The revised draft National Policy Statements on energy - Energy and Climate Change Contents

Examination of Witnesses (Question Numbers 124-165)

Dustin Benton, Simon Bullock, Simon Marsh, Dr Ivan Scrase

  Q124 Chair: Good morning, and welcome to the Committee. We're grateful to you for coming in. We have a fairly tight timetable, so we'll scoot straight in, if we may.

  When we saw the Minister, he said that the new ratification process improves the democratic accountability of National Policy Statements. Do you agree with that?

  Simon Marsh: From our perspective it is critical that there should be adequate time for parliamentary scrutiny. That is an issue we raised when we came in in January. We support the proposal that decisions should now be taken by the Secretary of State. We have campaigned for that for a number of years, so we're pleased to see the transition from the IPC to the Major Infrastructure Projects Unit. It is perhaps worth noting that, when we campaigned together on that three years ago as NGOs, more than 30,000 people wrote in response to the Planning White Paper.

  Q125 Chair: You talk about adequate time. I know that you are all as concerned as we are about the urgency of investment in low-carbon electricity generation. Delays in the planning process are undoubtedly one of the factors that increase the cost of any new investment. Is there now a conflict between our objectives? We can ask for more time, but the consequence might be to delay necessary low-carbon investment.

  Simon Bullock: I think the Secretary of State will still be making decisions on those applications that come forward. On the democratic accountability point, it seems to us that there is now a three-stage process: currently the IPC makes a recommendation and the Secretary of State takes the decision; when the NPS is designated, the IPC will take the decision; and after the Localism Bill is passed, in 2012 the IPC will be disbanded and replaced by the MIPU, which will make a recommendation and the Secretary of State will take the decision again. There will be an interregnum—roughly a one-year period—in which the Secretary of State won't be taking decisions, which will instead rest with the IPC.

  The Localism Bill had its First Reading yesterday, and the Government made it clear that they feel there has to be democratic accountability. The elected Minister must take the decision, which shouldn't rest with an unelected quango. We feel that perhaps it would be better if the NPS were ratified at the same time as the Localism Bill is passed. That would serve two purposes: first, it would mean that the Secretary of State would be taking the decisions throughout, so there wouldn't be a mixed-up, confusing system; and, secondly, the Government have made it very clear that the NPS should reflect energy policy. We're about to see major reforms to energy policy: emissions performance standards are coming forward; electricity market reforms are coming forward; and the Committee on Climate Change has just issued a huge report on the 2020s and 2030s. It seems to us that, if the NPS were ratified at the same time as the Localism Bill, that would allow the Government to reflect the new changes to energy policy, rather than having them ratified in 2011 and being almost immediately out of date.

  Dustin Benton: I think the same is true for the national planning framework, which is also being consulted on at this stage. There is an opportunity to tie those things together.

  Q126 Barry Gardiner: I declare my interest as a member of the Royal Society for the Protection of Birds. The Minister also told us that the UK needs four pillars: energy saving, more renewables, new nuclear and clean coal and gas. Do you think it possible to meet our energy needs and our mitigation targets without all four of those pillars?

  Simon Bullock: Yes; Friends of the Earth is opposed to new nuclear build. We don't believe that the case has been made that there are adequate, safe means for disposing of the waste. I can go into that if that would be of interest.

  Q127 Barry Gardiner: No, that wasn't the question I asked you. I asked whether it would be possible to meet our energy needs without them, not whether you thought it was a good technology or not. So don't tell me about the technology; tell me about whether it is possible to meet our energy needs.

  Simon Bullock: We believe that it is possible, yes.

  Q128 Barry Gardiner: In that case, tell me how.

  Simon Bullock: The Committee on Climate Change's report has issued a lot of technical data, alongside a very large report from Pöyry Energy Consulting about the possibilities for increases or different ways of meeting the 2030 and 2050 decarbonisation targets. A lot more could be done on renewables generation, on energy storage and on flexibility to ensure that we have security of supply and greener energy. We believe that it is possible for a combination of carbon capture and storage, a lot more effort on energy efficiency, a lot more effort on decentralised energy and offshore wind tidal renewables to deliver the 2030 targets.

  Q129 Barry Gardiner: Do you not find that strange—I am sure you followed the transcript of our session with the Minister very carefully—given that the Minister was slightly on the back foot when he had to admit that CCS is an unproven technology, and that quite a bit of reliance was placed on that unproven technology? Why are you so confident that CCS will work, and that it will be able to work in time and at a scale to make the difference to take account of the loss of 16 GW of new nuclear that the Minister suggested was needed by 2025? How can you be so confident that CCS can fill that gap, and how can it do it at 70 grams per kWh? That is what is required if we are to meet the 2030 targets that you support.

  Simon Bullock: There are two points there. The first is that I don't believe the Minister has made a convincing case that we need all this new gas and nuclear. I think the case the Government have set out for need in the NPS is not correct.

  Q130 Barry Gardiner: Again, you are not answering my question. My question was about CCS, in the first place. Let's go from there; let's take it in order.

  Simon Bullock: I accept and agree that it isn't certain whether CCS will be able to be done or not. I believe, and the Government believe, that it is technically possible to do it and they are putting in place demonstration programmes to try to ensure that it works. Paul Golby from E.ON gave evidence to you last week, and he made the very strong point that CCS really has to work if we are serious about meeting climate change goals globally. There is a very serious issue with China and other developing countries—developed countries as well—using huge amounts of coal.

  Q131 Barry Gardiner: Okay, Mr Bullock, rather than repeating what he said let me just drill down on what I am trying to get out of you, which is this. Given that you don't want nuclear—we haven't heard from the rest of the panel yet—if CCS were not able within the time scale to operate at such a scale as to produce the 16 GW plus the 2 GW that CCS coal was due to give in that mix according to the Minister, so 18 GW by 2025, do you honestly believe that you can get everything you need out of the alternative renewable technologies that are available?

  Simon Bullock: I'll only repeat that yes, I believe it is possible. I can send you a technical note on it if you would like.

  Q132 Barry Gardiner: Without CCS?

  Simon Bullock: Yes. I think that there would be five elements to it: more energy efficiency, greater renewables than the Government are saying, greater decentralised energy, a real effort put into storage technologies and interconnectors with Europe to deal with some of the peaking issues, and if CCS were not working there would have to be some role for using unabated gas plant at peak times. So that plant would be 350 grams/kWh, which I think is roughly what the best technology is at the moment, and I think there would have to be some use of that if CCS didn't work. I am confident that there are no technological barriers, and my opinion, and Friends of the Earth's opinion, is that it won't be technological issues that are the barrier to deployment of CCS; it will be cost.

  Q133 Barry Gardiner: Thank you. Can you also just tell us whether you think that specifying the generation mix would be ultimately more costly than leaving it to the market?

  Simon Bullock: I believe that the Minister, in his evidence, stated that it would be. I don't see any evidence from him that that would be the case. I think there is a real issue, however, in that the Government are saying they need 33 GW of new renewables to meet the renewables target, and that is a critical element of meeting our climate change targets. They say that we only need 18 GW of non-renewables, which is gas and nuclear. However, the Government's own figures in the NPS are showing that a vast amount of that 18 GW is already in the pipeline—being built or consented.

  In addition to that, there are a further 20 GW of new applications in front of the IPC right now. So we feel that unless there are significant changes to the electricity market, such that new gas wouldn't come forward—market conditions would make it less attractive—then there will be a new dash for gas. That will swamp, and mean that there will be less investment in new renewables, which is a real concern to us.

  Q134 Barry Gardiner: You offered us, in your previous answer, a note on how you would achieve the required energy production without CCS or nuclear, and we would be grateful if you sent that to us.

  Simon Bullock: Certainly.

  Q135 John Robertson: Is it not a fact that, no matter what is put in front of you, nuclear energy would be written off right away and that your organisation's hatred of nuclear energy would make you not want to include it under any form of any other energy mix?

  Simon Bullock: No. I don't think that is the case at all.

  Q136 John Robertson: So you would accept nuclear energy as part of the mix?

  Simon Bullock: No. I don't, because I don't believe—

  Q137 John Robertson: So I'm right.

  Simon Bullock: No. It's not hatred. I think that was your question, wasn't it?

  Q138 John Robertson: So you like it?

  Simon Bullock: I don't believe, and our organisation does not believe, that the case has been made that there are safe ways of disposing of nuclear waste.

  Q139 John Robertson: So it's only to do with waste; it's actually nothing to do with nuclear energy.

  Simon Bullock: No—

  Q140 John Robertson: And yet, for decades, we have safely secured waste without even having a set policy on it. You would accept that, surely.

  Simon Bullock: The waste is going to be around for tens of thousands of years. There has to be a safe method of disposing of it. The Government's NPS is saying that it will dispose of it, and the long-term solution is to put it into geological deep store, which it does not have, and there isn't one anywhere in the world. It is hoping that it is the same argument as with CCS.

  Q141 John Robertson: But other countries have been through this as well, and they are going down the road. It is not an immediate problem. It is not a problem that is going to happen in the next 10 or 20 years. We're talking 30 years before we need to have a repository. Why does your organisation get so hung up on nuclear energy and waste when there is proven scientific evidence of storage?

  Simon Bullock: I will give you one example of this. In the annexes on nuclear in the NPS, it says that they are proposing on-site storage of nuclear waste at Sizewell until 2130, so for 120 years before the new waste can be put into a store. At Sizewell, parts of that site are flood zone 3, so they have a one-in-200 annual chance of sea-storm flooding. A one-in-200 annual chance may not seem a lot, but over 100 years, that is a 40% chance of a sea flood. The Government are saying that at that Sizewell site, where they will be storing nuclear waste, there is a 40% chance of there being a sea storm FLOOD. That doesn't feel like an acceptable risk, which is the issue for us. It is about accepting the risk, and what we, as a society, should be prepared to take.

  I will quote from what the Government say on this, because it is important. On whether or not that was an acceptable risk, the Government then said, "there are no reasonably available alternatives to this site in a lower Flood Zone or at a lower flood risk and…all sites are needed in order for the Government to meet its objective." On the one hand, the Government are saying, "You can't argue about need because that's not something you can talk about in an NPS", but on the other, in this case, with this very decision, they are saying "No, the need for this site is so urgent, and there is no other way of generating that electricity, so we are prepared to accept that risk." We don't believe that that is the case. There are alternatives to building nuclear power stations that wouldn't involve such a risk.

  Q142 John Robertson: Okay, but your alternatives aren't necessarily proven, are they? We have talked about CCS, and we'd all love CCS to be a great success, but we don't know it will be—and yet we can't keep putting off planning for the future. Are the needs of the nation not important? Lots of your ex-colleagues have come at this from the opposite angle to you, and you know that. My problem is that, as a Member of Parliament, we have to put the needs of the nation first, and it would appear that, in organisations such as your own, you put your dislike of nuclear long before the needs of the nation.

  Gentlemen, I want to bring you in, because I feel like I'm picking on Mr Bullock and I don't mean to. I would like to pick on the rest of you as well, perhaps. Are we putting too much reliance on CCS or, as Mr Bullock has said, does the cost not matter, and do we have to go down that road no matter what? I think his actual words were that this "has to work." What happens if it doesn't?  

  Dr Ivan Scrase: As I understand it, there aren't any strong technical reasons to think that CCS wouldn't work. It would be very costly—

  Q143 John Robertson: They say the same thing about the storage of nuclear waste, of course.

  Dr Ivan Scrase: Yes, but you still have a very toxic substance that is going to be around for tens of thousands of years—that is not the case with CCS—and that is our concern.  

  Q144 Chair: Well, the greenhouse gas emissions from burning coal will be around long enough to do a lot of damage to the climate. They don't disappear within a few months.

  Interestingly, only last week, in one of the only two serious experiments with CCS, the company concerned went into administration. Most of the commercial and financial difficulties that need to be overcome seem to me to be lightly set aside by people, who say, "Well, it's all going to be fine." Mr Bullock said that we will solve the problem by burning lots more gas—that was the solution as I understood it. However, that gas is emitting, at best, five times more than the amount of emissions that will be acceptable in 20 years' time, so we will have a huge number of redundant gas plants that will not be capable of being used if we are going to hit our 2030 targets. We all have difficulty understanding why there is this blind faith that somehow, CCS will come on stream in five years' time at a price that won't quadruple electricity costs to consumers. What's your answer to that—any of you?

  Dr Ivan Scrase: It's a very sorry situation that we have come to the point where we need such technology as CCS. I believe that, as Simon has said, it has to work, and there are no reasons to think that it wouldn't.

  Q145 Barry Gardiner: Dr Scrase, we can wring our hands about the past and we can have blind faith because we can't see an alternative. However, surely the responsible thing to do is neither of those—neither to wring your hands nor to have blind faith in the technology "having to work"—and actually say, "What we have to do is plan along a set of different channels, which will enable us to have a reasonable expectation that, with a minimum level of risk, we can keep the lights on at a price that will be politically acceptable." Does that not seem like common sense to you?

   Dr Ivan Scrase: Yes, it does, and if we had some reassurances from the Government about how much, for example, CCS or nuclear we would have, and if we had some indication of where such things would go and what the environmental impacts would be, we would have a lot more confidence.

  Q146 Barry Gardiner: With nuclear, we have; we have had 16 GW and we have the locations mapped out—two fewer than there were originally, but they are mapped out.

  Dr Ivan Scrase: There is no upper limit on it, and it is only up to a certain date, but yes, there is more clarity on nuclear. In general, outside nuclear, there is a great lack of clarity on how we're going to keep the lights on. Like everyone else, we would like more certainty on that.

  Simon Bullock: I come back to the issue of CCS. It isn't an unconsidered view, and we are not putting blind faith in CCS at all. It is very important that the Government put a lot more effort in and have much stronger policy certainty and stronger policy leaders in place to bring in all the alternatives, and we have not had strong policy signals on those in the past 10 years. That includes CCS. It also includes energy efficiency and decentralised energy, where some good stuff has happened recently.

  It is not all a bad news story. Work on storage, interconnectors, as I mentioned, demand-side responses, smart grid—all those things are critical elements of it. I believe that if we go for those technologies in a really strong way—and we need to have much stronger signals from Government to do that—then we will be a very long way down the line by about 2020 or 2022 to meeting those carbon targets. If at that point we have found that CCS either doesn't work or is prohibitively expensive, then I believe there will still be time to invest in other alternatives, and that might be the time to look at nuclear and say, "Is nuclear now an option because we can't go down the CCS route?" That is the problem for us. A lot of these options are not perfect. Friends of the Earth and I personally do not want to see nuclear.

  Q147 Chair: So Friends of the Earth's principled objection to nuclear actually depends on whether CCS turns out to be viable or not, and the principles will only change if CCS doesn't work?

  Simon Bullock: No.

  Q148 John Robertson: Who pays for this? If we keep waiting and we keep putting things off, if we want to introduce new forms of renewables and so on at a time when every Department is cutting back, who is going to find the money to pay for this?

  Simon Bullock: The research that the Climate Change Committee published last week said that some of the things that I have been mentioning around energy storage, interconnectors and decentralised energy will reduce the capital costs. The electricity market reform options that the Climate Change Committee looked at said that doing this will reduce the capital costs of building some of these plants.

  Q149 John Robertson: That's if they work properly and as they should. Unfortunately, the history shows that it doesn't, so can you get the energy of this nation from unreliable sources?

  Dustin Benton: On the question of cost, we should bear in mind that energy saving is almost always cheaper than using energy, and if we are really concerned about costs then that should be the first thing that we do. This is slightly outside the remit of the NPSs, I admit.

  Chair: Yes, I think we ought to return to the NPSs, interesting though this debate is. We can cover it on another occasion.

  Q150 Sir Robert Smith: We have all preached energy conservation and energy efficiency, but we haven't yet delivered it in the way that we should, so I just wondered whether, in the interests of speed, Mr Bullock, you could expand on that in your written response.

  Simon Bullock: I was preparing for an NPS session!

  Chair: Laura, on NPSs.

  Q151 Laura Sandys: I am not sure you have had a chance to read all of this since yesterday when the Localism Bill was published, but how do you see the NPS and the Localism Bill process working together? As John rightly said, we all have energy security and cost of energy as our core national interest here. Do you think the NPSs and the Localism Bill will deliver that certainty for investment? I appreciate that you are not in the investment sector, but do you feel that that gives everybody the certainty that they need?

  Simon Marsh: I think the issue with the Localism Bill and the changes to the planning regime is that there is still a degree of uncertainty about how the NPSs will relate to the rest of the planning system. This was an issue we had earlier in the year. I don't think the Localism Bill helps us particularly in that respect. We have been promised a national planning framework, which my colleague mentioned earlier. That doesn't appear in the Bill and our understanding is that that will be a non-statutory plan, but I think it will be very important for that to relate quite closely to the national policy statements. I don't know whether the intention is to incorporate the national policy statements within that, maybe not straight away. But it seems to us that there continues to be some uncertainty. We would like to see the national planning framework given the statutory basis in the Localism Bill that it doesn't seem to have at the moment. There is a still a question mark about that which needs to be resolved.[1]

  Dustin Benton: One way that we could increase the amount of certainty that the NPSs provide would be to provide a more spatially explicit framework. I am not suggesting that we need to be as spatially explicit as we have been on nuclear, but certainly one way to help companies, and indeed people, who are concerned about delays in the planning process is to be much more explicit about where things should or should not go. The perfect counter-factual example of where it is not working is the Triton Knoll substation. Because there is no strategic guidance on location, the consultation is on the actual substation, not on the 400 kV lines that would be 40 km long, or longer, to connect it up to the grid, and people are crying foul. This is the sort of problem that not having a strategic approach creates, and that is only going to create more delay, which I do not think is in anyone's interest.

  Q152 Laura Sandys: Do you see any conflict between the objectives of the Localism Bill, which intends to give local communities much greater say, and the NPSs, and how that will be arbitrated through the Secretary of State?

  Simon Marsh: I think we would recognise that. We would broadly welcome the thrust of localism, giving local people more say in the planning system, but at the same time there is a need to make decisions on nationally important infrastructure at the national level. So we don't have a problem with that in principle, but it may give rise to some confusion in the public eye. Essentially, you have two planning systems in England, and indeed in Wales as well, and that needs to be carefully explained.

  Q153 Laura Sandys: I haven't declared my interest; I am a patron of the Campaign to Protect Rural England, Kent. But there will be certain moments, particularly with some of your organisations at grass-roots level, when there will be something that has been designated under the NPS that is a very important part of our energy infrastructure. Some of your local groups will question whether the substation should be there, or whether certain power lines should go in this direction or that. Will you work with your local organisations to put that context together, or do you feel that in your organisation's work the community bodies have more power than the centre? Are you going to have a disconnect in your policies between your grass roots and your policy units?

  Simon Marsh: The short answer is that we would seek to work with our local groups to guide them through the planning process and how they can best engage with that, while at the same time trying to influence national policy on these issues as well. I do not think that there is necessarily a disconnect, provided that people properly understand how the planning process works.

  Dustin Benton: I think there will always be a challenge about having large, national-scale infrastructure that happens to take place in local areas. People, I think, are reasonable. When things are explained to them, and they feel that they have an opportunity to question and have answers and to see that the decision is made properly, then they will consent to infrastructure. But one of the challenges with how the NPSs are put, particularly in relation to need—although it has been elaborated, which is very welcome, "need" is still, for the purposes of the IPC, considered to be a simple, monolithic "need: yes" or "need: no", and the answer is always yes—is the concern that will cause locally. People will perhaps feel that they do not have the opportunity to make their case in a fair way, because need will simply override what they are saying.

  I certainly think that there is a case for taking what the Government have given us in their justification of need, and pull out the fact that there are differences in the way in which need affects what we do. We have need for security of supply reasons, and we have need in relation to decarbonisation. We have need in relation to what is actually built, so if we consent to a lot of infrastructure, that obviously affects need, to any reasonable person. But for the IPC, it is not clear that it will be able to consider that. When local people, who are involved in planning and who are concerned about their area, see this they will feel that it is not particularly just. The Government could very easily take a look at that and incorporate that into how the IPC makes its decisions. That would help to build the good will required to deliver the necessary infrastructure.

  Q154 Chair: Do you think that the NPSs should go further to give priority to climate change mitigation?

  Simon Bullock: I think what the NPSs do not do at the moment is give a clear enough steer as to what happens in the 2020s and 2030s. A very strong recommendation of the Committee last time was that the NPS should adopt the 2030 decarbonisation target. In my view, the Government ignored that recommendation in their response. That point is made even stronger now, because the Climate Change Committee has formally said in its fourth budgetary report that that level of decarbonisation is essential by 2030, and that is to meet a target that it says is an absolute minimum, as well. I think that a strong thing for the NPS to do would be to make it explicit that the pathway to 2050 is really important. It is the total emissions under the curve over the whole 40 years between now and 2050 that matter, not just the end point. That is particularly important because in their need case the Government are saying that there is a range of different ways in which need can be met. If you don't have a 2030 target, that basically says that anything goes, and that any way of generating electricity will be okay because, frankly, 2050 is a long way away and we will be all right. 2030 gives a clear steer that we need to be decarbonising really fast through the 2020s and that some generating mixes would not be compatible with that target.

  Q155 Chair: So if there was a carbon assessment for an individual project that showed that it was too carbon-intensive, would that be a reason for turning the scheme down?

  Simon Bullock: I think there are two things here. We have discussed this with DECC and I think it is fair to say that it would not be reasonable to expect the IPC to make a judgment on whether an individual proposal was compatible with the entire carbon budget process, because loads of things are going on in all sectors. The Committee on Climate Change can take a view, and I think it should annually look at things that are being approved by the IPC and see whether that is generally compatible.

  Personally, I think that the best approach would be, if the Government say that we need 18 GW of new, non-renewable capacity—that is what they say we need by 2025—the NPS should be clear about it. It should say, "The IPC should not consent more than that quantity, because it would damage our capacity in relation to renewables." I don't think that's a problem. The Government seem to be implying that planning is somehow separate from the rest of policy regulation, but it is not; it is a market regulation like any other. It is important to have that safeguard to ensure that the renewable aspect of the electricity generation mix is not damaged by a rash or glut of new gas projects in the next five years.

  Q156 Barry Gardiner: I think that many of us share the concern that run-away on the one should not impair the investment that flows into the other. How would you respond to the argument that, if there was cherry-picking, they would effectively say, "This or that scheme can or can't proceed, because there is already too much in the area of coal, CCS and so on"? What you are then doing is picking and choosing, in a market situation, which company should be allowed to make those investments and benefit from the returns. Therefore, you would be driving competition out of that sector that might otherwise be to the benefit of people.

  Simon Bullock: First, I am not a planner. We have planning experts at our organisation to provide a note on that. If you had a first-come-first-served business for the first 18 GW of renewable capacity, it seems to me that quite a lot of people would be trying to get it. If there is a view that more applications will come forward, we would want to get them forward as fast as possible. They will be competing against each other.

  Dustin Benton: Doesn't a similar situation arise if you allow consent as much as you like, because then you give market operators the opportunity to pick and choose sites from ones they have had consented? That is hugely problematic from the perspective of environmental protection, because if you simply consent a large number of sites, you might as well not have planning if you can't actually constrain them.

  Q157 Barry Gardiner: I don't think that any of us are countenancing approval willy-nilly. It is a matter of whether you are doing it specifically because we already have too much gas, coal and nuclear, and are therefore not allowing a development because you already have enough of it in your mix. That is what we suggested ought to be done, so it does not fail to look at the other environmental considerations.

  Simon Bullock: Why would that be a problem?

  Dr Ivan Scrase: I think that the concern you are talking about is Government picking winners. This has obviously been a massive failure in the past. We are not talking about Government choosing specific technologies or companies. Energy companies tend to have a broad portfolio of technologies in which they can invest. Within any sector there are a range of competing technologies, so even within the fossil fuel sector and the renewable sector there are many technologies. No one is suggesting that Government should declare, for example, that a particular design of gas turbine is the Government's favoured one and go for it. That is the sort of thing that created problems in the 1970s; nobody is suggesting that now. You can, however, have a view on the level of broad classes of technology that are appropriate in an energy mix, which is what the Government are refusing to do.

  Q158 Barry Gardiner: Your view, then, would agree with Mr Bullock's—that the Climate Change Committee should be looking at the consents on an annual basis to ensure they are broadly in line with the mix it has specified.

  Dr Ivan Scrase: On carbon grams, they wouldn't necessarily have to look specifically in great detail at the specific technologies within any class, but yes.

  Q159 Barry Gardiner: Have you done any analysis of the detriment to investment in renewables that may result from an over-lax consenting regime for non-renewables?

  Simon Bullock: Only to the extent of analysing the figures that the NPS itself produces. It is saying that you need 33 GW of renewables and 26 GW, of which 8 is already built, of non-renewables. So 18 GW of non-renewables is to be built, and it looks from the Government's figures as though 14 of those are either with consent or in the pre-IPC regime. Then there is another 20 GW in, so already there is almost double what they say is needed. If those have been brought forward because the developers believe they want to build them, the likelihood is that they will build them, and that means that automatically there is less of a demand or need for the 33 GW.

  Q160 Barry Gardiner: Good point—not my question, though. I am asking whether you have done any calculations of your own on how the over-supply in non-renewables financially will affect the investment in renewables. It seems to me that the case that is always most winning with Government is the one that clearly shows the figures.

  Simon Bullock: At this stage, no. We took the view that the Government might be more convinced by their own figures than by ours.

  Q161 Dan Byles: I want to talk briefly about the revised appraisals of sustainability. I understand that your organisations have been critical of some aspects of them. Do you think the revised AOSs indicate that the Government are taking impacts on the landscape seriously?

  Dr Ivan Scrase: The revised appraisals in our view are significantly better than they were the previous time. We are still not happy, however, that they are performing the function that they should as strategic environmental assessments, which is to provide information about the impacts on the environment of implementing the policy and of implementing alternatives to that policy.

  There are two major problems. The alternatives, as they are, are very unclearly specified. One has to dig around in an annexe and six different sections of the appraisal to find out what might be in them. Nothing is clearly in or out; some of them are said to be definitely in, but then there are policy reasons for not accepting those ingredients. Some of those that are very important, such as energy saving, are said to be likely to be in the alternative we are most interested in, which is a policy to give greater protection to the natural environment. We don't know whether greater energy saving is in there or not.

  When it comes to assessing those effects, we come to a section that asks what the impact of that alternative would be on the natural environment. It simply says that if there were policies that were more positive for the natural environment, that would be positive for the natural environment. That literally gives no information. It is not quantitative and it is not qualitative; it is nothing. It is just a tautology, really. The Government's own guidance on how these things should be done says that the alternatives must be very, very clear, and if there is a lack of clarity on what the impacts would be, you should go back and reduce that uncertainty.

  The Government have said that their view is that this must be a more strategic level assessment, because it's a strategic kind of document. There is no reason, however, to treat the alternatives in a different way to the plan itself, which is what the Government have done. In doing so, they have ended up giving us no clear indication of exactly how those impacts would differ. We want to know. If it is a genuine alternative under genuine consideration, we want know what sort of impacts it will have.

  Q162 Dan Byles: So do you think the alternatives should be gone into in the same level of detail or just a greater level of detail than they have been?

  Dr Ivan Scrase: They should be gone into in the same level of detail.

  Q163 Dan Byles: Do you not think it would be impractical to try to cover all the alternatives in the same level of detail as the actual proposal?

  Dr Ivan Scrase: No. It would involve a fair amount of work, but it wouldn't be impractical.

  Dustin Benton: Can I just make a point on that?

  Chair: Yes, but we're running out of time, so quickly.

  Dustin Benton: I will be brief. Outside the AOS, the Government have done some things that, perhaps unintentionally, do affect the landscape quite negatively. The most obvious one is the Holford rules, the wording of which has changed from stating that they form the basis of how you site electricity transmission infrastructure to something that simply needs to be borne in mind. That is a dramatic reduction.

  There is a similar point in relation to protection for AONBs and national parks, which are, of course, the most outstanding areas of our country in landscape terms. The introduction of a provision on the importance of the regional economy to potential projects, which is completely new and is not in the relevant NPS, runs the risk of dramatically weakening protection for landscapes. That is not something that I think is picked up in the AOS.

  Q164 Chair: On the specifics, one of the consequences of all this investment in renewables is a need for much more transmission capacity. National Grid is stuck in the 1960s and seems to think that the answer to that is lots more overhead pylons everywhere. Is there any aspect, in any of the NPSs, which can offer any comfort to constituents like mine, living in an AONB, that we are not going to see masses more overhead power lines across our most beautiful parts of England, Scotland and Wales?

  Dustin Benton: Well, the Holford rules in the previous draft provided some comfort; I think that they provide less comfort in this particular example. There is a wider issue, though, which is that there is a bias in favour of overhead lines. That appears both in the NPSs and in the Planning Act 2008, which specifies above-ground infrastructure as what the IPC can consider. It is certainly worth looking at whether that should be changed to something more neutral about transmission infrastructure, so that when the IPC or MIPU—whoever is deciding the future—takes decisions, they are not constrained simply to looking at overhead lines.

  There is, however, a wider point about the way that planning operates for transmission lines. That is because we know we are going to need quite a lot more transmission lines, particularly offshore. But that provides us with an opportunity to reconfigure the network, which is, in a sense, outside of the NPSs. But the NPSs, because of the way they are drawn up, simply promote the 1960s way of looking at transmission, which is a real shame.

  Q165 Chair: Would it not be helpful if we put into the NPSs a requirement that alternative underground or undersea transmission methods should be considered in relation to all transmission applications?

  Dustin Benton: Absolutely.

  Chair: I think we're going to have to move on to the next set of witnesses. Thank you very much for coming in, and we look forward to another debate on a future occasion.

1   Note from the witness: 'The Open Source Planning Green Paper (published by the Conservative Party in February 2010) proposed a simple and consolidated National Planning Framework (NPF). Alongside the abolition of the Infrastructure Planning Commission, it also proposed to "integrate the National Policy Statements into our revised and simplified system of national planning guidance".

We understand that it is unlikely that NPSs will be integrated in this way, at least in the first iteration of the NPF. There is currently no formal consultation on the NPF, although we understand that an announcement may be made shortly.' Back

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