6 Environmental aspects
44. For the purposes of the EU Habitats Directive,
[86] an NPS is
considered to be a 'plan' and therefore subject to an assessment
to confirm that it will have no adverse affect on a European protected
site.[87] However, plans
or projects where Imperative Reasons of Overriding Public Interest
(IROPI) are shown to outweigh the impacts on habitats and wildlife
are permitted under the Directive. The draft NPS states that the
Government has presented a case for IROPI since it "cannot
rule out the potential for adverse impacts" on European sites
resulting from the NPS, and has concluded that there are no alternatives
which would "better respect the integrity of European sites
and deliver the objectives of this plan".[88]
Defra's IROPI case is that the NPS is needed to ensure there is
no further deterioration in surface water quality which would
"lead to increased risk to human health and safety and consequences
of primary importance for the environment".[89]
However, this section of the draft NPS does not provide detail
as to how an improved planning regime for waste water projects
can assist in delivering such objectives.
45. The statement of Imperative Reasons of Overriding
Public Interest (IROPI) justifying development of this NPS should
be strengthened to reflect the considerable environmental benefits
which a streamlined planning regime can deliver through enabling
timely completion of necessary waste water infrastructure projects.
Climate change
46. Many waste water projects are carried out to
meet environmental requirements yet the projects themselves can
have climate change impacts, for example through increased energy
usage in construction and ongoing operation of infrastructure.
The Institution of Civil Engineers noted that, although applications
would have to demonstrate their adaptability to climate change,
there was no requirement for a project to incorporate measures
to mitigate climate change through low-carbon approaches to their
design, construction and operation.[90]
According to Ofwat, the draft NPS was deficient in its treatment
of climate change mitigation and should have recognised that projects
necessary to adapt to climate change could have "significant
carbon impacts which may undermine mitigation efforts". It
considered that the scope for energy and carbon savings of any
alternatives to projects should be made explicit.[91]
47. The EA also considered that clearer guidance
should be included on how proposed developments could contribute
towards reducing greenhouse gas emissions, in line with Defra's
climate change plan, including generating renewable energy from
methane. It also recommended that the NPS should require information
on greenhouse gas emissions to be included in Environmental Statements
accompanying project applications.[92]
Southwark Council also suggested improvements to the section on
climate change mitigation, for example by including a requirement
on applicants to increase tree canopy cover and expand green infrastructure.[93]
48. The draft NPS should be revised to make more
detailed reference to increases in greenhouse gas emissions that
waste water infrastructure projects could cause and to provide
stronger guidance to decision makers on the mitigation measures
they should consider imposing on project applicants.
86 Council Directive 92/43/EEC on the Conservation
of Natural Habitats and of Wild Flora and Fauna, also known as
the EU Habitats Directive, requires EU Member States to introduce
a range of measures for the protection of habitats and species
as listed in its Annexes. Back
87
The EU has established a Europe-wide network of Natura 2000 sites
including Special Areas of Conservation and Special Protection
Areas to protect habitats and species of European importance. Back
88
Draft NPS, p 6, para 1.5.2. Back
89
Draft NPS, p 6, para 1.5.3. Back
90
Institution of Civil Engineers, Submission to Defra NPS Consultation,
February 2011. Back
91
Ev 46 Back
92
Environment Agency, Submission to Defra NPS Consultation,
February 2011, p 4. Back
93
London Borough of Southwark, Submission to Defra NPS Consultation,
February 2011. Back
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