Memorandum submitted by the Campaign to
Protect Rural England
INTRODUCTION
1. We welcome the opportunity to submit
evidence to the Energy and Climate Change Committee on the proposals
for energy National Policy Statements (NPSs). As a leading environmental
charity, the Campaign to Protect Rural England (CPRE) has worked
to promote and protect the beauty, tranquillity and diversity
of rural England by encouraging the sustainable use of land and
other natural resources since our formation in 1926.
2. We see the planning system as an essential
tool for protecting and enhancing the countryside. We are one
of the leading voluntary organisations engaged in both shaping
and operating the land use planning system at all levels. Through
our network of local branches, which operate in every county,
and our regional groups, we engage in the planning process on
a daily basis.
3. A prominent part of our recent engagement
in planning has been in the debate on planning for nationally
significant infrastructure projects (NSIPs), both in relation
to national policy, and in responding to specific applications.
Although CPRE raised significant concerns about the reforms recommended
by the Planning White Paper (2007) and implemented by the
Planning Act 2008, we have long supported the principle of national
policy statements. NPSs will play a critical role in our national
planning framework and will shape key decisions on long-lived
infrastructure and patterns of development. In this context, getting
them right, both in terms of content and process, is essential.
EXECUTIVE SUMMARY
4. CPRE recognises the urgent need for low
carbon energy infrastructure and the challenge climate change
poses, but we believe that the energy NPSs need to be further
developed before they can be designated. While we support the
development of NPSs in principle we believe that it is essential
that we do not rush to meet an artificial political deadline in
developing these documents. To be effective NPSs will need public
legitimacy; allowing adequate scrutiny and time to amend the NPSs
in light of public concerns is vital.
5. In making recommendations to Government about
the draft NPSs we propose that the Committee consider the following
key points:
The NPSs should set out a spatial vision
for the future development of energy infrastructure and should
be effectively integrated with existing PPSs. If the documents
provide a stronger steer to decision-makers about the optimum
locations for new energy infrastructure, it is more likely that
future energy infrastructure will be developed in a coherent manner
which integrates environmental, social and economic concerns.
The documents do not need to be site specific, but more detailed
criteria should be included in the documents to ensure applications
come forward for projects in the most appropriate locations. Providing
more spatial criteria is likely to reduce uncertainty for developers
and the public, which should allow for more rapid development
of necessary infrastructure.
The NPSs should not assert an unlimited
need for new energy generation. The case has not been made for
unlimited, "one-dimensional" need for all forms of energy
infrastructure. Requiring the IPC to assess applications on this
basis undermines the ability of planning to integrate and balance
competing uses of land, and to ensure that the infrastructure
that is built matches emissions targets and community aspirations.
The Government should redraft EN-1 to establish broadly how much
of each technology they believe is needed in relation to security
of supply and emissions targets, and this should guide both the
IPC and applicants.
Getting the right balance between national
need and local adverse impacts will be one of the IPC's biggest
challenges. The guidance in the draft NPSs on how the IPC should
consider local impacts, whether raised in Local Impact Reports
by local authorities or by third parties, is totally insufficient.
At present, it is difficult to imagine how negative local impacts
could outweigh national need as currently expressed in the NPSs.
The aim of the NPSs is to establish medium-to-long
term national positions which will largely determine the shape
of the future energy system. It is intended that these positions
will not be reconsidered when individual applications are being
determined by the IPC. Before curtailing further debate on these
contentious, strategic issues it is essential that there is a
full national public consultation which includes provisions for
iterative debate. We are not calling for unnecessary delay and
do not envisage that this should take an undue amount of time.
We believe, however, that the Government is currently taking a
"tick box" approach to consultation, rather than encouraging
genuine input.
The objectives of the NPSs have been
drawn so narrowly in relation to the Appraisal of Sustainability
that all reasonable alternatives have been excluded. This applies
both at the strategic level and at the level of eventual IPC scrutiny
of individual projects. Empowering the IPC to consider reasonable
alternatives and requiring applicants to provide evidence on these
alternatives is not incompatible with a swift and effective decision-making
structure and not doing so is likely to be unlawful.
A COHERENT AND
PRACTICAL PLANNING
FRAMEWORK
NPSs as planning policy documents
6. As Planning Policy Statement (PPS) 1:
Delivering Sustainable Development highlights, sustainable
development is the core principle underpinning planning. When
planning is undertaken well, it should be a positive process,
which operates to promote the public interest by preparing plans
of, and control over, the development and use of land. In order
to fulfil this function in an integrated fashion, planning policies
at local, regional and national level must operate to deliver
the four aims of sustainable development set out in the Government's
Strategy for Sustainable Development (1999). These are:
the maintenance of high and stable levels
of economic growth and employment.
7. Moreover, clause 10 of the Planning
Act 2008 requires the Secretary of State, when designating
a NPS, to do so "with the objective of contributing to the
achievement of sustainable development".
8. We do not believe that environmental,
social and economic issues have been considered in a sufficiently
integrated way in the draft energy NPSs to reflect sustainable
development principles. It is clear that there is an urgent need
to reduce carbon emissions and to ensure an energy supply that
meets the country's needs. But this urgency is not so acute as
to justify a planning process which fails properly to consider
the long term potential impacts, especially environmental impacts,
of the most significant programme of energy-related development
in decades. The value of planning lies substantially in aligning,
integrating, and ultimately reconciling competing interests within
the framework of the long term public interest. The NPSs place
too much emphasis on a one-dimensional conception of need and
fail to provide adequate guidance on, and show sufficient regard
to, sustainability criteria. The draft documents also include
too little information on how infrastructure should be located
to minimise environmental impact and therefore should not be designated
in their current form.
9. CPRE has supported the creation of NPSs
in principle as a means to clarify national policy on major infrastructure
projects in the past, but we do not believe that NPSs should override
established planning policy as set out in Planning Policy Statements
(PPSs) and Planning Policy Guidance (PPGs). EN-1 has not been
drafted in the context of PPS1 which sets an overarching framework
of sustainable development for the planning system as a whole.
If EN-1 is intended to operate within the existing framework,
we believe explicit reference should be made to PPS1, and the
principles of sustainable development should be evident throughout
the document. If, on the other hand, the intention is to change
the overarching framework for energy infrastructure away from
sustainable development the public should be consulted on this
significant change to the planning system.
10. Although the NPSs were developed to
guide the decisions of the IPC, they will also become material
considerations for local authorities determining applications
for energy infrastructure through the town and country planning
system (paragraph 1.2.1). We believe in order to provide a planning
framework for energy, the aim of EN-1 should be to provide an
overview of the Government's energy policy, including in relation
to renewable energy infrastructure, such as wave and tidal power,
which the Government does not believe would currently deliver
schemes that meet the IPC's thresholds. At the moment EN-1 is
entitled Draft Overarching National Policy Statement for Energy
but paragraph 1.3.1 explains that the document only "sets
out the Government's policy for delivery of major energy infrastructure",
rather than a coherent statement of energy policy. Making EN-1
a more coherent overview would help direct local decision makers
when they consider applications that fall below the IPC's thresholds
and would contribute to a more coherent planning framework. The
technology specific NPSs (EN-2 to EN-6) should provide guidance
to the decision-makers in the IPC and for applicants in developing
their applications for schemes above the IPC's thresholds.
11. If the NPSs are to fit more coherently
into the existing planning framework, a more explicit link needs
to be established between work at the regional and local level
to plan for new energy infrastructure. We believe that there needs
to be a clear link, for example, with the "bottom-up"
processes which aim to identify capacity for, and constraints
to, the delivery of renewable energy infrastructure, such as those
promoted by the Renewable Energy Strategy (UK RES) which
states that the "Office for Renewable Energy Deployment will
provide up to £1.2 million of support to help all regions
put in place a robust evidence-based assessment of their capacity
for energy projects". It is essential that the IPC's decisions
do not override and contradict this important work.
12. Overall, we are concerned that the purpose
of NPSs is not sufficiently defined. At present, the NPSs seem
to be trying to achieve four aims: a minimal statement of Government
energy policy sufficient only for IPC-level development control;
partial justification for Government energy policy; guidance to
the IPC on how to determine applications; and guidance to applicants
on preparing applications. Planning reform at the local and regional
level has tried to make the distinction between policy and guidance
clearer, for example in Regional Spatial Strategies, and we feel
the NPSs represent a backward step in this regard.
Spatial planning for energy infrastructure
13. CPRE has long advocated the benefits
of a plan-led system. Compared with a simple development-control
approach, developing long term plans within which decision-makers
operate allows places to be shaped in a way which makes development
coherent, and enables consideration of longer term benefits and
drawbacks to different development options, with the result that
development can be more beneficial to the wider environment. Development
Plans are shaped by the views of communities who feed in through
consultation exercises, but are also based on national policy
and reasonable assessments of need and demand. Because draft EN-1
is clear that the NPS will prevail whenever conflict arises between
a NPS and a development plan (paragraph 4.1.2), and because the
NPSs do not promote an effective spatial planning approach, we
are concerned that the NPSs in their current form will undermine
a plan-led approach to energy development.
14. If the NPSs are to become effective strategic
spatial planning documents, we believe they need to give a stronger
steer to decision-makers about the optimum locations for new energy
infrastructure. They do not need to be site specific, but more
detailed criteria should be included in the documents to ensure
applications come forward for projects located in the most appropriate
locations. One way in which this might be achieved would be explicitly
to expand and draw on the process for considering opportunities
and constraints to renewables development at regional and local
levels, as proposed in the UK RES and outlined above. This process
aims to identify relevant spatial considerations for development
and to develop energy targets which incorporate these considerations
at a strategic level. Where schemes are proposed for locations
that do not meet such criteria, a more spatially-literate suite
of NPSs could require applicants to explain why this is the case.
15. In fact, there is already a precedent
in draft EN-1 which draws on more spatially explicit strategic
work done by the Electricity Networks Strategy Group (ENSG) (paragraph
3.8.5 onward). The government directs the IPC to have regard to
this report when deciding on electricity transmission projects,
but rather than seeking to build on the work of the ENSG, to assess
this work strategically and from the perspective of sustainable
development, and to create a set of criteria which could provide
effective spatial guidance to the IPC, the NPS directs the IPC
to disregard the ENSG report when considering projects not covered
by iteffectively directing the IPC to disregard spatial
considerations when these conflict with a proposal.
16. A similar presumption in favour of development
where spatial considerations might suggest that development is
inappropriate can be found in section 4.24.7. This directs the
IPC to consider consenting major development in nationally designated
areas where it will contribute to the national and regional economya
new and potentially damaging consideration; contribute to meeting
the essentially unlimited national need for energy infrastructure;
and cost less than the significantly limited alternatives that
the IPC is empowered to consider in section 4.4. This very substantially
weakens the long-established approach to assessing major development
proposals in nationally designated areas as set out in paragraph
22 of PPS7. The implication is that spatial planning is largely
a barrier to development, and that spatial policies should be
disregarded where they might restrict NSIPs. CPRE fears this could
have hugely damaging consequences for our most valued landscapes,
including National Parks and AONBs.
17. In developing the criteria proposed
there also needs to be more cross referencing between the NPSs.
In EN-2, Draft National Policy Statement for Fossil Fuel Electricity
Generating Infrastructure, for example, there should be a
clear statement that when considering locations for fossil fuel
generating stations applicants should be required to consider
the routes the associated transmission lines and potential Carbon
Capture and Storage-related pipelines will take. Paragraph 4.9.2
of draft EN-1 states that the "Planning Act aims to create
a holistic planning regime" but it goes on to acknowledge
that applications for generating stations may not always be submitted
at the same time as applications for their associated infrastructure.
Where an application does not cover the associated infrastructure,
or they are not submitted in tandem, the IPC should still be required
to take into consideration the likely impacts of it in determining
the application for the generating station. Allowing separate
bids for transmission lines and generation plants risks predetermining
the later project, and recent examples of proposals for transmission
linesespecially the Bramford to Twinstead overhead line,
which is referred to as the "Sizewell C Connector" by
the IPC[15]do
not suggest that the NPS will deliver an integrated planning regime.
18. If they are to be effective strategic
planning documents, CPRE also believes that the NPSs should give
the IPC a steer on the broad national energy mix the Government
is trying to achieve. This should be legitimately within the scope
of the NPSs as the Planning Act 2008 states that they may
"set out ... the amount, type or size of development ...
which is appropriate nationally or for a specified area"
(section 5(5)(a)).
19. Although there are projections of demand
for different infrastructure types in the NPSs there is no indication,
other than in draft EN-6, of how much of each technology is needed,
or where different types of infrastructure should be located.
Draft EN-1 actually adopts the opposite approach in stating that
the IPC should start its assessment of applications on the basis
that there is a significant need for all of the infrastructure
covered by the energy NPSs except for nuclear (paragraphs, 3.7.1,
3.8.10, 3.9.8 and 3.10.8). Once the IPC has approved a number
of schemes for a certain type of infrastructure it may be the
case that approving further applications for new infrastructure
of that type would not be appropriate for a range of technical
and environmental reasons which do not relate to carbon emissions.
20. Guidance on cumulative impacts contained
in the draft NPSs is also of concern to CPRE. We are particularly
concerned that it fails adequately to address landscape impacts.
This is because they focus narrowly on cumulative impacts of individual
projects rather than taking an overview of the potential impacts
of all of the new infrastructure the Government believes we need,
has the potential to result in "death by a thousand cuts".
A more strategic analysis of the whole programme could seek to
avoid this and we are not confident that the market will deliver
the strategic approach that is needed.
Balance between national need and local impacts
21. Planning for nationally significant
infrastructure projects will always be relatively controversial.
As the 2007 Planning White Paper recognised the benefits
of infrastructure are often widely dispersed and enjoyed by society
generally, while the impacts of the projects are felt mainly by
those in the immediate vicinity of the installation. Getting the
balance between national need and local adverse impacts right
will be one of the IPC's biggest challenges. CPRE is disturbed
at the relative lack of attention given to local impacts in the
draft NPSs.
22. Local Impact Reports (LIRs) should play an
important role in enabling the IPC to understand the local impacts
a local authority believes a proposed scheme will have. In light
of this role, it is disappointing that the guidance for local
authorities on developing them has still not been published. Paragraph
4.1.1 in draft EN-1 sets out the key principles that the IPC should
consider when determining applications and reference is made to
these reports. CPRE is very concerned, however, that in some cases
local authorities may not have sufficient resources to develop
a LIR, or where they do they may not assess the full environmental,
social and economic impacts on their area. In some cases it might
be possible that a local authority would welcome the economic
growth a proposed development would bring, so to encourage the
IPC to approve the scheme may choose not to cover the full extent
of the adverse impacts of a development or assess these fairly.
23. In such cases, evidence submitted by
a third party may be crucial in ensuring the IPC is aware of all
possible adverse affects so they can make an informed decision.
Equally, third parties may bring forward evidence of further benefits
of a scheme. Reference to the need for the IPC to consider carefully
evidence from third parties when examining and determining applications
for energy infrastructure should be referred to more explicitly
in the draft NPSs.
24. Paragraph 4.1.1 also requires the IPC
to consider local, regional and national environmental, social
and economic benefits and adverse impacts of the applications.
No guidance is given, however, on how such benefits and impacts
should be considered against each other. This is an essential
part of EN-1 that needs to be strengthened.
25. It is also important to note that the
requirements above are preceded by the following:
"Given the level of need for energy infrastructure
as set out in Part 3 of this NPS, if the development proposal
is in accordance with this NPS and any relevant technology-specific
NPS, then the IPC should operate on the basis that consent should
be given, except to the extent that any of the exceptions set
out in the Planning Act apply."
26. Draft EN-1 generally lacks guidance
on how the IPC should take forward their difficult role of balancing
local adverse impacts with national benefits in their decision-making.
Instead, the guidance repeatedly comes back to the conclusion
that as the document has demonstrated a significant and urgent
need for new major energy infrastructure limited weight should
be placed on most other considerations.
27. Section 4.4 of draft EN1 on alternatives
also needs to be redrafted to ensure that the IPC is required
to try to establish whether the proposed project represents the
best option. The energy infrastructure the IPC will be granting
permission for is likely to be in place for decades; while there
is a need for urgency in reducing our carbon emissions there is
also a need for the IPC to ensure that development is of a high
quality and in the most appropriate location. The third bullet
point in paragraph 4.4.3, for example, should be deleted. If a
site is proposed for development the IPC should judge it against
suitable alternatives to ensure it is the most appropriate. It
should not be for the IPC to speculate on whether an application
may be submitted, in the future, on other vacant sites and therefore
whether or not it should remain vacant. In determining an application,
the IPC should be expected to be able to judge a proposal against
alternative sites that are available at that time.
28. Moreover, CPRE does not support the
suggestion in paragraph 4.4.3 (final bullet point) in relation
to alternatives put forward by a third party. Our concerns about
this are set out in more detail below.
PUBLIC CONSULTATION
AND PARLIAMENTARY
SCRUTINY
National debate on energy policy
29. In the existing planning system, major
proposals are usually subject to public inquiries, which consider
local factors alongside questions of national need and energy
policy. This process subjects plans and policy to rigorous and
independent scrutiny, which plays a key role in addressing legitimate
concerns about new development, and also in demonstrating to the
more sceptical sections of the public that the major issues have
been aired and decisions to proceed are legitimate. Indeed, the
Government has regularly cited[16]
the example of Sizewell B, which spent only 30 of the 340 days
of hearings on local issues, as justification for the new planning
system for nationally significant infrastructure on the basis
that it is inefficient to repeatedly establish national policy.
CPRE believes that the fact that previous public engagement in
national infrastructure planning has focused on national issues
is a demonstration of the deep public concern and interest in
national energy policy. This merits equally deep commitment from
government to enable effective public engagement and scrutiny
in the development of national energy policy.
30. Unfortunately, the energy National Policy
Statements consultation and scrutiny process seems to be proceeding
at a pace dictated by the desire to deliver economic growth rather
than by a desire to engage the public and secure a degree of public
consent over the policy. This is evidenced by the very short notice
given for public meetings on the proposed nuclear sites which
resulted in only 34 people attended the consultation meeting in
Hartlepool and low turnout[17]
in other meetings, the fact that the public consultation period
has coincided with both the Christmas holidays and Copenhagen
climate negotiations, and the accelerated timetable set for parliamentary
scrutiny. Worse, although there is now a public consultation on
the aspects of government energy policy set out in draft EN-1,
the energy policy is incomplete and there is no established forum
in which to cross-examine the Government's proposals. This represents
a significant step backwards for public participation compared
with the existing system.
31. CPRE does not want to slow the process of
designating the NPSs down unnecessarily. Indeed, we believe taking
more time to fully consult the public on the draft documents could
reduce future delays due to opposition to specific applications
at a later stage. In a recent project funded by the Economic and
Social Research Council, researchers considered the factors underlying
public support and opposition to renewable energy technologies.
The final report, Beyond Nimbyism: a multidisciplinary investigation
of public engagement with renewable energy technologies,[18]
found that the perception that a developer was listening to local
concerns and could be trusted was an important part of the decision-making
process. The research concluded that rather than trying to dismiss
and undermine legitimate questioning and criticism of particular
renewable projects, industry and policy makers should instead
focus on protecting and nurturing social consent for what is a
key part of a low carbon future.
32. The wider implications of this research
are worth serious consideration. CPRE's interpretation is that
because the NPSs exclude many of the contentious issues for major
developments from later consideration at an IPC inquiry, very
substantial public engagement on the NPSs is required. The fact
that the NPSs will be subject to consultation rather than independent
scrutiny and that this consultation will take place at an abstract,
seemingly remote, national level well before any public engagement
is sought in relation to actual on-the-ground infrastructure poses
a serious challenge. Because most people engage with national
debates through the prism of local applications, there is a real
danger that the public will only become aware of key debates over
energy infrastructure after the decisions have already been taken.
This risks creating public discontent without a legitimate process
to deal with this discontent, and raises the spectre of judicial
review and even direct action protests against particular infrastructure
schemes, which would benefit nobody.
33. A starting point for achieving effective
public involvement in the development of NPSs might be to articulate,
in simple terms, the importance of the energy NPSs in relation
to the existing planning system, and using examples of schemes
that will be considered by the IPC to encourage people to engage
in this debate.
Narrow focus
34. Throughout the suite of energy NPSs,
a number of limits on what the IPC should and should not consider
when taking decisions are set out. This is a legitimate aim for
a national policy statement, but CPRE contends that the national
framework, in line with aspirations to ensure effective public
engagement in environmental decision-making, should seek to allow
swift but fair consideration of all relevant factors. Taken cumulatively,
we believe that the issues which are excluded or compromised by
the NPSs prevent fair consideration of many of the most important
and environmentally-relevant elements of nationally significant
infrastructure projects. Our initial analysis of issues excluded
from consideration in the NPSs has focused on the overarching
energy NPS.
(a) Need
35. The issue of need is discussed above,
but is relevant to the consultation and scrutiny process because
of the implications of "blanket" need on the extent
to which the public will feel that they can affect the outcomes
of development. Put simply, because the relative weight of national
need is not defined in relation to local impacts, and could reasonably
be interpreted to be very significant, the identification of need
explicitly as a benefit to be weighed against negative impacts
of proposals seems to imply that the benefit of delivering infrastructure
which helps to meet national need is as limitless as the claimed
need for new energy infrastructure itself. The benefit of delivering
infrastructure is explicitly set against more readily defined
(and presumably limited) negative impacts on SSSIs (paragraph
4.18.11), ancient woodland (paragraph 4.18.14), protection of
habitats (paragraph 4.18.17), dynamic coastlines and coastal processes
(paragraph 4.20.10), flood risk (paragraph 4.22.13), landscape
(paragraph 4.23.12), and open land (paragraph 4.25.17). Taken
together, this explicit invocation of national need seems to trump
most of the non-climate related environmental concerns, including
landscape protection, which might motivate local engagement in
the planning process for NSIPs.
(b) Carbon implications of development
36. At the same time, although much of the
justification for the creation of the IPC and NPS process relates
to the urgent need to reduce carbon emissions, it does not seem
that the IPC will be able to consider how the carbon impacts of
new development might affect carbon budgets. CPRE is not advocating
that the IPC take charge of delivery of emissions targets, but
as the IPC is the ultimate decision maker on the infrastructure
that is likely to deliver the bulk of these targets, it seems
paradoxical that they should have no regard to delivering emissions
targets, and no guidance on the types of energy mix that would
deliver our targets. We support the Environmental Audit Committee's
suggestion that a link be established between the Committee on
Climate Change's (CCC) carbon budgets and the IPC's guidance[19]
and we suggest that the most effective way of doing so is to be
much clearer on the types of energy mix required to meet our carbon
budgets within EN-1, and have this scrutinised by the CCC following
the development of the carbon budgets. At the application level,
emissions are a key environmental consideration which the IPC
should be empowered to take evidence on and assess impartially,
and which members of the public should have the right to scrutinise.
(c) Alternatives
37. Draft EN-1 explicitly states that it
does not establish a "general policy requirement to consider
alternatives or to establish whether the proposed project represents
the best option" (paragraph 4.4.1). Instead, it notes that
there are legal requirements for an assessment of alternatives
in some cases, and seeks to limit the IPC's consideration of these,
both with reference to the urgency of national need, but also
as regards the role of third parties in proposing alternatives.
38. While we agree that the IPC should not encourage
delay by assessing frivolous or unreasonable alternatives, we
believe that the general presumption should be, in keeping with
the spirit of the Habitats and EIA directives, for the IPC to
be satisfied that all reasonable alternatives have been considered.
Furthermore, we believe that where a reasonable alternative is
proposed by a third party, it is unrealistic to place the onus
for providing evidence for alternatives on this third party, especially
for NSIPs, which by definition are large, complicated projects
requiring substantial resources to provide adequate evidence for.
39. It is worth noting that the process
for considering alternatives contrasts with the Government's approach
on proposals for generating energy from the Severn Estuary, a
potential energy NSIP. Concerns about the Government's SEA for
the project have led to alternatives to a barrage being proposed
by third parties. Where these have the possibility of providing
power at a lower cost to the environment, the Government has undertaken
to consider these third party alternatives. Similarly, in order
to satisfy public demand for investigation of more inchoate alternatives,
the Severn Embryonic Technologies Scheme is providing funding
for the exploration of these. Although the Severn Estuary could
provide around 4% of UK electricity, and might therefore host
a particularly large project, it is not clear that this makes
it a special case. A proposal for a twin reactor nuclear power
station or a large coal-fired power station would produce similar
amounts of power, and we believe that the generally more positive
approach to third-party alternatives should prevail in the energy
NPSs.
(d) Assessment of the relative merits of different
technologies
40. The summary of national need (paragraph
3.1) states that the "IPC does not need to consider the relative
advantages of one technology over another". CPRE is concerned
that this guidance, which is not expanded upon further in the
document, is overly restrictive. While we recognise that Government
energy policy is to allow the market to determine the overall
energy mix, the NPS should be redrafted to explicitly clarify
that the IPC should consider the relative advantages of technologies
within a proposed project.
APPRAISAL OF
SUSTAINABILITY (AOS)
41. CPRE's analysis of the NPSs has not
focused on the AoS in detail. However, we have reviewed the evidence
submitted by the RSPB and WWF and support the analysis that reasonable
alternatives for the NPSs were rejected inappropriately; that
the opportunity to engage the public in national debate on existing
policy on energy has been missed; and that the SEA focuses on
the impact of the NPSs on the consenting process rather than the
impact of the NPSs on the environment.
January 2010
15 IPC Programme of anticipated projects, 5 January.
Available from http://infrastructure.independent.gov.uk/wp-content/uploads/2010/01/ProgrammeofProjects-5-Jan1.pdf Back
16
See, for example, Lord Hunt of Kings Heath's statement on the
National Policy Statements, HL Deb, 9 November 2009, c646. Back
17
See, for example, the response to Mark Williams' question on the
attendance figures for the nuclear consultation events, HC Deb,
13 January 2010, c1049W. Back
18
Further information about the report can be found at http://geography.exeter.ac.uk/beyond_nimbyism/ Back
19
Paragraph 71, Environmental Audit Committee, Third Report:
Carbon budgets, January 2010. Back
|