Memorandum submitted by the Energy Networks
Association
1.1 ENA supports the introduction of National
Policy Statements (NPS) to ensure there is a clear policy framework
for significant infrastructure. The need to set out at a national
level a statement of Government intent will provide clear and
unambiguous investment signals to network developers so they can
plan efficiently for the future. However the interrelationship
between them and the hierarchy of the existing suite of planning
policies, statements and guidance must be clear if they are to
be effective. NPS must play a significant role in defining the
approach of all consenting regimes both the local and regional
planning regimes as well as the Infrastructure Planning Commission
and the DECC Consents team.
1.2 Whilst the IPC regime will not apply to electricity
network projects under 132 KV (unless part of a Nationally Significant
Infrastructure Project) the NPS must play a significant part in
defining the approach taken by the DECC Consents team and the
local TCPA planning regime.
2. THE NEED
FOR ENERGY
NETWORK INFRASTRUCTURE
2.1 The need to develop a more streamlined
and responsive planning system has never been more important in
the field of energy. Energy developments require large scale infrastructure
that inevitably touches on local communities. The need to transport
new and diverse energy from remote areas and between communities
calls for a new approach to planning.
2.2 The low carbon agenda and the importance
of security of energy supply set out in the Government's Energy
White Paper can only be achieved by the construction of new electricity
and gas networks. A third of the UK's existing electricity generation
portfolio needs replacing over the next 10 to 15 years, and within
a decade 80% of the UK's gas will be imported. At the same time
development of major renewables including microgeneration will
be needed to achieve the 2050 carbon dioxide reduction targets.
2.3 There is a clear need for new energy
infrastructure. A central component of this will be network infrastructure.
ENA agrees with the National Policy Statement that 60 GW of new
capacity will be needed by 2025. With 30% of electricity coming
from renewable sources by 2020 there will be a need for a wide
portfolio of new energy sources. Many of these will have a significant
impact on the distribution network that will increasingly have
a more active role and eventually will have to act as district
system operators, a legion of "mini-National Grids"
plotted across the country.
2.4 ENA welcomes the approach set out in
the Statement on maintaining security of supply as we move to
a low carbon economy. The UK must make substantial investment
in energy network infrastructure to address the need for low carbon
secure energy supplies. Under the current planning arrangements
there is a considerable level of planning risk inherent in investing
in this infrastructure. ENA has been calling for policy certainty
and ENA members welcome the clarity and policy certainty that
the NPS introduces. The uncertainties of the planning regime have
been an important factor in deciding international investment
strategies and in delaying connection of new renewable energy
sources.
2.5 New electricity network infrastructure
will provide crucial national benefits. ENA welcomes the statement
in the NPS that a failure to put the necessary network infrastructure
in place will reduce the reliability of energy systems with potentially
damaging consequences for local, regional and national communities
and economies.
2.6 Network infrastructure projects often
have long lead times and are designed to cater for longer-term
needs based on careful forward planning by energy companies.
2.7 Network companies will have to respond
to expected increases in demand due to the development of new
housing estates and business premises. The number of households
in the UK is expected to rise by 31% by 2031. The electrification
of transport will also have a significant impact on the development
of electricity networks.
2.8 ENA welcomes the statement in the NPS
that the recent report by the Electricity Networks Strategy Group
on the electricity transmission needs to meet the 2020 renewable
targets represents the best available view of the optimum strategy
for reinforcing electricity network infrastructure to meet those
targets. ENA is playing a full part in its work on smart grids
as well as on the 2050 network vision. These all point to an increasingly
crucial role for the networks in facilitating the low carbon energy
sources of tomorrow.
3. FLEXIBILITY
3.1 Whilst the new regime very much improves
the ability for all stakeholders to consider the holistic implications
of any nationally significant infrastructure project (NSIP), it
also retains flexibility around submission of different elements
of a project, with the option for each in their own right being
submitted as a NSIP eg a proposed electricity generation project
and any connection or indeed deeper reinforcement of the electricity
network system.
3.2 The proposed approach strikes the right balance
enabling the Infrastructure Planning Commission and other stakeholders
to understand the likely full implications of a proposed development,
whilst enabling the developers of the respective elements of an
energy project, the opportunity to for one party to apply on behalf
of all involved; to jointly apply or to apply separately.
4. THE ELECTRICITY
NETWORKS NATIONAL
POLICY STATEMENT
4.1 Factors influencing site selection
by developers—ENA fully supports the principle of compliance
with Schedule 9 of Electricity Act 1989.
4.2 General Assessment Principles—ENA
has consistently supported a holistic planning process. At the
same time there is a need to separate out some network project
applications and ENA welcomes the recognition of this in the NPS.
4.3 Climate Change Adaptation—ENA
welcomes the emphasis in the NPS on the need to adapt our energy
infrastructure to the effects of climate change.
4.4 Landscape and Visual—Energy
network companies are fully committed to the principles of the
Holford Rules. Companies have made full use of Ofgem undergrounding
allowances, where appropriate, in areas of outstanding natural
beauty. In addition companies are very sensitive to the impact
of overhead line locations in respect of communities and scenic
landscapes. However ENA welcomes the recognition in the NPS of
the costs of undergrounding and the impact on the ability of network
companies to maintain and repair undergrounded assets.
4.5 Mitigation—ENA fully supports
the principles set out in the National Policy Statement on mitigation.
5. EMFS
5.1 ENA welcomes the clear statement of
Government policy on this issue set out in its recent response
to the Stakeholder Advisory Group on electric and magnetic fields
recommendations (SAGE).
5.2 As a responsible industry we take this issue
extremely seriously. Our approach is always to follow authoritative
independent advice. This statement now gives complete clarity
on Government policy and we welcome it. Government policy is that
as long as the exposure limits and other specified measures are
complied with, there are no other restrictions on building near
power lines. This clarity will be particularly helpful to local
planning authorities, as well as to developers and industry.
5.3 The Government has identified some sensible,
low-cost steps to take in the best interests of society as a whole.
We support these and have already volunteered to implement those
measures which fall to us.
5.4 Some campaigners had called for more
extreme actions. However, those actions would have quite serious
consequences for individuals and society that simply aren't justified
by the evidence. Government have now clearly said that those more
extreme actions are not part of national policy. That conclusion
is based on a careful analysis by the stakeholder group SAGE,
where all the different opinions were represented.
5.5 The Government decision is the end result
of a long process involving all the many stakeholders. ENA strongly
support this approach. This is a sensitive issue which needs to
be addressed by all the shades of opinion working together and
ENA is committed to working with other stakeholders to find the
right solution for society as a whole.
6. CONSULTATION
PROCESS
6.1 The Draft NPSs must be subject to the
deepest and widest consultation process. This must take as long
as is necessary. This will ensure that the NPSs agreed have the
widest agreement and legitimacy and go into the right level of
detail to aid the IPC in their decision making. It will prevent
unnecessary delay caused by challenges later through the Judicial
Review process.
7. SUMMARY
7.1 The challenges faced by the energy sector
in delivering a sustainable and secure energy future are considerable.
The planning process has acted as a serious barrier to the energy
developments designed to meet those challenges. The publication
of the NPSs on energy infrastructure including the one on electricity
networks represents a profound and significant step in addressing
this issue. ENA strongly supports them and believes that any dilution
of them will have a fundamental impact on the ability of the networks
in meeting the low carbon challenge.
January 2010
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