Supplementary memorandum submitted by
Friends of the Earth
Friends of the Earth are writing to raise two
points regarding the treatment of climate change in the NPS which
have come up since our oral evidence—we hope this is useful
additional information for the committee.
The first is to correct what we believe to be
a misrepresentation in regard to the oral evidence given by the
IPC on 3 February. On a number of occasions the IPC answered committee
questions regarding how climate change would be tackled effectively
by stating that this would be dealt with because the CCC was a
statutory consultee for individual applications. Although the
CCC is a statutory consultee to the NPS consultation, we do not
believe that it is statutory consultee to individual applications.
We have checked the official list of statutory consultees, at
http://www.opsi.gov.uk/si/si2010/pdf/uksi_20100102_en.pdf
which does not include the CCC, and checks to legal
databases as of 11/2/2010 show no amendments to these regulations.
In practice, the CCC do not appear to be consulted either—the
IPC's list of projects http://infrastructure.independent.gov.uk/wp-content/uploads/2010/02/ProgrammeofProjects-08-Feb.pdf
lists three "scoping opinions" issued by the IPC, none
of these scoping opinions includes the CCC in its list of consultees.
We are concerned therefore that the IPC's answer
to the committee's questions on climate change is not accurate
and does not provide reassurance that this issue will be properly
tackled.
The second point is related. During evidence
the IPC repeatedly stated that climate change was capable of being
a significant material consideration in its decision making and
that the information necessary to allow it to consider the issue
would necessarily be provided because it would have to be submitted
by applicants in their environmental impact assessment reports.
However, it appears that the scoping reports
(from applicants) and, more importantly, the scoping opinions
(from the IPC) issued so far indicate that greenhouse gas emissions
are not being considered at all. For example, for the proposed
energy-from-waste plant at Rookery South, the scoping report does
not include any assessment of greenhouse gas emissions (which
it should do), and the scoping opinion from the IPC also does
not say that there should be an assessment of greenhouse gas emissions
either. In this context we are very concerned that if applicants
are not providing this information and the IPC are not asking
for it then the IPC will not have the information it needs to
be able to carry out a comprehensive assessment of the economic,
social, environmental costs and benefits of each application as
required in section 4.1 of the overarching energy NPS. Without
full information, particularly on an issue as important as climate
change, how can the IPC's decisions be robust?
February 2010
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