Consultation: Electricity Infrastructure

Dave Windle

NEMT has replied to the UK Government consultation on Electricity Infrastructure Consenting. This is of considerable concern as the object of the exercise is to streamline planning for changes to Electricity Infrastructure that are needed to accommodate the move to green, fossil-free energy. However, the proposed streamlining will result in reduced public involvement in the planning process. The main driver for the changes appears to be the need to speed up the upgrading of the grid to accommodate electricity generated by the new wind farms, both onshore and offshore. If the grid is not upgraded, the cost of constraint payments to pay developers for electricity that can´t be sent to users will become excessive. Although aimed at grid upgrades, the proposals will affect electricity generation projects such as windfarms, both on and offshore.

Our summarised reply is set out below.

General Comments

• NEMT agrees with the need to speed up the planning process for Electricity Infrastructure, both to accelerate our transition to net zero and to avoid potentially large future capacity constraint payments. However, the current proposal reduces the quality and quantity of public consultation. This will end up alienating local communities, and triggering additional protest actions, spurious lawsuits, etc. In the end, the process will be slower. NEMT suggests that a better compromise is needed here.
• Greater clarity on possible options is needed. If a new transmission line is proposed, to what extent is the route fixed as part of a national Government mandate, and to what extent can it be rerouted, put underground, or diverted offshore? In the case of a proposed new wind farm, to what extent can objections refer to the limited capacity of a transmission line? The current system wastes a lot of public goodwill, campaigning for options that are never really on the table.
• These proposals are unlikely to speed up the end-to-end project planning process. They simply restrict the public´s right to be consulted and to appeal.

Specific Requirements

• EIAs should be required for all applications.
• We support the proposal to include all aspects of the project, e.g. generation and power export for a wind farm.
• Information on what alternatives were considered and how the chosen solution was arrived at should be made available to the public. People need to understand why their "back yard" has been chosen.
• Binding information needs to be provided on proposed financial benefits to the community, as this will be a key part of gaining community support. (A separate Government consultation is currently underway on appropriate levels of funding.)
• There needs to be at least two stages of public consultation; one considering wider issues, and a second stage when detailed points are being considered. This need not delay the overall process. The first stage will fit into the Pre-Application stage, and the second stage will fit into the Acceptance Stage because the design work can proceed once the wider details are agreed. This is standard engineering practice for larger projects.
• It would help all parties if as many document titles in planning applications as possible could be standardised. Much of the information supplied addresses standard points, and standard titles would help people navigate their way around the large quantity of documents normally supplied with such applications.
• The planning authority needs to be in control of the process. Responses to the pre-application document need to be sent to the planning authority and not just the applicant. They should then be posted on a publicly available website as used for conventional planning applications.
• Having spoken with objectors to the recent proposed Hill of Fare wind farm, we have become aware of perceived privacy issues. Adequate identity protection needs to be ensured.
• Limited funding needs to be made available for recognised community groups, e.g. community councils, to get professional assistance in preparing their cases.

Public Inquiries

We agree that the present public inquiry system takes too long. The added value of the planning KCs employed by applicants is questionable at the very least. However, the proposal to transfer this role to a single Examiner, with no public scrutiny, goes too far. No matter how well qualified this person is, there is a serious risk of the decision being seen as unfair and partial.

In addition, people need an opportunity to express their views in public.

Statutory Appeals and Judicial Proceedings

We do not agree with the proposals to reduce the time allowed for bringing an appeal once a decision has been announced. This erodes the ability of a community group to challenge a decision and gives no real schedule benefit. Once the decision is announced, the applicant can start work on the detailed design at very low cost, until the 3-month period for an appeal has finished.

Please let the webmaster know if there are problems with viewing these pages or with the links they contain.