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Revised Draft Overarching National Policy Statement for Energy (EN-1)

My Lords, I declare an interest as an honorary officer of both the Friends of the Lake District, which represents CPRE in Cumbria, and the Campaign for National Parks. I was struck by what my noble friend Lord Giddens said about the urgency of climate change. I find myself completely in harmony with him, although there have been moments in Cumbria in the past few weeks when I have had to hang on to that conviction. However, it remains absolutely firm. It seems that this statement again brings home to us the question of what we are trying to achieve. There is a danger that our preoccupations with energy and energy policy become an end in themselves, which they are not. They are about how we get a society worth having. If we are to take that seriously, it is not an appendix to our considerations; it is central to our considerations that we take responsibility for stewardship of our aesthetic, environmental and landscape inheritance, which is envied by the world. It would be easy, under the pressures that exist, to repeat the mistakes of the first Industrial Revolution. With hindsight we can see that they were mistakes, but surely we have a capacity to learn as a society from the faults of our predecessors. It was not necessary to do all that was done in the way that it was done, raping some of the richest, most important inheritance in our countryside and landscape across the nation. There are those aesthetic considerations but there are also social challenges. How do we avoid a situation in which the weight of what is being done falls on those who are already relatively socially disadvantaged or less articulate? How do we avoid the ““not in my backyard”” syndrome, where those who do not have the same influence end up with a disproportionate amount of what has to be done on their doorstep? All this has to be put together, which is why a national statement has the potential to be so important. I must confess to some disappointment about the draft that is before us. In what I have just talked about, the guidance on spatial issues is inadequate. There is room for much more detailed spelling out of criteria. Quite apart from the considerations that I have just mentioned, without more detailed criteria we are creating greater uncertainty for planners and public alike. Potentially, all parts of the countryside are up for grabs as the policy goes forward. This will lead to great public anxiety and pressure that, however much the Government want to speed up the process, will in the end find ways of delaying it. If there were more information available and more specificity on these issues, it would speed up the process in the way that the Government would like. All this is brought out rather well by CPRE. It gives a specific example in an interesting brief that has been prepared. Underlining that it is not a theoretical concern, CPRE spells out that, "““experience of pre-application consultation for the substation required to connect the Triton Knoll offshore wind farm to the national grid highlights the risk of the current approach. The location of the substation is subject to consultation, but the fact that all proposed sites for the substation are approximately 40km from the nearest suitable 400kV overhead lines is not considered. Indeed, the required overhead lines to connect the substation are entirely outside of the consultation, and risk not being considered at all by the Infrastructure Planning Commission or a future Major Infrastructure Unit of the Planning Inspectorate””." There is an apparent underlying assumption that there is an almost unlimited need for new energy infrastructure, but how much examination has there been of what has already been consented to? What are the implications for need and what we may have to do in the future of what has already been consented to? This is a missed opportunity to provide for effective integration of different planning needs, to examine reasonable alternatives or to complete a convincing appraisal of sustainability. I referred earlier to what my noble friend Lord Giddens said about the urgency of climate change. I endorsed that view and said that we faced a challenge. The challenge is probably of greater significance in some ways for the history of the species than the Second World War. What strikes me in any reading of the history of the Second World War, when we faced that huge challenge in which we had to succeed, is how much work was going on at that very time into the quality of society that we wanted when the war was won and what was necessary to ensure it. Are we in danger now, in our very materialist age, of getting so preoccupied with the means that we are not facing up to the challenges that were faced up to by that great Government from 1940 to 1945? The statements are a missed opportunity, but there are other aspects, too. The protection of areas of outstanding natural beauty, to which the Minister referred in his introduction, and national parks is, I fear, weakened in the revised drafts. One can identify this weakening by looking at the issue of the national grid and the Holford principles. Perhaps I could be forgiven for drawing in this matter again on the wisdom—there is a lot of wisdom and experience there—of CPRE. The majority of 1,100 public responses to questions on electricity transmission policies in the first drafts of the NPSs, which was almost a third of the 3,000 responses received to the consultation on all six NPSs as a whole, called for stronger policies to control the visual impact of overhead lines. That is a pretty substantial indication of public feeling and what the public are looking for. Disturbingly, however, the second draft of the NPS on electricity networks proposes to weaken the standing of the Holford rules. The original draft stated that decision makers should recognise that the rules should form the basis for the approach to routing new overhead lines, and applicants should be expected to follow them where possible. This latest draft says only that decision-makers should bear the rules in mind. This would mean a significant weakening of the rules. It is likely to mean that there will be no requirement on either electricity companies to demonstrate that they have sought to avoid damaging impacts to important areas of landscape or on the decision maker to base its evaluation of a proposed overhead transmission line scheme on whether the Holford rules have been met. Nor is there any expectation that the mitigation measures suggested in paragraph 2.8.9 of EN-5 should be carried out for schemes where one or more of the Holford rules are not met. The effect of this could well be seriously to weaken the protection of the countryside from unnecessary and intrusive energy infrastructure. Of course, since the NPS was drafted, significant policy changes have occurred, the most notable of which is the review announced by National Grid on 15 December of its policy on undergrounding electricity lines. This review comes in the context of a review of the costs of undergrounding led by the Institution of Engineering and Technology and KEMA. Their estimate of costs appears to be much lower than the inflated figures cited in the previous draft NPSs. In the light of these reviews and of the scale of proposed new electricity transmission infrastructure, will the Minister not agree that the Holford rules should surely continue to form the basis of planning for new overhead lines, and that the IPC should be empowered to require underground or undersea transmission in areas which are environmentally sensitive? Before I conclude, I wish to deal, if I may, with what have been described as ““minor changes”” to the new drafting. After quite a number of years in politics, I am always very cautious about minor changes in drafting, because they sometimes have far more implications than are recognised. I suggest that the public have not been alerted at all well to the implications of some of the so-called minor changes and their—I shall be generous—unintended consequences, although there is always the question, which, of course, I would never associate myself with, as to whether the consequences really are unintended. I shall give examples. Paragraphs in section 5.8 of EN-1, on the historic environment, almost exactly repeat existing protections in PPS5, except that they remove references to non-designated areas. In particular, paragraphs 5.8.12 and 5.8.17 add the word ““designated”” to existing language in PPS5, thereby weakening protection for non-designated heritage assets, such as the buried remains of Roman Winchester. According to English Heritage, these are of at least equivalent importance to that of many places that are designated. To give a sense of scale, less than 15 per cent of historic buildings on farms are nationally designated. Paragraph 5.9.9 of EN-1, on visual and landscape impacts, repeats the new contribution-to-the-regional-economy criterion which first appeared in the previous draft EN-1. This is a major departure from existing protections for nationally designated areas and significantly reduces their protection. Paragraph 5.12.8 identifies developer contributions as a material consideration for planning decisions. It is right to consider these benefits through the planning process. However, the NPS should specify that contributions must relate to the purpose of the project. For example, community benefits for energy projects should contribute to local energy saving or microgeneration. I feel very sad. I have talked about the thinking that went on during the war about the kind of Britain that we wanted to have when it was won. Paragraph 5.10.12 of EN-1 advises applicants on ways in which to circumvent green belt protection. That is deplorable. On Thursday, nuclear policy is to be discussed and this is therefore not the time to do so. However, there is a close interrelationship. Apart from all the other issues that I have mentioned—aesthetic, environmental and the rest—there are of course geological considerations. This was recently brought home tellingly by the earthquake in Cumbria. I raised this with the Minister in a Written Question and I am grateful for his full and helpful reply, which noble Lords can read for themselves in Hansard. In that reply, he says: "““Vibrations associated with earthquakes experienced in the UK will not significantly affect a repository at depth, but any potential for changes to the rock mass containing a GDF must be thoroughly investigated””. —[Official Report, 10/1/11; col. WA375.]" We are talking about hundreds of years ahead. I wonder whether some of our successors may look very closely at that confident prediction that vibrations associated with earthquakes experienced in the UK will not significantly affect a repository at depth. It does not sound to me like quite the careful drafting that there should be on a matter of this significance.