Memorandum submitted by the Campaign to
Protect Rural England (CPRE)|
CPRE recognises the urgent need for low carbon energy
infrastructure and the challenge climate change poses. We have
welcomed the development of National Policy Statements (NPSs)
in principle. We have been very critical of the first set of Energy
National Policy Statements, however, because they: lacked any
significant spatial guidance, restricting the benefits which could
be gained from strategic planning; asserted an essentially unlimited
need for new energy infrastructure, undermining the ability of
planning to integrate competing demands on land use; insufficiently
engaged the public in debate over the UK's energy policy; and
failed to enable consideration of reasonable alternatives, including
through the Appraisals of Sustainability.
While a number of changes which improve the NPSs
have been made, we are disappointed that few of the above criticisms
have been effectively addressed. Notably:
- the NPSs have not been strengthened to enable
the planning system to direct infrastructure to the least environmentally
- although the need for new infrastructure now
has an evidence base, the NPSs provide no guidance on how decisions
should be affected by expected need, other than to assert that
the need is significant. There is, for example, no suggestion
that need will not continue to be significant if the IPC consents
enough infrastructure to meet expected need;
- despite very significant public concern about
the impact of overhead power lines on the countryside, protection
for Areas of Outstanding Natural Beauty and National Parks has
actually been reduced in the revised drafts. This is a matter
of serious concern to CPRE; and
- minor changes to the wording of certain sections
are likely to have significant impacts on the interpretation and
meaning of the NPSs. These changes have not been adequately highlighted
to the public.
As national planning documents, the draft energy
NPSs should set out spatially explicit guidelines to help direct
the future development of energy infrastructure. Giving a stronger
steer to decision-makers about the optimum locations for new energy
infrastructure would make it more likely that future energy infrastructure
could be developed in a coherent manner which integrates environmental,
social and economic concerns. CPRE would like to see more detailed
spatial criteria in the documents to ensure applications come
forward for projects in the most appropriate locations. Providing
more spatial criteria is likely to reduce uncertainty for developers
and the public which should allow for more rapid development of
necessary infrastructure. We are concerned that the absence of
more explicit spatial guidance will lead to poorer outcomes for
the natural environment.
This is not merely a theoretical concern. For example,
experience of pre-application consultation for the substation
required to connect the Triton Knoll offshore wind farm to the
national grid highlights the risk of the current approach. The
location of the substation is subject to consultation, but the
fact that all proposed sites for the substation are approximately
40 km from the nearest suitable 400 kV overhead lines is not considered.
Indeed, the required overhead lines to connect the substation
are entirely outside of the consultation, and risk not being considered
at all by the Infrastructure Planning Commission or a future Major
Infrastructure Unit of the Planning Inspectorate.
Similar concerns relate to the consenting of carbon
capture ready (CCR) gas fired generation. All new gas generation
will need to be CCR, but there is no guidance about whether or
not decision makers should prefer projects sited near potential
CO2 transmission infrastructure or storage sites.
Currently, draft EN-1 asserts the need for 59 GW
of new generation capacity by 2025. Of this, approximately 16.5
GW is already consented, with a further 23 GW in planning or firmly
proposed, as evidenced by National Grid's seven year statement.
In total, there is therefore some understanding of where around
two thirds of required capacity for new energy infrastructure
may be built.
While not all of this will be consented, and some
of those projects that are consented will not be built, the fact
that the way in which need is considered by decision makers does
not relate to the amount of infrastructure that is proposed appears
perverse. In a sense, the fact that the revised draft NPSs contain
a detailed case for need supports the argument that an understanding
of how much need has been fulfilled should be incorporated into
decisions on major infrastructure projects.
As it stands, there is a risk that major infrastructure
planning will be unable effectively to perform its development
control function by directing necessary infrastructure to the
most suitable sites. It is also unlikely to be unable to respond
intelligently to oversupply of energy infrastructure which may
jeopardise wider policy goals (such as a large increase in gas-fired
generation). Moreover, the possibility of overconsenting may mean
undue frustration for local communities and developers "cherry-picking"
the cheaper, environmentally less appropriate sites.
Electricity networks have a significant impact on
the beauty and tranquillity of the countryside. To date the industry
has followed a set of principles, the "Holford Rules",
in routeing new overhead lines. These have generally worked effectively
to limit this impact.
The majority of 1,100 public responses to questions
on electricity transmission policies in the first drafts of the
NPSs (just under a third of the 3000 responses received to the
consultation on all six NPSs as a whole) called for stronger policies
to control the visual impact of overhead lines. About 600 of these
were, according to the Government, directly inspired by the campaigning
of CPRE and partner organisations.
Disturbingly, the second draft of the NPS on electricity
networks proposes to weaken the standing of the Holford Rules.
The original draft stated that decision makers should recognise
that the Rules should form the basis for the approach to routeing
new overhead lines, and applicants should be expected to follow
them where possible.
The latest draft only says that decision-makers "should
bear them [the Rules] in mind". In CPRE's view this would
mean a significant weakening of the Rules. It is likely to mean
that there will be no requirement on either (i) electricity companies
to demonstrate that they have sought to avoid damaging impacts
to important areas of landscape; or (ii) the decision maker to
base its evaluation of a proposed overhead transmission line scheme
on whether the Holford Rules have been met. Nor is there any expectation
that the mitigation measures suggested in EN-5 (paragraph 2.8.9)
should be carried out for schemes where one or more of the Holford
Rules are not met. We fear that the effect of this would be seriously
to weaken the protection of the countryside from unnecessary and
intrusive energy infrastructure.
Minor Changes with Major Impacts
Other minor changes to the wording of several sections
of the NPSs are of concern to CPRE. Because NPSs have a different
status under the Planning Act 2008 than existing PPSsdecisions
on major infrastructure must be taken in accordance with the NPSs
rather than existing policyminor changes in wording can
have major impacts on countryside protection.
A few examples of such changes are detailed below:
- Paragraphs in section 5.8 of EN-1 on the historic
environment almost exactly repeat existing protections in PPS5,
except that they remove references to non-designated assets. In
particular, paragraphs 5.8.12 and 5.8.17 add the word "designated"
to existing language in PPS5, weakening protection for non-designated,
but still important, heritage assets.
- Paragraph 5.9.9 of EN-1 on visual and landscape
impacts repeats the new "contribution to the regional economy"
criterion which first appeared in the previous draft EN-1. This
is a significant departure from existing protections for nationally
designated areas and significantly reduces their protection.
- Paragraph 5.12.8 of EN-1 identifies developer
contributions as a material consideration for planning decisions.
While we welcome the consideration of these benefits through the
planning process, the NPS should specify that contributions should
relate to the purpose of the project (eg. community benefits for
energy projects should contribute to local energy saving or microgeneration).
- Paragraph 5.10.12 of EN-1 advises applicants
on ways in which to circumvent Green Belt protection. This is
This is by no means an exhaustive list of the changes.
We are concerned that democratic scrutiny of the revised draft
NPSs has been made more difficult by these changes being summarised
as drafting changes, ostensibly used simply or clarify, rather
than changes in policy, which deserve public scrutiny.
1 Note that this only partially takes into account
the spatially explicit proposals for new nuclear power stations. Back