Memorandum submitted by the RSPB
SUMMARY
In line with all the political parties and with many
other stakeholders, we support the principle of national policy
statements (NPSs). However the RSPB was highly critical of the
draft NPSs published in November 2009, which were highly deficient
as planning documents and in terms of compliance with environmental
law.
We welcome DECC's decision to re-open its consultation
and scrutiny process. However the revised NPSs are very little
changed: we remain concerned that they will neither speed the
delivery of a low carbon economy nor give adequate protection
to the natural environment. The revised appraisals of sustainability
still do not appear to serve the objectives, and to meet the requirements,
of the Strategic Environmental assessment Directive (2001/42/EC).
In summary the RSPB is disappointed that the revised
energy NPSs and associated appraisals have the following weaknesses:
- The NPSs have no more spatial expression than
the previous drafts, missing the opportunity to avoid environmental
impacts "upstream" in the planning process.
- The statement of need does not adequately address
development of the energy mix, nor does it set out limits for
deployment of any technology.
- There is no new requirement to consider the necessary
associated power lines at the same time as considering power generation
facilities.
- The IPC is not to consider the carbon emissions
of any proposal, unnecessarily jeopardising the UK's carbon budgets.
- No new conditions are placed on the sustainability
of fuels for biomass.
- The Appraisals of Sustainability make only a
cursory effort to examine alternatives, and thereby do not allow
for their direct comparison with the preferred plan.
- The revised appraisal process has contributed
almost nothing to the level of environmental protection afforded
by the NPSs.
- The time frame for consultation on the monitoring
strategy is not adequate.
MAIN CONCERNS
Lack of strategic vision and coherence
The NPSs represent an opportunity for DECC to undertake
joined-up, strategic planning for the delivery of essential infrastructure.
Strategic planning of this kind would help to anticipate and avoid
environmental damage, to reduce problems at the project planning
stage, and to provide greater certainty for investors and stakeholders.
However the NPSs are more development control documents rather
than strategic policy statements, so will not direct investment
towards locations and technologies with acceptable environmental
impacts. Further the energy NPSs are not integrated with each
other, so the IPC will not be able to consider infrastructure
development in an integrated way—for example both new power
stations and any new power lines they require.
Lack of clarity on infrastructure needed
Although the NPSs contain projections of demand,
the NPSs remain unclear on how much infrastructure is needed,
of what type and where (apart from nuclear). The NPSs assert an
overwhelming, urgent need for new infrastructure, which is used
to relegate any environmental concerns to issues of local detail.
Blindness to carbon emissions and unsustainable biomass production
The IPC is essentially "carbon blind" in its decision-making,
and is instructed not to consider the sustainability of biomass
fuel production. We consider that the IPC (or its successor) should
give significant weight to projects' carbon emissions, to ensure
that cumulative emissions from projects do not jeopardise the
UK's carbon budgets. While we accept that other aspects of energy
policy encourage low-carbon investment, we do not understand why
the NPSs cannot provide an additional safeguard. The same applies
to the sustainability of biomass production.
Weak Appraisals of Sustainability
Greater effort has now been made in the revised appraisals
to consider "reasonable alternatives", as required in
the SEA Directive. However, contrary to European Commission guidance
on application of SEA, alternatives to the NPS policies are not
addressed in the same way and to an equivalent level of detail.
Contrary to Government's own guidance (and to rules requiring
consultation of the public at a stage when options are open) the
alternatives are often ruled out within the appraisals. Indeed
the appraisals deal with alternatives in such a brief and cursory
way that they repeatedly fail to give meaningful information about
their likely impacts on the environment. Further, little effort
has been made to integrate the revised findings into the content
of the NPSs. Thus the appraisals do almost nothing to increase
the level of environmental protection provided for by the NPSs,
and therefore do not serve the SEA Directive's central objective.
Inadequate consultation on provisions for monitoring
Government proposes to develop its draft Monitoring
Strategy during the current re-consultation period, and then to
publish it alongside the designated NPSs. We do not consider this
provides an adequate timeframe for consultation on this important
aspect of the policy..
November 2010
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