Section 3.3.60 of the Draft Overarching National Policy Statement for Energy (EN-1) reads: “subject to any legal requirements, the urgent need for CNP Infrastructure to achieving our energy objectives, together with the national security, economic, commercial, and net zero benefits, will in general outweigh any other residual impacts not capable of being addressed by application of the mitigation hierarchy” Section 4.1.3 reads: “Given the level and urgency of need for infrastructure of the types covered by the energy NSPs set out in part 3 of this NPS, the Secretary of State will start with a presumption in favour of granting consent to applications for energy NSIPs”. These proposals are in direct conflict with other policies in the Electricity Act and in National Policy Statements and risks causing untold and unnecessary harm to the environment and to communities. Electricity Act 1989 duties on National Grid include: • Section 38 and Schedule 9 – duty to have regard to the desirability of … conserving flora, fauna, geological or geophysical features of special interest, and or protecting building s and objects of architectural, historic or archaeological interest. Preservation of ecological resources (Schedule 9). • Shall do what he reasonably can to mitigate any effect on …any such flora, fauna, features, sites, buildings or objects. National Policy Statement EN-1 says, in paragraph 3.7.10 that: “…in most cases, there will be more than one technological approach by which it is possible to make such a connection or reinforce the network (for example, by overhead line or underground cable) and the costs and benefits of these alternatives should be properly considered as set out in EN-5 before any overhead line proposal is consented.” These proposals are therefore incompatible with, and contradictory, to other policies and legal requirements for the construction of transmission infrastructure. Further, the proposed wording is incompatible with the aims of the NSIPs action plan, because it will not deliver better, faster, fairer, greener and more resilient infrastructure and projects approved which rely upon this wording are likely to meet significant legal challenge. I object in the strongest possible terms to the proposed wording. ALL relevant matters should be weighed in the planning balance and the appropriate outcome driven by that balance. It is unacceptable to attempt to make such sweeping and damaging changes to policy. These sections would prevent appropriate and necessary challenge and serve only to ensure that bad proposals are rapidly approved. PRESUMPTION TO OVERHEAD LINES (OHL) AND PYLONS The Draft Overarching National Policy Statement for Energy (EN-5) includes presumptions that OHL and Pylons should be used to transmit electricity and goes to length in section 2.9 to set out that they will be acceptable in all but extremely rare circumstances. To date the majority of electricity in England has - broadly speaking - been generated by burning coal in the Midlands and North, transporting it north-south through pylons to the denser population areas in the south. In such circumstances OHL and Pylons were a natural starting point. The majority of generation was in the centre of our land mass and there was no real alternative to overhead line and pylons. However, in a future world where the significant proportion of our electricity will be generated offshore through wind power this no longer makes sense. It is self-evident that if the power is being generated offshore and not near to existing OHL, a presumption in favour of OHL to transmit it will be the wrong starting point! As demonstrated by ESO in their December 2020 paper the establishment of a coordinated offshore grid would be approximately £6Bn cheaper when the costs of all parties are summed than their 'counterfactual' example of radial connections to shore supported by onshore pylons. ESO sets out that a coordinated offshore grid results in less use of cable both offshore and onshore and thereby result in less damage in both settings, AND results in a cheaper and MORE RESILIENT grid. OHL’s are highly damaging to habitats and bird strikes into power lines are a major killer acknowledged in the NPS’s. OHL’s are less resilient in extreme weather than underground cables or sub-sea grids. OHL's cause significant damage to landscape, archeology and cultural heritage including the settings of AONB (even when the pylons are outside of the AONB), scheduled monuments and listed buildings. Forcing pylons upon communities without genuine alternatives is not fair. A contentious system in which communities are not presented with options, and in which the one option they are presented is driven by a faulty presumption that OHL and Pylons are the right answer, will be slower than a fair system with fully evidenced alternatives as communities will inevitably mount significant legal challenge. The presumption in favour of OHL's and Pylons is: (i) Outdated, and not fit for a world in which by 2050, according to National Grid ESO in 2020, the UK will need to have a total of 83 Gigawatts (GW) of offshore wind power connected to the grid. (ii) Un-necessary. The electricity is already offshore and is typically not required anywhere near the point at which it would be brought onshore to connect with OHL and Pylons (which do not themselves yet exist and which have no planning approval). As demonstrate by ESO there are better ways to bring the power to where it is needed. (iii) Harmful. It drives the design process at National Grid ensuring that they always commence from an overhead design without any other consideration and even when other options would be better. The assumption that each wind-farm will connect back to shore radially and that power will be transported over land by pylons leads to significant increases in cost, time to approve, time to build, increased damage to landscape, seascape, and cultural heritage. (iv) will drive delays as pylons and OHL do not readily achieve consent amongst the population due to the damage they cause. (v) Incoherent in policy terms, given the requirement also in NPS’s to look at alternatives and Electricity Act 1989 duties on National Grid. As you can see, a presumption in favour of OHL and Pylons will not lead to the best outcomes for anyone. National Grid ESO said, of this growth, “One of the challenges to delivering the ambition in the timescales required will be ensuring that the offshore and onshore transmission network enables this growth in a way that is efficient for consumers and takes account of the impacts on coastal communities and the environment.” I believe that to ensure better, faster, fairer, greener and more resilient transmission infrastructure, which is the goal of the NSIP’s Action Plan: - paragraph 2.11.13 of Draft EN-5 should be changed to read: 'a full range of options must be considered and presented to stakeholders, taking Treasury Green Book[3] principles into account, so that the optimum solution for consumers, communities and the environment is arrived at'. - other references to presumption in favour of OHL should be removed entirely. - a presumption in favour of coordination for offshore projects must be added. - finally, all NPS’s should insist upon compliance with Treasury Green Book guidance. As a separate matter, your hard copy questions includes question 7: “Draft EN5 includes a strong starting presumption for overhead lines for electricity networks developments outside nationally designated landscapes, which was consulted on in 2021. Do you agree?” This is however missing from the online response form. The outcome of the consultation is likely to be biased against those who reject the inclusion of the presumption in favour. As you can see from our response above, we very much reject this proposal. In order to achieve a fair and balanced outcome it must be acknowledged that the current consultation is faulty and it must be re-started.
Dear Sir/ Madam, Thank you for your email which has been received by the Planning Inspectorate. The proposed East Anglia Green Energy Enablement (GREEN) application is currently at the Pre-application stage of the Planning Act 2008 process. Further information about the process can be found at the following link to the National Infrastructure Planning website: [attachment 1]. The Planning Inspectorate is unable to consider representations about the merits of any application until it has been submitted and accepted for Examination. As the application has not yet been formally submitted to the Planning Inspectorate, your first point of contact should be the developer and we would encourage you to contact National Grid Electricity Transmission (NGET) directly: Email: [email protected] Telephone: 0800 151 0992 It is important that the developer is made aware of any comments at the Pre-application stage to enable them to consider the points raised before finalising their proposals and submitting the application. Additionally, any queries relating to national policy should be addressed to the Department for Energy Security and Net Zero, rather than the Planning Inspectorate. Should the application be accepted for Examination in due course, it will be possible to register as an Interested Party by submitting a Relevant Representation. This must be submitted on the ‘Registration and Relevant Representation form’ which will be made available on the project webpage of the National Infrastructure Planning website at the appropriate time. Further information about registering as an Interested Party can be found in the Planning Inspectorate’s ‘Advice Note 8.2: How to register to participate in an Examination’ which can be found here: [attachment 2]. You may also find it helpful to subscribe to receive email notifications for key events that occur after an application has been submitted to the Planning Inspectorate. Kind regards, The East Anglia GREEN Case Team
18 May 2023
Various enquirers
