Examination of Witnesses (Question Numbers
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
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 interregnumroughly a one-year periodin
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
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
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 strangeI am sure you followed the transcript
of our session with the Minister very carefullygiven 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 countriesdeveloped countries as wellusing
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 nuclearwe haven't heard from the rest
of the panel yetif 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
pipelinebeing 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 forwardmarket conditions
would make it less attractivethen 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
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 beand 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 yearsthat is not the case with CCSand
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 gasthat 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 thatany 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 thoseneither 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 outtwo
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
gridall those things are critical elements of it. I believe
that if we go for those technologies in a really strong wayand
we need to have much stronger signals from Government to do thatthen
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.
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
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
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 needalthough 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 yesis 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
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
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
Personally, I think that the best approach would
be, if the Government say that we need 18 GW of new, non-renewable
capacitythat is what they say we need by 2025the
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
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'sthat 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 pointnot
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
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
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 MIPUwhoever is
deciding the futuretakes 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
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
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