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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