Energy and Climate Change CommitteeWritten evidence submitted by the National Trust
Executive Summary
1. The National Trust supports Government’s ambitions to tackle climate change and the UK’s targets to reduce carbon emissions and increase the proportion of overall energy generated from renewable sources. We share the sense of urgency in deploying and developing solutions to move the UK towards a low carbon society.
2. We believe that securing widespread public support for the transition to a low carbon economy is critical. This will be helped considerably if large-scale renewable projects are seen to respect the natural and cultural environment.
3. The National Trust recognises the Severn Estuary as a unique environmental asset of international importance requiring careful management on sustainable development principles. We also recognise the potential of the Severn Estuary’s vast tidal range to generate electricity and welcome the assessment of a range of options for harnessing this power.
4. The National Trust owns various coast, countryside and heritage sites around the Severn Estuary which could be affected in some way by generation of tidal energy. Our response to emerging proposals will be informed by our statutory conservation objectives and our duty to maintain the integrity of these important places for the benefit of the nation in a changing environment.
5. Wave and tidal power will both have an essential part to play in moving to a low carbon power sector. We therefore support exploration into harnessing the tidal power resource of the Severn estuary in order to contribute to emissions reductions and harness the Severn’s tides in a sustainable way.
6. The National Trust was engaged with its partners in the Government’s Severn Tidal Power Feasibility Study. In our consultation response we said that the Government should seek to identify a project which maximises the generation of renewable energy, while minimising damage to the Severn Estuary’s internationally important wildlife, and natural and historic environment. It should be at an affordable cost to tax-payers and consumers, not in itself carbon-intensive in construction and operation, and form part of a coherent plan to put the UK at the forefront of sustainable tidal power technology.
7. Any solution should also be consistent with two tests. The first is compliance with EU law, eg the Habitats and Birds Directives. Secondly, the solution should form a significant part of a radical plan to tackle climate change, including reduction in energy demand, rapid deployment of sustainable, low impact renewables and development of a more decentralised energy system.
Specific Issues
Finding the optimal solution using the most innovative technologies
8. One of the concerns we raised during the feasibility study was how we assess proposals in a way that give environmental constraints equal consideration alongside economic factors, energy generation potential and technological advancement in the design of any solution to harness the power of the estuary.
9. We believe that an essential part of any discussion on Severn tidal power is identifying the optimal option in terms of environmental, economic and technical criteria. Any future project must therefore be developed on the basis of socio-environmental considerations, as well specified economic and technical outcomes in order to identify the option which is in the best public interest and take advantage of the most innovate technologies.
10. During the previous Feasibility Study, we concluded that, had the value of environmental assets been properly considered within the assessment framework, it is unlikely that the Cardiff-Weston barrage would have been short-listed. The Phase I analysis predicted that it would destroy 80% of the internationally important intertidal habitat and result in considerable mortality of the internationally protected fish populations. We are concerned that a disproportionate focus on a Cardiff-Weston proposal may result in resources and investment being diverted away from alternative solutions for harnessing the power of the Severn, which could be both sustainable and more easily transferable to other estuaries.
Scope of Environmental Assessment
11. Any assessment of the current proposal would need to ensure that the evaluation of energy, cost and environmental impact criteria is unbiased and weighted appropriately. We would like to highlight the following critical issues which need to be given full consideration as part of this, particularly in relation to the scope of the assessment of environmental impacts:
12. Sea level rise, coastal change and flooding: As a major coastal landowner, the National Trust supports flexible management solutions which can enable, or adapt to, the processes of coastal change and predicted sea level rise. Any development on the coast should take proper account of these factors and give sufficient consideration to the latest science on sea level rise, and that the implications for alleviating or adding to flood risk, in looking at the viability of the different options. This would mean taking into account the impacts of predicted sea level rise, informed by UKCIP projections, overtly and in detail.
13. There are a number of critical areas of research required into coastal processes and estuary dynamics based on i) how the estuary is going to respond to sea level rise in it’s current form and ii) how the system will respond to sea level when modified by the addition of the tidal power infrastructure. The key questions are:
a calculation of the amplification of sea level rise impacts both spatially and temporally;
how will estuary sediments respond to these changes—helpful data may exist as a result of marine aggregates studies;
will contaminants held within with the historic sediment profiles be mobilised;
what will be the impacts on shoreline erosion/accretion; and
what will be the impacts on inland and coastal flooding?
We believe that modelling studies are required to enhance understanding of current and future estuary dynamics to inform decision making.
14. Landscape and seascape: Any proposal needs to give full consideration of impacts on landscape, settings and. The protected landscapes potentially affected are a vital part of the region’s economy and culture and consideration would need to be given to how they will be affected. This includes potential loss of visual amenity and other impacts on the landscape and seascape and public access to those places. During the Feasibility Study we felt there was an inadequacy of information and understanding on these aspects. A full assessment of the potential impacts on the land and seascape is required together with an understanding of public perception of such changes.
15. Historic environment: Any proposal would need to study the historic environment and the potential loss of heritage and archaeological assets. This should include the impacts on historic gardens and landscapes and industrial heritage, as well as the well preserved archaeology and palaeoenvironmental records within the River Severn Basin.
16. Ancillary development and indirect impacts: A tidal power project and its construction will inevitably affect existing communities around the Severn Estuary. It will also create new development pressures, such as demand for housing and transport links, which are not currently planned for. Unplanned and ad-hoc planning permissions around the landfall of a tidal energy project could result in a loss of landscape and habitat, and could be inappropriate or unsustainable in a range of other ways, such as adding to water and sewerage demand. These pressures should be fully assessed, and will need to be taken into account in local plans.
Recommendations of Atkins Analysis
17. In order to inform the previous feasibility study, and to inform our own response, the National Trust was one of a group of organisations that commissioned Atkins to undertake a critical review of the Technical Options Appraisal Report (Vols 1 & 2) from an engineering perspective.
18. We urge Committee to consider the full report attached at annex 1 as part of their evidence, in addition to the specific National Trust comments above.
December 2012