Memorandum submitted by the Department of Energy and Climate Change (NPS 1)
ENERGY NATIONAL POLICY STATEMENTS: CONSULTATION PROCESS
This note has been produced in response to issues raised by the Energy and Climate Change Select Committee, at the Energy National Policy Statements Briefing held on 25th November 2009, about the aims and objectives of the consultation process. The Committee also questioned why the national consultation events were not being held in every region, notably the north west of England. In the light of this comment we are now proposing to run an additional event in Manchester on 26th January 2010.
The Committee stressed that it was important to engage people in active consultation and questioned whether the Regional Development Agencies (RDAs) were involved in the process. A note was requested on the public meetings held to date, their purpose, scope and format, and the location and timing of events. (Information regarding the dates, locations and venues of each event was forwarded to the Committee on 26th November 2009 and for convenience is attached to this note).
We welcome the Select Committee's interest in how we engage with the public and would welcome further comments and suggestions for ways in which to improve the consultation process if necessary.
REQUIREMENT TO CONSULT
The Planning Act 2008 requires the Government to consult the public and stakeholders on the National Policy Statements (NPSs) before they can be designated. The particular challenges in devising the consultation programme have been the very technical nature of the information and the large quantity of information involved, given the range of energy technologies under consideration and site specific analysis required for the Nuclear NPS.
Officials of the Department for Communities and Local Government (DCLG) were engaged in the design of the consultation process for the energy NPSs. The process reflects their advice about engaging directly with communities. Planning Aid also provided advice on the accessibility of the consultation document and the format of the national events. Senior DCLG and DECC officials are actively involved in the consultation events, either attending the exhibitions or as panel members at the public meetings.
NATURE OF THE CONSULTATION
The Government is consulting on six draft energy National Policy Statements including the associated Appraisal of Sustainability and Habitats Regulations Assessment for each document:
· Overarching National Policy Statement for Energy (EN-1)
· Fossil fuel electricity generation (EN-2)
· Renewable energy generation (EN-3)
· Gas supply infrastructure and gas and oil pipelines (EN-4)
· Electricity networks (EN-5)
· Nuclear power generation (EN-6)
A 15-week public consultation began on 9th November 2009 and will close on 22nd February 2010. This extends the usual statutory consultation period of 12 weeks.
There are four main elements to the consultation process, as follows:
· National events covering all energy NPSs
· Local events close to the 10 nuclear sites judged potentially suitable in the Nuclear NPS
· Stakeholder meetings
· Responses to the consultation for instance via the Government website
National Policy Statement Events
These events are stakeholder facing, although open to the public to attend if they wish, and cover all 6 energy National Policy Statements including nuclear. Each event includes an exhibition, presentations by Ministers and/or Government officials, followed by a Question and Answer discussion. The events are at Peterborough, York, London, Cardiff, Exeter and Manchester.
Nuclear National Policy Statement Local Events
A series of local events are being held at locations near to the 10 potentially suitable sites for new nuclear power stations identified in the NPS, comprising 3-day exhibitions (Thursday- Saturday) and a public meeting usually on a Saturday.
As well as the local and national events, we will be inviting stakeholders to a technology specific meeting on the draft Energy National Policy Statements (EN-1 to EN-5) on 25th January 2010, with a separate meeting on the Nuclear NPS (EN-6) on 2nd February. These will be working level meetings with environmental NGOs, industry and other stakeholders to help them engage and formulate their responses to the consultation on the National Policy Statements. The original proposal was for a series of meetings to cover each NPS but these have now been amalgamated upon the request of NGOs who preferred a single event to cover the majority of NPSs in one sitting. We will also be holding an additional event for stakeholders interested in the Appraisals of Sustainability and Habitats Regulation Assessments on 3rd February, as well as a meeting with Statutory Consultees (such as the Environment Agency, Natural England, and the Countryside Council for Wales) covering all the above issues, to be held on 1st February.
Responses to the Energy National Policy Statement consultation can be submitted on line via the Government website www.energynpsconsultation.decc.gov.uk The online consultation has been designed to make it easy to submit responses to the questions set out in the consultation document which accompanies the draft National Energy Policy Statements.
PURPOSE, SCOPE AND FORMAT OF EVENTS
National Policy Statement Events
The events aim to raise awareness of the consultation, provide information on the ways in which responses can be made, allow respondents to understand where the consultation fits into the overall process, and answer any questions they may have regarding the consultation itself.
The consultation events are open to stakeholders and to the public, and delegates are required to register their attendance via the consultation website. The target audience includes the following:
· Members of the public with an interest in energy, planning and infrastructure
· Elected Members and officials of Local Authorities and County Councils
· Non-government Organisations (NGOs)
· Regional Assemblies
· Regional Development Agencies (RDAs)
· Institute of Civil Engineers (ICE) members
· Royal Town Planning Institute (RTPI) members
· Private sector professionals with an interest in energy, planning and infrastructure
· Planning consultants
· Energy companies
The events typically run from 10.30 a.m. to 2.00 p.m. on week days, and focus on two presentations which provide an overview of the forthcoming planning reforms and the NPSs, followed by an open Q&A and an additional chance for delegates to ask questions more informally over lunch. Exhibition boards provide outline information on the 6 energy NPSs and an opportunity for delegates to raise any issues and questions before the presentations commence.
Consultation material provided at the events includes hard copies and CDs of the consultation documents, Planning Aid leaflets relating to the NPSs, laptops connected to the consultation website where people can submit a response if they wish, and hard copy response forms. The IPC also has a presence at the meeting to give out information about the planning application stage, and are available to discuss their role and processes informally, though to preserve their independence they are not part of the formal proceedings.
The locations of the events were selected on the basis of achieving the maximum geographic coverage within the resources available, ensuing that overlap with the Nuclear NPS Local Events was kept to a minimum. For instance, taking care not to overload potential consultees in north west England given the concentration of Nuclear NPS Local Events in Cumbria. However, the Select Committee's concerns regarding the lack of a national consultation event in the North West is noted. As a result we will be holding an additional event in Manchester, which was recommended as the optimum location following consultation with Planning Aid, CLG and other relevant departments.
Various actions have been taken to publicise and raise awareness of the national consultation events through the following media, contacts and organisations:
There was wide media coverage the weekend before the launch of the Energy NPSs, with press articles, television and radio interviews with the Secretary of State and other Ministers and extensive national and regional media coverage in print, broadcast and online throughout the 9th and 10th November. This in turn resulted in a large number of hits on the consultation website and questions and comments sent via e-mail direct to DECC.
Energy NPS Consultation Website
15,200 unique visitors have viewed the website as of 5th January 2010. The website, which provides details on all Energy NPS consultation events, has been widely publicised and included on a number of related websites (DECC, DirectGov etc).
Government Office Network
All GO regional officers were contacted by email with details and updates about the events. They then forwarded details on to Local Authorities, community groups and local planners. GOs in the regions 'hosting' events were contacted via telephone to ensure that details had been passed on and that all possible leads had been followed. We have also worked with GO press offices to encourage local and regional press coverage of the events.
Regional Development Agencies
The RDA network was contacted in a similar way via the lead DECC contact, Vicky O'Kelly of the North West RDA, who widely distributed the details of the consultation events to the RDA regional offices throughout the UK, and encouraged business contacts to attend. As the remit of RDAs does not include planning (that is a matter for GOs) they have not been directly involved in the organisation of events.
Planning Aid are involved in promoting the events both through their volunteer groups across the country and their contacts at the RTPI among others. Planning Aid set up a dedicated website on the NPSs which had generated almost 60,000 hits as of 26/11/09. Representatives of Planning Aid are facilitators at the national events and provide exhibition support at the nuclear local events. As noted above, they have also helped with ensuring the consultation document is accessible, and with the format of the national events.
National Organisation of Residents Associations
Planning Aid recommended and provided details of the National Organisation of Residents Associations (NORA) whose members they thought would be interested in the NPS events. NORA were then contacted via email regarding the consultation events.
The press offices of the GOs with consultation events in their regions were contacted regarding publicising the events. Press notices were then sent out to local newspaper publications and media, and to regional publications using contacts from the East of England, Yorkshire and Humber, Northeast and Northwest GOs. Emails were sent to internal and stakeholder communication colleagues in Peterborough Unitary Authority and Cambridgeshire County Council, Natural England, Environment Agency, GO policy colleagues (who in turn forwarded to policy colleagues in local authorities, planning and environmental groups, NGOS, Sustainability East and charities and local forums).The regional press office recommended specific groups to invite to the events who were subsequently informed.
Local Government Association
CLG provided details to the LGA for circulation to their members and network.
Publication of event venues and times
The location, venue and schedule of the events were publicised both on the website and via other contacts so that those who did not manage to register for an event were still able to attend if they wished.
Institute of Civil Engineers
The Institute of Civil Engineers was contacted and publicised the events to its members.
Consultation email address
We received inquiries from people interested in the events via the email address published in the consultation document (and online) who we were able to inform about the events and advise how they could register to attend.
DECC/ CLG stakeholder database
Information has recently been distributed regarding the events to DECC and CLG stakeholders.
All Statutory Undertakers were emailed in accordance with the Planning Act 2008 with details of the consultation which contained information on the national events. Letters have been sent where emails were not successful.
Chief Planning Officers letter
The Chief Planning Officers letter, which went to all local authorities, highlighted the NPS consultation and linked to DirectGov for further information, and there was also an email that went out to thousands of LA professionals via Info4local about the NPS consultations generally.
South West Sustainable Energy Agency
Following the Peterborough and York events, we contacted the sustainable energy agency (funded by SW RDA) regarding the Exeter event. They have been helpful in identifying local issues and promoting the consultation events.
Nuclear NPS Local Events
The purposes of the local events are to raise awareness of the consultation, encourage people to take part and allow them to discuss issues with senior policy officials. The aim is to enable people who visit the events to:
· Learn more about the draft Nuclear National Policy Statement and how a site in their area has been assessed as a potential location for a nuclear power station;
· Find out how the public can have their say in the consultation process; and
· Comment on the draft NPS and test the evidence presented. We therefore consider responses made during these events as consultation responses where appropriate.
Venues for the events are selected as close to the site and in locations as populated as possible to engage a wide audience. Suggested venues have been recommended by Local Authorities and energy companies (who have undertaken similar events in the past) and we have endeavoured to use as many of these recommendations as possible. The priority is finding a large enough room that is accessible to a large majority of the public.
The events usually run for 3 consecutive days. The first two days (typically Thursday and Friday) comprise an exhibition which is open from 8.00 a.m. to 8.00 p.m. and 8.00 a.m. to 7.00 p.m. respectively. The exhibition continues on the final day from 9.00 a.m. to 4.00 p.m. and includes a public meeting from 10.00 a.m. to 12.00 midday.
The exhibition features a series of interactive touchscreens and graphic panels giving information on the draft Nuclear National Policy Statement, the consultation process and the assessment of the site . The panels provide background information on nuclear power stations to help people understand the practical implications of constructing and operating a nuclear power station. That information also appears in the consultation document.
They aim to introduce the draft Nuclear National Policy Statement and the Government's assessment of sites in an engaging, interactive and understandable way. Respondents will still need to read the consultation documents, however the exhibitions are intended to help summarise the detailed information contained in the draft National Policy Statement and help people engage with them.
Consultation materials provided at the event include hard copies of the Nuclear NPS, the consultation documents, the Appraisal of Sustainability and Habitats Regulations Assessments for the site, and the Overarching Energy NPS. Planning Aid leaflets and flyers are provided, together with hard copy versions of the consultation questions. Laptops are provided with access to the consultation website, where visitors are assisted in navigating the consultation pages and in answering queries.
The public meeting is held over 2 hours and includes two slide show presentations given by senior DECC officials which provide an overview of the Nuclear NPS and planning reform, and details of the site assessment carried out at the nominated site. Each presentation is followed by a public discussion and Q&A session with an opportunity for the audience to air their views. Attendance at the public meetings is normally captured by registration via the consultation website, but additional visitors can attend on the day if space permits. The panel discussions aim to:
· Raise awareness amongst the local community of the consultation questions;
· Explain why the Government considers the listed sites as potentially suitable for new nuclear;
· Actively listen to both concerns and feedback on the substance of the NPS documents and the consultation process;
· Help people to understand and respond to the consultation questions; and
· Capture the views expressed at the events and record them as individual responses to the consultation.
Whilst the exhibitions largely raise awareness and inform consultation responses, it is important that we listen to local views and we are recording/keeping a record of the comments made. The presentations and public discussions are recorded at each event and a formal Government response to the issues raised by local delegates will be provided.
The primary target audience is the local community. Energy companies, local authorities and regulators are invited to attend the public discussions in an audience capacity, with specific support at the events provided by Planning Aid and the Environment Agency. A range of people are invited to attend the local events as follows:
· General local community (including hard to reach groups)
· Elected representatives (Councillors, MPs)
· Local protest groups / environmental groups
· Local businesses
· Local schools (primarily / secondary)
· Local Community Groups
· Site Stakeholder Groups (at existing sites)
· Local Authorities
· Site nominators/energy companies
· Parish Councils
· Statutory consultees
Publicity for the local events involves the distribution of leaflets door to door, and posting notices in local community buildings including libraries and doctors' surgeries. Advertisements are placed over 2 consecutive weeks* in local and regional newspapers with a combined circulation of at least 150,000. A rolling communications campaign is underway targeting local stakeholders including Parish Councils, campaign groups and schools. We have been working with the local authorities to develop our plans and they are helping to publicise the events to their elected members and staff. We are also generating PR coverage in the local print and broadcast media.
* With the exception of the Hartlepool event which took place in the first week following the launch of the NPS.
In response to comments raised about the short notice of these events following publication of the NPS, we will be holding an additional public meeting from 6-8 p.m. at Hinkley Point on 27th January 2010, and attending a public meeting arranged by Hartlepool Borough Council on 26th January, involving a panel discussion with DECC (OND), EDF, Friends of the Earth, the Sustainable Development Commission and neighbouring local authorities.
More than 880 people have attended the first 5 consultation events (both public meetings and exhibitions). There are currently more than 450 people registered to attend the remaining 5 public meetings, some of which have not yet been publicised. We would expect at least as many people again to attend the exhibitions, and for registrations to increase as the meetings are publicised.
National Policy Statement Events
Three of the five national consultation events have now taken place, at Peterborough and York (24th and 25th November respectively), with the London event held on 2nd December. A total of 22 people attended the event in Peterborough, with 30 at York. The London event attracted over 80 delegates and was addressed by Parliamentary Under Secretary of State, David Kidney MP. Delegates came from a wide range of organisations including members of the public.
Feedback was generally positive, with the London event particularly well received. The choice of venue of the Peterborough event was however questioned by one delegate, particularly its accessibility by public transport.
We have since reviewed and amended the format of the events, and ensured the venues of the later events are located within walking distance of railway stations and public transport routes. The use of better targeting through extensive mailing lists and marketing has resulted in a substantial increase in the number of delegates for the London, Cardiff and Exeter events. We will be applying the same marketing techniques for the additional event.
The principal issues raised at the events related to planning reform, renewable energy and nuclear. Particular questions focussed on:
· Planning reform (both the principles behind the change and the capacity of the IPC to assess complex technical issues);
· Renewable energy (particularly wind power);
· Technologies not covered by the NPSs (including wave and tidal, and smaller electricity lines);
· The Appraisals of Sustainability (particularly the impact on the AoS of any changes to energy policy, and issues relating to nuclear waste);
· Local authority capacity to deal with the pre-application process and to comment on applications (especially around nuclear in Cumbria) and the weight given to local authority reports by the IPC;
· Concerns about the difference in timing between the call for evidence by the ECC Select Committee by 15th January 2010, and the close of the consultation period for the Energy NPSs, on 22nd February 2010;
· How to engage with and respond to detailed extensive planning documents (which, in the case of the Nuclear NPS, also contain very important policy issues) in time;
· Concerns about impact of new nuclear build on local communities;
· Interim storage of radioactive waste and the IPC's role in consenting these facilities;
· The costs of decommissioning nuclear power stations;
· The status of the NPSs and how they would carry forward after the general election;
· Whether policy would change as a result of the consultation, and how that would impact on the AoS; and
· Whether the planning reforms truly represent a single consents regime, and if applications could 'pass' the IPC but fail other consents.
Delegates at the events have included representatives from local authorities, local residents and members of the public, energy companies, the nuclear industry, Regional Assemblies, RDAs, Parish Councils, CPRE, Commission for Rural Communities, Government Offices, planning consultancies and law firms, anti-nuclear campaign bodies, ICE, Nuclear Industry Association (NIA), and the National Federation of Fishermen's Organisations (NFFO).
Nuclear NPS Local Events
To date, local events have taken place at the following locations:
22e danceing locations:
The public meetings have been highly participative with no shortage of questions. Issues raised have covered such issues as:
· potential health impacts;
· interim storage of high level waste and geological disposal;
· safety concerns regarding the proposed reactor designs;
· the case for promoting a higher proportion of renewable energy;
· key local environmental impacts;
· the potential benefits of a future new nuclear plant to the local economy; and
· economic implications in terms of potential public subsidy to support the new nuclear programme.
Media coverage at the events included local radio bulletins and regional TV at the Hartlepool event, with radio and local press coverage at Hinkley Point, Heysham, Sizewell and Bradwell.
Transcripts of the local public meetings held at each location are uploaded onto the consultation website and can be accessed via the 'Nuclear' page under the 'Sites' link: www.energynpsconsultation.decc.gov.uk/nuclear/ssa
The detail of how the national and local consultation events are organised and structured is kept under review and amended appropriately following feedback to ensure we are responsive to issues raised.
Whilst we have made some changes to the format and venues for the national events and we are very receptive to any suggestions as to how they might be improved, we are nonetheless satisfied that the events to date, and those planned for the future, have constituted an effective means of consulting and provided an effective and meaningful opportunity for people to engage with and understand the Energy NPSs. We therefore consider the consultation process is fit for purpose.
CONSULTATION VENUES AND DATES
Nuclear Local Events
Stakeholder Workshop Events
* Appraisal of Sustainability and Habitats Regulation Assessment