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Energy: National Policy Statements

My Lords, at the outset, I declare an interest on three grounds. First, I am vice-president of the Campaign for National Parks. Secondly, I am president of Friends of the Lake District, which represents CPRE in Cumbria. Thirdly, I am a resident of the national park in Cumbria. None of these are remunerated—not even with expenses—but all of them are very real commitments on my part. I could not agree more with the Government on the urgency of low carbon forms of energy and the benefit of having national planning strategies. I am very glad that in the document before us there are indeed references to national parks, the broads and areas of outstanding natural beauty. In other words, I support the Government’s low-carbon transition plan. I am confident that my noble friend will agree that while, therefore, minimising carbon emissions is an essential priority, of equal priority is enhancing people’s quality of life, protecting biodiversity and aqua-system resilience, landscape beauty, diversity and our sense of identity, and conserving our precious and declining natural resources. My noble friend is a particularly civilised and sensitive man. I read with great joy his diary of a visit to Cumbria—probably in the House Magazine. My heart leapt with joy when he referred to how, as the train crossed the mountains of Cumbria, he was full of the glories and richness of life. I know that he feels these things as I do. I have put it to him in private conversation—I am sure that he will not mind my mentioning this—that he really has a huge challenge, which has two objectives. One is, of course, to make sure that the nation’s energy needs are met, but the other is to leave an inheritance of which we can all be proud. He would never be happy if he went down in history as a man who met the energy needs but wrecked the environment; I am sure that he will not prove to be that. The language of the document before us slightly concerns me. It seems to be a pretty good model of a values-free government publication. I do not think that I am being harsh, but its language is a sort of cold management-speak. Imagination and vision are not the hallmarks of this document. I therefore put it to my noble friend that while the energy priorities are beyond doubt, the other aspects to which I have been referring need to be more strongly worded. A tone needs to be set that these are not things which we shall have to accommodate, but to which we are deeply committed. I am also a little concerned lest the emphasis in this NPS on energy will work against the principle of increasing public engagement with and understanding of major decisions, and the enhancement of the whole nature of citizenship in a way that enables people to feel that they can play a meaningful and real part in developing the solutions we all need to find as a society. Our nationally and internationally important landscapes are very special places for the nation and essential to the public interest. The new draft circular for the English national parks and the broads demonstrates well their holistic worth to society, be it for health, exercise or seeing the local demonstration of sustainable lifestyle choices. Yet the western fringes of the Lake District National Park face potential destruction from a series of separate "nationally significant infrastructure facilities" that the NPS says can, in themselves, override the protection afforded to national parks in PPS7. The potential is for three nuclear build sites—only one closely related to Sellafield—with all the associated infrastructure, such as roads, a major upgraded National Grid transmission system, with conspicuous overhead lines all over the place, tidal energy bridges across Morecambe Bay and the Solway Firth, together with a plethora of existing and proposed off and onshore major and large-scale wind farms. That is not to mention nuclear waste being stored above ground for 160 years, with all its attendant management problems of safety and security, to which the right reverend Prelate referred rather tellingly. For a start, I should put on the record my view that overhead lines in national parks and areas of outstanding beauty should be a no-go issue. Cumbria, indeed, can meet its own domestic needs for 500,000 households and contribute toward meeting regional planning targets, but just how much energy does it have to provide for the nation in the context of protecting those exceptional landscapes, including the Lake District jewel and its generally high environmental quality? The overarching NPS, and accompanying technology-specific NPSs, cannot reflect the totality of the cumulative impact from that potential development. This must be done in the local context, but as set out in the draft statement, that local impact appears to be almost automatically out-trumped by the national energy need. In weighing need and impact, the decision-making of the IPC, and of local authorities through their local impact reports, must be able to assess the principle of major individual projects that affect national parks, together with the deployment of alternative options or sites in the context of other potential proposals. The draft NPS is based on the premise that there is a considerable need for new investment over the coming years and that any new provision is therefore needed. As part of this approach, the market is left to decide where proposals for new electricity generating infrastructure will come forward. For example, the proposed list of sites for nuclear power stations in EN-6 has been identified by promoters on the basis of market considerations, rather than through a rigorous site selection process based on sustainability criteria. I hope that the Government will consider very carefully representations by CPRE, CNP and other agencies that play such a vital part as guardians of the quality of British life, and which I find compelling. Those agencies are surely right to argue that the Government should not prescribe what development will be provided when the absence of any priorities or steer for where infrastructure might be most desirable, acceptable and necessary is unhelpful. This is unlikely to result in the more strategic approach to which the Government aspire. Instead, objectors will continue to resist developments on a case-by-case basis. The need case will not be accepted by the public. Draft EN-1 appears to say that whatever promoters say is necessary is necessary, regardless of the impacts that that might generate. The NPSs effectively promote the unconstrained development of energy schemes anywhere on the basis that their need is established and unquestionable. This creates an over-riding and, in my view, dubious presumption in favour of any such development. What is more, reliance on a market-led approach is flawed because it does not properly take into account how the presumed need can be achieved through alternative means, such as energy conservation measures or through demand management. Only EN-6, which deals with nuclear matters, contains any form of spatial referencing. While it may not be necessary for detailed proposals to be included in every NPS, it would be valuable to have greater spatial guidance and clear identification of priority areas for new energy infrastructure indicating, for example, sensitive areas to be protected. This would assess the IPC’s decision-making and increase certainty. In paragraph 4.1.2 and elsewhere, weight is attached to development plans and regional guidance. The draft NPSs do not individually or collectively give sufficient weight to the relevance of the development plan, the regional spatial strategy and the local development framework to the IPC. This is particularly important for Wales and specific guidance on energy, including TAN8, and the renewable energy route map, as well as the Wales spatial plan and Panning Policy Wales. Much more clarity is required on whether the national policy statements relate solely to nationally significant proposals and to what extent they are a material planning consideration for proposals under that threshold. There is an interesting reference to heritage assets in paragraph 4.23.14. I wonder why similar guidance principles are not included in this section on landscape and visual impact. In paragraphs 4.24.6 and 4.24.8, reference is made to assessing nationally significant infrastructure projects in national parks, the broads and AONBs. The guidance in the draft NPS for assessing projects in these unique places really needs to be redrafted so that it properly reflects the rigorous examination required for such projects and the tests that must be satisfied before such projects can be considered acceptable. Exceptional circumstances and public interest must both be demonstrated. The guidance in paragraph 4.24.7 appears to be completely at odds with current government policy for assessing major development proposals within national parks, as set out in paragraph 22 of planning policy statement 7. The draft NPS attempts to define exceptional circumstances as those where development can be demonstrated to be in the public interests. This is in contrast to existing government policy, which is that both exceptional circumstances and public interest must be demonstrated—and the two are after all not always necessarily equivalent—for a major development proposal to be considered acceptable. Footnote 68 also changes existing government policy, as it attempts to redefine national considerations as including the contribution of the infrastructure to the regional economy. Nor is there any reference to the requirement for such proposals to be subject to the most rigorous examination. When taken together, the changes constitute a significant onslaught on a key government policy, the principles of which have remained unsullied throughout the lifetime of several successive Governments. The reference to the regional economy in footnote 68 could be deleted. National parks are designated for the nation’s benefit and because of their national significance. The suggestion that a contribution to a regional economy is necessarily a national consideration is highly questionable. I urge my noble friend to ensure that this is given careful thought. By contrast, the NPS contains a welcome recognition that for developments outside nationally designated landscapes, the potential impact on the landscape should be taken into account by the IPC and the aim should be to avoid compromising the objectives of designation. Paragraph 4.4 refers to alternatives. The principle in effect that alternatives to proposals should in some circumstances not be considered smacks to me of the characteristics of a control economy, with all its pitfalls and dangers. The need to make a rigorous assessment of alternatives seems to me to be a fundamental principle that underpins the promotion of sustainable development and the strategic environmental assessment process. Given that it is the role of the applicant to undertake a thorough assessment of all alternatives, it is difficult to accept the proposition in the final bullet of paragraph 4.4.3 that third parties should be responsible for assessing any alternatives that they put forward. This is, frankly, likely to be unrealistic for members of the public or smaller voluntary groups. I conclude with a reference to paragraph 4.9 and the grid connections. I see that the paragraph requires any application to the IPC to include information on how the generating station is to be connected to the grid and whether any particular environmental issues are likely to arise from that connection. This is good. However, does my noble friend not agree that it is essential that proposals for generating stations and associated proposals for grid connection should be submitted to the IPC as a single application? If that is not possible, surely separate applications must be submitted in tandem to the IPC so that their environmental impacts can be considered at the same time, and any combination of effects assessed. This is not the first occasion on which I have drawn the attention of the House to what happened in the 19th century industrial revolution. At the Proms and elsewhere we sing with passion of the "dark satanic mills" but with hindsight it need not have happened; it could have been done in a much more civilised way. Have we learnt or, through high technology and all its paraphernalia and infrastructure, are we about to make the same mistake again? Pray God not. To ensure that the priority of meeting energy needs is not allowed, in any way, to impair or rape our rich, rural country inheritance, I cannot think of a better champion than my noble friend. I urge him to accept the challenge.