for such proposals to be subject
to the most rigorous examination. When taken together, the changes
constitute a significant perversion of a key Government policy,
the principles of which have remained unsullied throughout several
governments. We therefore suggest the following rewording:
Nationally significant infrastructure projects
should not take place in these nationally designated areas, except
in exceptional circumstances. Because of the serious impact that
nationally significant infrastructure projects may have on these
areas of natural beauty, and taking account of the recreational
opportunities that they provide, applications for all such developments
should be subject to the most rigorous examination. Nationally
significant infrastructure projects should be demonstrated to
be in the public interest before being allowed to proceed.
1.3 The reference to the regional economy
in footnote 68 should be deleted. National Parks are designated
for the nation's benefit and because of their national significance—the
suggestion that a contribution to a regional economy is a national
consideration is not only prima facie wrong; it must also be regarded
as an attempt to undermine the national significance of nationally
designated areas.
1.4 The wording of this test also needs
to be corrected in the gas and oil pipelines NPS (EN-4).
The weight attached to development plans
1.5 CNP considers that the suite of draft
NPSs do not, either individually or collectively, give sufficient
weight to the relevance of the development plan (currently comprised
of the Regional Spatial Strategy and the Local Development Framework)
to the Infrastructure Planning Commission.
Need and the absence of a locational strategy
1.6 The draft NPS is based on a premise
that there is a considerable need for new investment over the
coming years and that any new provision is needed. As part of
this approach, the market is left to decide where proposals for
new electricity generating infrastructure will come forward—for
example, the proposed list of sites for nuclear power stations
within EN-6 have been identified by promoters on the basis
of market considerations, rather than through a rigorous site
selection process based on sustainability criteria.
1.7 While we accept that the Government
should not prescribe what development will be provided where,
the absence of any priorities or steer for where infrastructure
might be most desirable, acceptable or necessary is unhelpful.
In our view, this is unlikely to result in the more strategic
approach the Government aspires to—instead, objectors will
continue to resist developments on a case by case basis. The need
case will not be accepted by the public, as the draft NPS appears
to be saying that whatever promoters say is necessary is necessary,
regardless of the impacts that this might generate.
Cumulative impact of development
1.8 EN-6 highlights the importance
of considering the cumulative effects of nuclear development but
EN-1 does not provide any guidance on how the cumulative
effects of all energy infrastructure, including nuclear and transmission
infrastructure, will be identified and assessed.
1.9 Significant cumulative impacts would
arise if a number of different installations came forward in the
same general area—for example, Cumbria is endeavouring to
establish itself as Britain's Energy Coast with proposals and
possibilities of nuclear, wind (onshore and offshore), tidal developments
and their associated infrastructure. At which point will the potential
cumulative impacts of these separate developments be considered,
including on the special qualities and statutory purposes of the
Lake District National Park? CNP suggests that the Committee's
questioning of promoters and the Minister ought to include some
potential scenarios such as this in order to probe them on how
cumulative impacts will be assessed in practice.
2. NATIONAL POLICY
STATEMENT FOR
ELECTRICITY NETWORKS
INFRASTRUCTURE (EN-5)
A strategic approach to transmission is needed
2.1 A strategic vision is needed for the
UK's transmission network but unlike the scenarios presented by
the Electricity Networks Steering Group this must have sustainability
considerations at its heart. At present, National Grid is required
to provide connection agreements for each new site of generating
capacity before any assessment is made of the appropriateness
of either the location of the generating capacity or the grid
connection that it would require. A strategic vision of the electricity
transmission network (onshore and offshore) is called for and
this must factor in environmental considerations—such as
the location of National Parks and other nationally designated
areas—if it is to win public acceptance.
Mitigating measures
2.2 The draft NPS does not take a positive
enough view of mitigating measures such as undergrounding. This
should be de rigueur in nationally designated areas such
as National Parks.
2.3 Research by Ofgem demonstrates that
the public is willing to contribute financially towards the undergrounding
of lines in sensitive landscapes. Much progress has been made
on undergrounding visually intrusive distribution lines through
a special funding allowance to Distribution Network Operators
set up by the price control review process. Where a new transmission
line is proven necessary in a National Park following the rigorous
process outlined in paras 1.2 and 1.3 of this submission,
its entire length must be undergrounded within that landscape
(subject to consideration of possible local impacts on interests
such as archaeology) and funds must be available for this. The
process for offering connection agreements to generators is not
transparent and should not be divorced from the consenting process
for nationally significant infrastructure projects—the two
must be linked.
Joined-up approach to applications for generation
and associated development
2.4 The Infrastructure Planning Commission
should be given the strongest possible encouragement to consider
applications for power stations and associated development such
as grid connections at the same time. This is especially pertinent
to the proposed greenfield sites at Kirksanton and Braystones
where is currently no grid infrastructure. This would enable the
Government's vision of a single integrated consent regime to be
achieved in practice and the overall acceptability of a project
to be considered before development consent is issued for individual
elements.
3. NATIONAL POLICY
STATEMENT FOR
NUCLEAR (EN-6)
Legality in respect of the Habitats Directive
3.1 We are concerned at the legality of
the draft NPS in respect of the Habitats Directive and its test
of Imperative Reasons of Overriding Public Interest (IROPI). The
draft NPS relates the grounds for IROPI to the protection of human
health and public safety and to beneficial consequences of primary
importance for the environment (ie tackling climate change). Given
this, the Government is not seeking an opinion from the European
Commission, despite the presence of priority habitat types within
sites which may be affected. We think that this argument is flawed
and agree with the many other submissions to the inquiry that
the legality of this element of the draft NPS should be tested.
Site specific considerations
3.2 We have serious concerns about the suitability
of the proposals for Kirksanton and Braystones because of their
impact on the setting, tranquillity and special qualities of the
Lake District National Park. The ecological impacts at Kirksanton
would be extreme, and both sites would have impacts on internationally
and nationally designated sites of ecological importance. Coupled
with the adverse impact on the Lake District National Park and
other factors such as the impacts on the marine environment, we
consider that there is a compelling case to remove both sites
from the NPS.
3.3 We are concerned about the cumulative
impact of up to three nuclear power stations in this remote, rural
part of Cumbria—scrutiny is needed of how will this assessed
by the Infrastructure Planning Commission and the process by which
the public will be able to make its views known on cumulative
impacts.
3.4 Three nuclear power stations, two of
which would be greenfield sites, would expand significantly the
character of the area dominated by nuclear power station infrastructure.
Scrutiny is needed of whether this would be publicly acceptable
before these sites can be included within the final NPS, especially
given the impact on the character of the nationally designated
Lake District National Park.
3.5 Given the small size of the Braystones
site, we question whether it would be feasible for the intermediate
level waste that it would generate to be stored there and whether
there may be plans in the longer term to coalesce the site with
Sellafield. While this may appear to offer operational efficiencies,
this would further extend the area of countryside dominated by
nuclear power station infrastructure and increase the impact on
the Lake District National Park.
3.6 We do not accept the validity of the
site selection process through which the ten listed sites have
emerged. They have come forward simply because developers have
nominated them and in our view there has not been a rigorous assessment
of whether there are any viable alternatives.
3.7 As mention in para 2.3 of this
submission, the proposals for new nuclear power stations cannot
be considered in isolation from the implications of strengthened
or new electricity transmission infrastructure, especially as
the latter would intensify as the number of power stations consented
in West Cumbria increased. The least impactful options ought to
be given the highest priority (undergrounding and using offshore
connections), and grid capacity needs to be considered in the
light of other non-nuclear major energy generation schemes such
as offshore wind and potential tidal barrages. These points are
also relevant in respect of the new nuclear power station at Wylfa
in North Wales, as this would have implications for the electricity
transmission line that runs through the Snowdonia National Park.
January 2010
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