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| Paragraph | Comment
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| 1.1.1 | The third sentence of the paragraph suggests that it is Government policy that all new coal fired generating stations should be required to capture and store the carbon emissions from a substantial proportion of their capacity. However, the policy is more accurately set out in paragraph 2.3.6. The statement in paragraph 1.1.1 should be amended to reflect this.
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| 2.1.1 | As the IPC must balance any adverse impact of the proposed development against its benefits it would be helpful if the NPS made it clear that the need in terms of the benefits of fossil fuel electricity generation in providing reliable and flexible electricity supplies and a secure and diverse energy mix should be given substantial weight.
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| 2.1.2 | It is not clear what is meant by the term "satisfies the impact considerations" in the final sentence of this paragraph. Presumably, the impact considerations are matters that should be taken into account by the IPC, rather than being matters that need to be satisfied. This sentence should be amended accordingly.
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| Water resources |
| 2.2.6 | This suggests that the volume and availability of water depend on a number of factors including (amongst others) the power consumption of the cooling system. The link between power consumption and the volume and availability of water is tenuous. Also the direct power consumption of the cooling system is a factor to be taken into account in selecting a cooling system design. However, we would like it to also recognise that the cooling system has a significant impact on the condenser performance characteristics and hence in the efficiency of the steam turbines and therefore the whole power station operation. This is not a simple case of estimating the works power consumed in pumping the cooling water, or by fans etc. in assessing the merits of alternative cooling systems.
It is not clear what relevance "the visual impact of the chosen system" has to the volume and availability of water. This should be deleted.
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| Grid Connection |
| 2.2.9 | We firmly support the text here. It is critical that flexibility is retained in the relationship with grid applications.
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| Government Criteria |
| 2.3.3 | "If an application does not demonstrate that CHP has been considered, as described in EN-1, the IPC should seek further information from the applicant. The IPC should not give development consent unless it is satisfied that the applicant has provided appropriate evidence that opportunities for CHP have been properly explored."
The EA have adopted a policy to check compliance with CHP and recently tried to request reports to be submitted to them, regularly, to demonstrate that we had investigated CHP opportunities. This was in addition to a planning condition.
We believe it is important to make a clear statement within the NPS what the role of EA's is for CHP without this we will face contradiction and confusion.
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| 2.3.15 | We acknowledge the importance of climate change adaptation and support the requirement to consider these potential effects of climate change in proposing new developments. However, we will carry out risk assessments that strike a balance between implementing additional measures now at additional cost and the probability that those measures will actually be required. Therefore a more efficient approach may be not to implement additional resilience measures now but to monitor changes and to ensure that there are no barriers to implementing additional measures at a later date, if the need should arise.
We would like the IPC to take account of this uncertainty and believe it should be prepared to accept the option of active monitoring, rather than implementing advance measures to deal with uncertain outcomes.
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| Good design |
| General | Further clarity on what is meant by achieving good design in terms of "attractiveness" would be helpful. We believe this to be very ambiguous and that further guidance is necessary so that it is not open to interpretation. A definition should take account of cost factors.
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| 2.3.18 | The meaning of the words "attractive, durable and adaptable" is unclear in this paragraph and paragraph 4.5.2 of EN1. These are not words that are generally used in assessing the design of infrastructure. Similar wording is also used in paragraph 4.5.1 of EN-1, although usable and contributing to sustainable development are also added. Alternative wording should be considered.
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| 2.3.19 | The paragraph does not explain how "good design" is to be achieved. We believe this part of the NPS would be more useful if it provided more detail on what "good design" means.
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| Landscape and Visual |
| 2.6.6 | The words "landscape and" should be inserted before "visual impacts" in the first sentence. There is inconsistency between this paragraph which refers simply to minimising impact on visual amenity as far as reasonably practicable and paragraph 2.6.10 which refers to sufficient measures having being taken to minimise effects on landscape and visual amenity. 2.6.10 should also refer to "as far as reasonably practicable".
Paragraph 2.6.6 is within the section headed IPC Decision Making. However, in section 2.5 a distinction is made between IPC decision making and mitigation. There should be consistency in those sections dealing with impacts. It should be made clear what the IPC is expected to take into consideration and what mitigation would be expected from Applicants.
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| 2.6.8 | The meaning of the last sentence is unclear and it should be clarified.
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| 2.6.9 | This paragraph lacks clarity and ought to be re drafted.
It instructs the IPC that they should:
"... expect the applicant to justify the use of a cooling system that involves visible steam plumes. It should be satisfied that application of modern hybrid cooling technology is not reasonably practicable before giving consent."
Whilst it is reasonable to expect developers to justify the selection of the cooling system, we do not feel that it is justified to direct the IPC to weight visual impact considerations over other factors in this manner.
The European Commission guidance (BREF) on Industrial Cooling Systems (Integrated Pollution Prevention and Control (IPPC) Reference Document on the application of Best Available Techniques to Industrial Cooling Systems), clearly indicates that a number of factors should be taken into account in designing cooling system and selection of the best option. This particularly includes consideration of efficiency of the process and hence greenhouse gas emissions per unit of electricity generated. Direct (once-through) cooling is generally the most efficient system where there is sufficient water available. Natural draught cooling towers are the next most efficient, followed by forced draught, hybrid towers and then air cooled condensers. Any of these technologies may be the most appropriate depending on local circumstances and we see no justification in directing the IPC to weight visible plume impacts in this manner.
It would be preferable to direct IPC to take account of the European Commission reference documents (BREFs) in determining projects that come under the Pollution Prevention and Control Directive, rather than give superficial `guidance' where there is no particular national interest reason to do so.
Finally we would like the following to be inserted at the end of the final sentence
"for the use of a cooling system that involves visible steam plumes"
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| 2.6.11 | "The visibility of a fossil fuel generating station should be given limited weight by the IPC if, having regard to the considerations set out in EN-1 and this section, it is satisfied that the location is acceptable for the project and it has been designed sensitively given the various siting, operational and other relevant constraints, to minimise harm to landscape and visual amenity".
Whilst this is helpful does the consideration of whether the site is an acceptable location itself include consideration of visual impact?
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| Decision making for mitigating factors
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| 2.7 | The IPC decision making and the mitigation should be separated.
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| 2.9 | Once again the IPC decision making and mitigation should be separated.
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| 2.9.5 | This indicates the primary mitigation for residue management is to use coal with low ash content. Whilst this may be true to some degree there are a large number of factors that must be taken into account in selecting fuel supplies.
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| 2.10 | There is no text dealing with the IPC decision making; it simply refers to mitigation.
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