4. Update on generic issues
4.1 It has often been said that people would tolerate a line which was
seen to be necessary to bring the benefits of electricity to others. The claimed need for
this line is something very different. The question of need for this line has been vexed.
In the decision letter of 26.3.98, SoS concludes in 5.5 that the technical case for need
has been established. It is however based on a claimed security requirement "in
the light of … Teesside Power Ltd, exports from Scotland and expected future growth
in generation" while accepting that "a single circuit line would be
sufficient for immediately foreseeable needs" (5.2). The excessive and
speculative nature of the decision will weigh heavily with the Wilkinsons, were the
wayleave to be granted.
4.2 The security requirement at the core of the claimed need was
challenged by many objectors, and NGC admitted it had departed from the literal meaning of
the relevant standards. To the Wilkinsons this appears to be like cheating. The question
of meeting the requirements in the absence of the proposed line, for example by continued
derogation, was raised but not examined sufficiently. New evidence is now available in the
letter of 1.10.96 from OFFER (Appendix 1) which suggests the possibility of
continued derogation. It will be important to the Wilkinsons that such a possibility, at
least for the three-year duration of the moratorium on gas-fired power stations, is not
ignored.
4.3 The consent decision is also based on financial misinformation to
the inquiries resulting in unsound economic appraisal. This very serious and material
issue seems to have been treated with contempt by DTI. It transpires from OFFER’s
1996 Transmission Price Control Review firstly that the proposed line would cause an
increase in operating costs, not a decrease as the inquiries were led to accept, and
secondly that the proposal was not the "most economic option" as claimed
in 5.3 of the decision letter. Full details are given in Appendix 2 which was
submitted to Secretary of State in 1996, and was said to have been taken into account in
her decision in 1998. Her consideration is flawed. She acknowledges in 8.2 that the new
information "may reduce the economic benefit of the Development", a
grudging understatement of its effect of reversing the true assessment of options, but
goes on in 8.3 to accept "on the evidence the Company presented to Inquiry 2 that
the three options utilising the Stella-Harker line would still remain by far the most
expensive options". She therefore relies on the flawed evidence which the Company
gave while accepting that the new information could change the assessments. Without the
increased Scottish imports, which are contractually dependent on the new Yorkshire line,
the Stella-Harker options will be cheaper.
4.4 It follows further from Appendices 1 and 2 that, consequent
to the increased Scottish imports contractually dependent on the proposed line, the line
would result in increased constraint costs and increased grid developments elsewhere on
the system, in other words at new bottlenecks elsewhere throughout England. These
consequences have never been taken into account or costed in any of the proceedings so
far. They should properly be identified in the assessment of the project; this has not
been done.
4.5 The "tortuous route" argument perpetuated in 5.2 of the
decision letter of 26.3.98 reinforces the view that neither the inspectors nor the SoS
have understood the point: the security requirement covering the event of a double-circuit
outage means that any such route is simply a safety valve which based on past records
would hardly ever be used, and if ever used would be only for about one minute in five
years. The argument that such a route is uneconomic is plainly absurd, yet it has been
incompetently perpetuated since the original inquiries in 1992.
4.6 More recently the pattern of generation has materially changed, in
that for example
(a) the proposed Neptune power station is no longer
transmission-contracted;
(b) government policy has increased CHP targets to 10 GW which will
radically increase locally generated power and reduce the need for bulk long-distance
transmission, and a government report has suggested that targets of 15GW may be
economically viable;
(c) more cost-reflective regulation from 1997 will also reduce the need
for transmission;
(d) government policy on fuel sources and the moratorium on gas-fired
power stations will further reduce the need for this line.
Appendix 3 gives some background. Even if the decision were
regarded as sound in March 1998, the changing industrial pattern and government policy is
moving strongly to reduce the case for the line. NGC cannot be expected to reflect this
change sympathetically in its proposals, since the line would be, in effect, a free asset
paid for by consumers, with the added bonus of facilitating lucrative short term contracts
for intrinsically wasteful connection of power stations remote from net demand.
4.7 Given that opposition to the line principally challenges the need,
the Wilkinsons feel there has not been adequate consideration of alternatives other than
those put forward by NGC, in particular of single-circuit alternatives, possibly using the
proven French system of poles on the centre reservation of dual carriageways such as the
Parkway and A19.
4.8 Lack of confidence in both DTI for the proceedings and NGC for its
information weighs heavily in the impact the Wilkinsons would suffer were a wayleave to be
granted. First, the DTI proceedings: suggestions of "complicity" and comments of
"sham and shambles" were argued in my closing submission of 23.11.94 to the
second set of wayleave hearings conducted by Mr Walker. These were not noted in his
report, although he reported some of the factors under "The case for the
objectors", e.g. in 4.5 and 4.8. Appendix 2 gives reasons for lack of
confidence in the 1992 proceedings (sec.1), the 1994 wayleave hearings (sec.2), the 1995
inquiries (sec.3) and the unreliability of NGC’s evidence (secs. 5 and 9). Enclosures
2 and 3 were REV 210 dealing with wayleave misinformation and REV 301.21 with inducements
in detail. Other enclosures dealt with NGC’s financial misinformation.
Other factors are the hastily fragmented hearings, last minute increases in
inducements not to appear, late re-serving of most wayleave requests, changes in tower
heights, and errors of fact and of identity of grantors. Inspectors are appointed who are
said to be independent yet appear to be appointed and paid by the government. Hambleton DC formally objected to Mr Walker’s appointment in 1995
claiming the inspector should be unconnected with the previous proceedings. Their
objection was rejected by DTI. The Bruntons’ first wayleave
hearing was abortive due to a mistake by NGC about gas pipes, so they had to go to the
expense of a second hearing for an adjusted line position, at extra expense for which NGC
resisted compensation. An oversail of Mr Osborne’s land at Crosby has been omitted
and only brought to light this summer, when NGC has made a new request for the wayleave.
Now DTI has blundered over the Wilkinsons. The sham and shambles continues.
4.9 Appendix 4 summarises why the Wilkinsons disagree with
Secretary of State’s decision.
4.10 The impact on the Wilkinsons is exacerbated by reports of
incidents of NGC flouting proper procedures and taking an aggressive approach to entry on
to land (Appendix 5).
