Memorandum by Natural England
EXECUTIVE SUMMARY
— Natural England recognises that climate
change represents the most serious long term threat to the natural
environment. We believe that there is an urgent need to reduce
greenhouse gas pollution if we are to avoid potentially catastrophic
impacts on the natural environment. A particular challenge is
the necessity to move towards becoming a low carbon economy, as
this will entail the need to develop clean energy supplies, whilst
ensuring that the natural environment is not irreversibly damaged
by such developments.
— We therefore support Government's
ambitions for increased renewable energy generation. In pursuing
the European Union's 2020 renewable energy target, we would stress
that the full impact on the natural environment must be considered
alongside the wider contribution towards reducing greenhouse gas
emissions.
— There will be different impacts on
the natural environment from different options available to deliver
on the renewable energy target. That is why Natural England is
calling for the Government to undertake a strategic assessment
of the relative environmental impact of different renewable and
clean energy development options, for the United Kingdom. We believe
that that this comprehensive assessment will inform better long
term policy making and provide greater certainty for investors
and developers.
— The current evidence base available
to inform decisions about sustainable energy developments is largely
based on predictions of the immediate impacts of any development
on the existing natural environment. This evidence base is developing
as the deployment of sustainable energy technologies proceeds
and the actual impacts are monitored. The evidence base around
the cumulative impacts of sustainable energy infrastructure in
particular, needs significant development. There is also a need
to expand this evidence base to also consider how the natural
environment is likely to change in the face of climate change.
INTRODUCTION
1. Natural England is a statutory body created
in 2006 under the Natural Environment and Rural Communities Act
by bringing together English Nature and parts of the Rural Development
Service and the Countryside Agency. Natural England has been charged
with the responsibility to ensure that England's unique natural
environment, including its flora, fauna, land and seascapes, geology
and soils are protected and improved.
2. Natural England's purpose, as outlined
in the Act, is to ensure that the natural environment is conserved,
enhanced and managed for the benefit of present and future generations,
thereby contributing to sustainable development.
RESPONSES TO
SPECIFIC QUESTIONS
Question 1: How do and should renewables fit
into Britain's overall energy policy and how does it compare with
other countries?
3. Natural England believes that there is
an urgent need to put in place climate change mitigation measures.
We therefore support the uptake of renewable energy generation
for electricity, heat, cooling and transport in the UK, particularly
sustainable energy developments which minimise impact on the natural
environment and optimise their contribution to the reduction in
greenhouse gas pollution.
4. We believe that it is essential that
the Government undertakes a strategic assessment of the options
for delivering renewable energy targets, and their direct and
indirect impacts on the natural environment. This should be coherent
with the Government's work on a land use strategy, and be undertaken
before any renewable energy policies are put in place. This will
avoid developing renewables in inappropriate places where there
could be adverse effects on the natural environment and in doing
so help to streamline the onshore and offshore consenting process.
Question 2: What are the barriers to greater
deployment of renewable energy? Are there technical limits to
the amount of renewable energy that the UK can absorb?
5. Natural England is aware, through its
own role as a statutory adviser on most renewable energy developments,
that delays in the on and offshore renewables consenting process
can be caused by a lack of information on the environmental impacts
of renewable energy technologies and energy cropping. In order
to avoid such hold ups, it is crucial that all the environmental
implications of renewable energy options are assessed at an early
stage in the development process.
6. We believe that the potential cumulative
and in combination impacts from competing pressures on land and
sea are one of the largest barriers facing large scale development
generally. Renewable energy development in the UK must be strategically
assessed in the context of its cumulative impacts on the natural
environment.
7. The current evidence base available to
inform both on and offshore decisions about renewable energy developments
is largely based on predictions of the immediate impacts of any
development on the existing natural environment. We note that
there is large variation in the environmental impacts, depending
on the location and the risk of cumulative impacts and these must
be taken into consideration by taking a more strategic approach
to environmental assessment of the renewable energy options. The
evidence gathered from the current piecemeal approach to energy
development is inadequate to address this.
8. Government also needs to take full account
of the entire environmental and social costs and benefits across
the full life cycle of renewable energy generation (including
crop production, infrastructure manufacture, generation, transport,
transmission and end-use) when appraising alternative options
for renewables.
9. Natural England is currently developing
guidance and spatial locational mapping for both onshore wind
and energy crops, to focus development and cropping towards those
areas that we believe are more appropriate. We are aiming to identify
broad areas of search for larger scale onshore wind energy infrastructure
and crops for energy production.
10. Natural England will provide its advice
on the implications of any proposed sustainable energy infrastructure
development based on our statutory functions and include an assessment
of:
— the impact of the infrastructure
on the existing features of the natural environment;
— the changes to the existing features
of the natural environment that will occur as a result of climate
change which is already locked in;
— the potential for the infrastructure
development to contribute to improving the resilience of the natural
environment to further climate change; and
— The contribution of the infrastructure
to reducing greenhouse gas pollution.
Question 3: Are there likely to be technological
advances that would make renewable energy cheaper and viable without
Government support in the future? Should, and how could, policy
be designed to promote such technological advances?
11. Government policy should promote technologies
with minimal adverse impacts on the natural environment and that
demonstrate significant greenhouse gas savings.
12. We therefore stress that all renewable
strategies and policies should be designed so as to include a
strategic environmental assessment and cumulative impact assessment
for all emerging and new technologies, with a full carbon life
cycle analysis of the development and ancillary infrastructure.
Question 6: How do the external costs of renewable
generation of electricity—such as concerns in many affected
rural areas that wind farms and extra pylons spoil areas of natural
beauty—compare with those of fossil fuels and nuclear power?
How should these be measured and compared? Is the planning system
striking the right balance between all the different considerations?
13. We believe there is a need to weigh
up the environmental impacts of renewable energy generation against
the longer term environmental benefits of mitigating climate change.
This requires an assessment of the impact of renewable energy
infrastructure on current features of the environment and the
contribution that it might make to reducing greenhouse gas emissions.
Such assessments also need to factor in the potential changes
to the environment as a result of climate change and to assess
how the development might contribute to enhancing the resilience
of the natural environment to climate change.
14. Without a strategic assessment of all
the available options in the energy mix, taking into account the
cumulative impacts in the context of climate change, the external
costs of negative impacts on the natural environment cannot be
fully assessed.
Question 8: How do the costs and benefits
of renewable electricity generation compare to renewables in the
other key forms of energy consumption—transport and heating?
15. Natural England believes that an increase
in renewables in each of the energy generation sectors will be
needed to meet the Government's climate change and renewable energy
targets. Energy of all types must be sustainably produced, distributed
and used and have taken into consideration all the environmental
benefits and costs through relevant strategic assessments and
environmental impact assessments.
Question 11: What are the costs and benefits
of the present generation of biofuels? Will there be a second
generation of biofuels and, if so, what are the estimated costs?
What are, or are likely to be, the carbon emission impacts of
first and second generation biofuels, and what are the other relevant
environmental effects?
16. Natural England believes the sustainable
production of bioenergy for both electricity, heat and transport
fuels could form an integral part of the Government's renewable
energy strategy and contribute to reducing greenhouse gas emissions.
An increase in first generation biofuels production and use, however,
has the potential to create sizeable direct and indirect environmental
costs associated with increased crop production, particularly
overseas. We urge that robust sustainability criteria and reporting
measures should be implemented with appropriate targets as swiftly
as possible. It is imperative that these are in place before an
increase in the production and use of biofuels is encouraged.
17. Second generation biofuels will vary
in their cost and benefits depending on the feedstock used and
technology implemented. Further support is needed in this area
to encourage new and emerging low or zero carbon technologies
which have minimal or no adverse impacts on the natural environment.
17 June 2008
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