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


Supplementary memorandum submitted by the Department of Energy and Climate Change

EXTRACT FROM RESPONSE TO THE SELECT COMMITTEE ON THE INCREASE TO PROVISION FOR BRITISH ENERGY LIABILITIES IN THE 2010-11 WINTER SUPPLEMENTARY ESTIMATE

RSPB CRITICISMS OF AOSS

The Committee also asked about the RSPB's assertion that 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."

The revised AoS has established a series of alternatives that could deliver clean, secure and affordable energy. The revised AoS gives details of how these alternatives were arrived at, with explanations as to why some were ruled unreasonable and therefore not assessed. The revised AoSs for EN-1 to EN-5 considered over 10 reasonable policy alternatives, using a common appraisal framework before a more detailed appraisal of the preferred option. The assessment was thorough, although necessarily at a strategic level as the NPSs themselves are strategic.

The level of detail in which either the NPS policies or the alternatives to them can be appraised is determined to a large extent by the level of detail in the revised draft NPSs themselves. Thus there is an obvious difference in the level of detail which can be applied in the case of the site-specific NPS EN-6 and the "non-nuclear" NPSs EN-1 to EN-5. We consider that the way in which the alternatives have been described and evaluated is, in the words of the Guidance, "comparable" with the description and evaluation of the NPS policies. It is not identical, but it is not required to be so. More specific environmental assessment will be done at the individual project level.

The revised AoS was responsible for making significant changes to the NPS, notably; the clarification of policy alternatives and additional input into the environmental effects and mitigation contained within the energy NPSs. Such changes include, but are not limited to:

AoS process flagged up potential significant effects on water resources so a section covering impacts and mitigation was added to EN-3.

The AoS raised concerns around the effects of "flaring" on climate change which prompted revision of the text within the NPS.

AoS flagged up the issue of bird strike for overhead lines. The NPS now incorporates a section on the effects and mitigation.

I hope this is helpful to the Committee.

January 2011


 
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