Memorandum submitted by Britain's Energy Coast Cumbria (NPS 69)

You have called for written evidence on whether DECC's National Policy Statements on energy infrastructure provide a coherent and practical framework within which the Infrastructure Planning Commission (IPC) can assess future planning applications.

I am responding as Chairman of and on behalf of Britain's Energy Coast West Cumbria Board. Our role is to help deliver the regeneration of West Cumbria, working closely with local, regional and national stakeholders. Our Board comprises the private and public sector, including our local authorities.

Our long term plan for the regeneration of West Cumbria is based on a low carbon economy, and in particular on the development of the nuclear sector, and diversification based on our nuclear strengths. As explained in more detail below, we have a very direct interest in energy policy and its delivery, and the related planning system.

The need for a new framework

We support the concept of National Policy Statements, and the establishment of IPC. It is widely accepted that there needs to be significant investment in the UK energy infrastructure over the next 15 years - Ernst & Young have estimated it at £235 billion. The energy sector needs to be de-carbonised - at almost 40% of the UK total, it is the biggest carbon emitter. New energy capacity needs to replace old to protect energy security, as nuclear and coal fired power stations close. And, with North Sea oil and gas stocks rapidly dwindling, we need new UK infrastructure to enhance UK's energy independence. The UK electricity network needs to be fit for the 21^st century.

UK energy policy is clear, and largely uncontroversial. We now need delivery. And with the long lead times for construction of major energy infrastructure - even under a fast track process the first new nuclear power stations will not be available until 2017 or 2018 - we believe the UK can ill afford some of the lengthy planning delays of the past (e.g. over 10 years to approve Sizewell B). So we need the IPC and NPS to pave the way for speedy IPC approval.

 

West Cumbria's interest

As noted, West Cumbria has a clear, direct interest in a swifter planning process. West Cumbria has been the centre of the UK nuclear industry for the past 60 years, and comprises around 60% of the current UK industry. It is host to Sellafield - the UK's biggest nuclear complex, to the UK's only national nuclear waste disposal facility, the Astute nuclear submarine programme, the National Nuclear Laboratory, and to the National Skills Academy for Nuclear. New nuclear power stations are - along with the Nuclear Decommissioning Authority's clean-up programme - likely to be the lifeblood for the local economy for several decades to come, both directly, indirectly, and in terms of the opportunity to grow out from a nuclear base.

Three Cumbrian nuclear power station sites have been selected by Government as potentially capable of deployment by 2025. Some of the biggest UK offshore wind farm developments are planned off our coastline. And, if economically viable and environmentally sensitive, we could also have up to three significant tidal energy schemes.

According to the NNB Consortium that plans to develop Sellafield, construction could start by 2015. We need the NPS and IPS to help deliver this, and the 21^st century grid connections that will be needed to support the outflow of power to the country (Cumbria would be a huge net electricity exporter).

Our experience of the Government's process

We have been closely involved in the process for the last year or so. In view of the circumstances at the time (the NDA had not then sold its development land adjacent to the current Sellafield site to a utility) we acted as agent for the NDA in drafting its nomination for the Sellafield development land, as part of DECC's Strategic Siting Assessment (SSA) process. So we have understood what has been required to satisfy DECC's exclusionary and discretionary criteria, and what issues DECC has considered to be best addressed at national and at local level. We believe the various criteria were properly established, since they were subject to full public consultation in draft before finalisation. They seem to us to a large degree to cover the ground expected of the IPC, and thus they appear to set a good precedent. Moreover, the answers that were provided in the SSA nomination against DECC's criteria seem to have provided a good basis for public comment during the Government's assessment of the nominations in 2009, and the current round of local and national consultations (those for Cumbria are taking place this week and next week).

Our views on the NPS documents

We are obviously not a statutory planning authority, and are responding in a business development context. But against the background of our own experience and involvement, we consider that the draft NPS provide clear guidance to:

(a) potential development proposal applicants;

(b) the IPC; and

(c) other interested parties, including local communities.

We believe that they set out clearly:

(a) Government policy on energy and climate change;

(b) The Government's views on the need for early new energy infrastructure;

(c) The information the IPC needs to take decisions, and the principles on which it should base its assessments; and

(d) The impacts that new energy infrastructure could have (e.g. on the environment, ecology, biodiversity, landscapes, and historic sites), and possible options for mitigating such impacts.

Moreover, we note that the NPS include Appraisals of Sustainability and Habitats Regulations assessment reports.

Again it is a personal view, but we thought the ground covered in the NPS on nuclear power in its section on Sellafield - using broadly the criteria the IPC is being recommended to adopt - seemed right in its scope and in terms of the assessment itself, recognising both where the site ticks the boxes, and where further detailed work will need to be done by a developer in an IPC application.

We will be responding publicly in more detail to DECC's consultation by the 22 February deadline, but I hope the above summary analysis is helpful to you and your Committee members. We have also responded to the NW Select Committee's inquiry into the future of the nuclear industry in the NW, and would be happy for your Clerk to see that too if it is useful to you.

January 2010