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Memorandum Submitted by the
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.
2.0 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
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
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
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.
3.0 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 e.g. 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.
4.0 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.
5.0 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.
6.0 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.
7.0 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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