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Draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)

My Lords, I will concentrate on the transport infrastructure, particularly during the construction phase of the many different types of energy creation that we are considering today. My comments apply generally across all the NPSs, but I refer in particular to paragraph 2.2.4 on EN-2, which refers back to EN-1. I am sorry that I could not participate in the debate on EN-1 when we considered it, but it applies to all generation and to the Severn barrage, about which the noble Baroness, Lady Young, has just spoken. I declare an interest as chairman of the Rail Freight Group and as a harbour commissioner of the port of Fowey in Cornwall. My most recent experience of transport during the construction of any of these pieces of equipment or generation relates to Crossrail and the London Olympics, for which the transport of construction materials both in and out has mostly been by road. There could have been much more water and rail transport, and this mode of transport compares pretty unfavourably with the sustainability policies that are now all over the place in government policies. The Olympics could have saved 800,000 lorry journeys around the site in an area in which the air pollution, as I said in a recent debate, is already over the Government’s limits. I hope my noble friend will take into account the fact that rail or water transport is probably at least 70 per cent more sustainable in CO2 terms than road transport. I also hope he will take into account the fact that people do not actually like heavy lorries trundling down unsuitable roads; this comes out in all the documents. I have been studying one of the projects that are being developed, the nuclear power stations at Oldbury and at Hinckley Point, and an opposition group has already started up whose main concern is lorries going through unsuitable sites. The NPSs should do a lot to strengthen this area. The noble Baroness, Lady Young, quite rightly pointed out that all these stations and the switchgear need to be clear of flood plains. The Oldbury site could be on a flood plain if the River Severn floods, so the plan is to import about 10 million tonnes of field from somewhere to raise the whole site. I calculated that that would require roughly 500,000 lorry journeys over two years. The roads around there are quite awful and there is no railway within about 10 miles. You could build one, but what is the point when you are next to the river? One would hope that the contractors, the designers and the Government would go for sea transport, but I can see nothing in any of these documents that encourages or requires it. There is an opportunity, so far missed, to put in these documents the need to have sustainable transport, because they do not go much further than the status quo, rather than set out future policies. I do not know whether I am right—perhaps my noble friend can help me—but it is almost as if the Government believe that the excellent plans here for sustainable energy generation will solve the whole carbon problem in this country. However, my noble friend will be very aware that transport is, I think, the only sector where carbon emissions are forecast to increase. This is not doing much to reduce it. The NPSs, in the parts that I shall come to, should include a presumption of sustainability as regards using water or rail transport during the construction phase. The proposals are not bad as regards some of the operation phases, but during the construction phase sustainability tends to be forgotten. I turn to some of the specifics. I shall begin with EN-1 and return to EN-2. Ministers have said many times that the policies which will come from these draft statements will also be applied to smaller planning applications which come below the limit for NPS and IPC consideration. I hope that that will apply to anything that we are talking about today—in particular to some of the points that I have been making—but it would be good to have my noble friend’s confirmation. Paragraph 4.28.8 of EN-1 states: ""Water-borne or rail transport is preferred over road transport, where cost-effective"." I ask my noble friend how the IPC will calculate the cost-effectiveness, and whether it will take into account the carbon and other benefits—possibly in the way that the Department of Transport has used NATA methodology, which, for those who are not familiar with it, is a new approach to transport appraisals. It is important to know how the calculation will take place. Paragraph 4.28.3 raises an important issue for when possible multi-user transport infrastructure projects are proposed. The Government will need to ensure that other users will be protected if the scheme does not proceed because it cannot obtain permission to go ahead. As regards the mitigation measures provided in 4.28.6, it could be inferred that demand management of road traffic is a substitute for providing a bit of investment in rail or water facilities. I am sure that that will be how some developers will wriggle out of their commitments. It would be good if that provision were to be strengthened a little. Paragraph 4.28.9 states: ""The IPC may attach conditions"." It would be very nice if the IPC were to be required to attach conditions such as the use of rail or water, and set targets for the modal share. It is no good just doing it for the modal share of all material coming in or going out. The Olympics did extremely well on bringing in aggregate and other bulk construction materials by rail, and a bit by water, but they did not do so well when they were chucking polluted soil to Teesport by road when there is a rail terminal on the site and they have done appallingly badly with any other material. That compares with what BAA did regarding Terminal 5, where it organised its procurement properly. It made a great difference to the roads around Terminal 5 to have so much equipment coming in. I am talking about any kind of material that you can get on a train. I do not think you could get big offshore wind generator blades on a train; it is quite difficult to take them by road. There is an awful lot that you can transport that way if you try, though, and some targets for that would be important. I turn to EN-2, which is where it all starts. I worry about paragraph 2.2.4, which talks about the transport infrastructure. I have a horrible feeling that the process put down here will be used by the developer as a way of wriggling out of any commitment to use water or rail. Those were the main issues that I had with these policy statements on the transport infrastructure. The same comments apply to ports and to other similar areas that we have not spoken about, which I do not want to cover today. It is important that these policy statements—which I hope will last for many years, as there are many good things in them—should reflect the latest government policies on sustainability and particularly put requirements on deliveries, spoil removal from sites and so on during construction. That applies to maritime as well, because that area is just as important once the thing is up and running. I heard a comment yesterday from a cement manufacturer who has changed the transport of his company’s cement from road to rail. I managed to work out the calculation while the man was talking. As noble Lords may know, for every tonne of cement manufactured you consume a tonne of carbon, which is quite a surprising amount of carbon. If you are moving it by rail rather than road, you remove about 25 per cent of that carbon.