opposing unnecessary, excessive
REVOLT Newsletter 319
Revolt news 31/01/2010 Print (pdf) Version
1. My response (APPENDIX A below, without its attachments) to the 2011 Energy NPSs (re-)consultation raises just three concerns: strategy, health and alternatives (underground and undersea). Lack of balance in the draft NPSs is a factor in all three concerns, where positions taken on strategy, on health, and on undergrounding, appear to reflect the official and industrial sources but not the range of academic research and practical experience. There does seem to be scope for further stakeholder engagement which might help to improve the balance on these issues.
2. The response raises some recommendations calling for
3. Graham Lamburn from Powerwatch attended the Suffolk CC National Symposium on 19 Jan, which had 77 people on its delegate list, and reports some summary points at APPENDIX B below. The delegate documents including the speakers' presentations have now been uploaded to the Suffolk County Council website and are available here.
4. National Grid and Scottish Power Transmission (SPT) have announced consultation on a new 400km subsea cable from Hunterston (Ayrshire) to Connah’s Quay near Liverpool, in line with strategic documents (news318). It will have capacity of around 2GW, about half of a typical 400kV double-circuit line, but welcome nevertheless. A press release of 26-1-11 is linked below but there seem to be no detailed documents yet. http://www.nationalgrid.com/uk/Media+Centre/PressReleases/2011/Subsea+26.01.11.htm
5. John Smith sends an update on EON’s buy out of his former home under their 132kV powerline which appeared to be in breach of ESQCR safety regulations. “Over the past few weeks there has been a lot of activity at both properties. No 39 is scaffolded all round … and we believe the place has been replastered and decorated. Local talk leads us to believe that EON are having the roof altered. A monopitch roof could be accomplished which would solve the clearance problem, although not a very attractive solution. They have demolished the chimney nearest to the conductors on our old property (No 41). This is one of the alternatives they suggested when we lived there. Again lights have been seen in the house and decorators have been busy. No 41 would not have frozen since our boiler had a freeze protection system …. It looks as if they are going to sell or rent and not demolish No 39.
6. Andrew Hope, of the mid-Wales group STOP, raises the point that EU Directive 97/11/EC requires consultation over impacts on other member states. “If therefore the end destination of an interconnector involves an onshore section then that section is strategic by definition and must be subject to an EIA that involves the other member state. The consensus may be that an onshore section is better designed in HVDC and that consensus must be subject to the public participation directive in the usual way.” Wider consideration of more and longer HVDC onshore connections could also allow economies of scale.
7. Another thought from Andrew Hope: “a strategic european approach may be able to make use of the social factor cost offset that has recently been used in the france / spain interconnector. ie everybody pays a bit extra for the common good and energy security”. Andrew also has his eye on developments in South-West Europe and in Iceland and how they may affect transmission in the UK.
8. Thanks to Andrew Hope for drawing to our attention the Nordic Transmission System Operators’ (TSOs) INTERNATIONAL CONFERENCE ON HIGH VOLTAGE TRANSMISSION AND THE VISUAL ENVIRONMENT held in Reykjavik on 16-17 September 2010. We are looking for proceedings in English (if anyone can help).
9. Parliament urges delay in ratifying NPSs and more power line undergrounding, says government website, courtesy of Michelle Lloyd of mid-Wales group STOP. http://www.planningportal.gov.uk/general/news/stories/2011/jan2011/27jan2011/270111_3
The Commons Energy and Climate Change Committee argued that ratification of the NPSs should be held up while other planning reforms are clarified and the Government decides on electricity market reform (EMR).
10. Stour Valley Underground (SVU) January newsletter is out today 31 Jan from David Holland, as lively and thought provoking as ever. Key topics are listed at APPENDIX C below. Especially worth viewing are the simple but effective maps of East Anglia showing what we want (subsea windfarm and Sizewell connections coming ashore via the Thames to areas of high demand) and what we don’t want (multiple overhead lines through East Anglia) – hear, hear! http://www.stourvalleyunderground.org.uk/ ***** *****
Response to DECC Energy re-consultation Jan 2011
from Professor Emeritus M J O’Carroll
1.1 I submitted a full proforma online response (herewith as Attachment A) in Feb 2010 to the first DECC consultation, making just two evidence-based points of concern (on strategy and on health), which the government response did not answer satisfactorily. The government response of October 2010 was in material error (as spelled out in section 3 below) in respect of the health concern as to the conclusions of the DH-based government advisory group SAGE (in which DECC and I participated). My two original and unanswered concerns are updated in sections 2 and 3 below with additional supporting material.
1.2 A third concern has arisen, regarding both process and content, from the exercise to assist the IPC and its planning process by commissioning an “independent” KEMA/IET review of relative costs of overhead lines and alternatives.
1.3 The three concerns are summarised in sections 2, 3 and 4 below, together with new recommendations in bold font. These short summaries are additional to the points and conclusions given in my response to the first consultation, which still stand and which I ask you to reconsider.
1.4 Further detail and comment can be found on www.revolt.co.uk in the frequent news issues. In particular the latest ten issues, numbers 309 to 318, all contain relevant comment on policy, strategic or local issues, with specific examples which illustrate some of the points of this submission.
2 CONCERN 1 - STRATEGY (applies mainly to EN-1 section 3.7)
2.1 I agree that major reinforcements of the electricity grid will be needed if the stated government targets are to be met. The number of new HV powerlines may be under-estimated in EN-1 3.7.6, since mooted proposals for wind generation in the far north of Scotland (Hebrides; Shetlands; Mainland; North Sea offshore) amounts to tens of GW of installed capacity. I have a quantified analysis based on stated assumptions, but do not forward it as so much depends on the assumptions.
2.2 There is a plethora of sources of UK and EU strategic analysis, of which the ENSG is only one, and moreover one from interested parties. Others include NG-SYS (noted in the draft NPS), NG-ODIS, HVDC North Seas Countries Offshore Grid Initiative, Crown Estate, EWEA and EWIS. There are substantial differences between them, so that a full and fair picture is obscured. A summary guide is given with comments (on some policy issues and local implications) in Attachment B herewith. It is important that a full and fair picture should be on the table, both in public consultations and in IPC/MIPU considerations, about any proposed powerline or substation which may prejudice or be prejudiced by wider future strategy.
2.3 The nub of this concern is the lack of a balanced strategy which takes account of all the impacts of overhead lines. Instead, a closed review of government and industry through ENSG considers potential delays and difficulties arising from public objection, rather than considering the impacts themselves and the substantive reasons for public concern in a balanced way. Two things are needed: stakeholder engagement in developing a strategy, and an acceptable strategy in itself.
2.4 Two recommendations on strategy
Recommendation 1: Infrastructure strategy should be developed through balanced stakeholder engagement taking account of all impacts including dis-amenity and precaution against possible evidence-based health risks.
Recommendation 2: A strategic national HVDC network should be planned and developed, with strategic rather than piecemeal positioning of lines and converter stations linking to the AC grid. The HVDC network should be mainly under-sea and under-ground, bearing in mind access for maintenance and repair.
3. CONCERN 2 – HEALTH (applies mainly to EN-5 section 2.10)
3.1 The government response to the first consultation, in paragraph 5.27, says: SAGE's own cost benefit analysis of the proposal did not support the high cost option of creating corridors around power lines on health grounds. That indicates a singular analysis by SAGE which was conclusive against the option. However SAGE had two cost-benefit analyses, based on two identified legitimate scientific views, one of which would not support that option and one of which could. SAGE acknowledged that the benefit of avoiding exposure could be of the order of a hundred times greater based on the second view. SAGE “did not recommend” the option, as distinct from “recommending against” it. SAGE could not agree. This is a material error and misunderstanding in the government response. Sections 5.4 and 5.5 of the SAGE report make the position clear. Granted, the government response to the SAGE report rejected the option, which was for a general or universal separation between homes and lines in new developments; rationally, that should not rule out separation or indeed undergrounding in some specific situations. Negation of a universal separation is not a universal prohibition of separation.
3.2 The re-draft EN-5 mentions SAGE but in effect takes the position that (as reflected in the “Route Map”), the only precautionary consideration is that of optimum phasing, regardless of exposure levels below the ICNIRP levels. This fails to reflect the views of SAGE, agreed by all sides, in favour of an “ALARA” policy of making exposures as low as reasonably achievable. It is important to distinguish between the following three situations which are all based on scientific evidence:
3.3 Bearing in mind the above distinctions, the ICNIRP standards (on which the EN-5 approach relies) are irrelevant to the rational and evidence-based public concerns about possible chronic health effects, as are the ESQCR safety standards. Attachment C herewith summarises the position.
3.4 Recommendation on health
Recommendation 3: Consistently with government policy that EMF health considerations alone do not justify a general separation of homes and powerlines in new developments, the NPS should recognise EMF exposure reduction on the ALARA principle as agreed by SAGE as a material consideration which may be taken in combination with other impacts and which in special situations may support alternatives to overhead lines or to certain routes.
4. CONCERN 3 - ALTERNATIVES (applies mainly to EN-1, 3.7 and EN-5, 2.8)
4.1 The draft EN-5 2.8.7 requires the IPC to weigh the reductions in visual intrusion against the impacts of undergrounding. As such, this paragraph is partial and incomplete. All the impacts and benefits of both options (overhead or underground) should be weighed cumulatively in the balance, in accordance with EU Directive 97/11/EC, including EMF exposure reduction and protection of amenity, for example.
4.2 Following the partiality of 2.8.7, the next paragraph 2.8.8 seems directed with an adversarial emphasis against undergrounding, while lacking a balanced statement of opposing factors. This paragraph should be amended along the lines of 2.8.7. Benign examples of undergrounding such as around Regent’s Park and on the Lackenby-Picton line in North Yorkshire should at least inform the drafting of EN-5. The idea of “swathes of sterilised land through the countryside”, perpetuated in the past, is very misleading and it is good that they are not repeated verbatim here. It should be made clear that the impact is generally temporary around the construction period.
4.3 While the KEMA/IET review is a welcome move in principle, in practice it has been hasty and inadequate in stakeholder consultation. It is important that it takes account of both government-industry reports and their professional rebuttals. The KEMA/IET review will be yet another review commissioned by interested parties to set alongside the several such reviews and rebuttals of recent years. Attachment D herewith comments on the KEMA/IET review and discusses a range of such reports which it should consider.
4.4 Recommendation on alternatives
The above recommendation 1 (national HVDC network) is also relevant here.
Recommendation 4: There should be a presumption, for planning and regulation purposes allowing the cost to be recovered through price, that a limited proportion of any transmission line project may be underground and/or undersea. For example, limits for the presumption may be 10% of length and 100% of equivalent overhead line costs, or some other figures. Such measures should be justified in terms of the choice of undergrounded section, and should consider all impacts (such as visual and EMF) cumulatively, but the presumption should mean that the burden of proof would be on why not rather than on why. The presumption of cost-recovery, within the stated limits, would be important and may help to speed up project decisions. Complete or partial undergrounding in excess of the presumption limits would still be possible, but would require positive justification with the burden of proof reversed.
LIST OF ATTACHMENTS
Attachment A Proforma submission to first consultation, Feb 2010
Attachment B A guide to sources and links for key UK strategy documents, version 5, Jan 2011
Attachment C Summary on health issues (as submitted to Suffolk National Symposium), Jan 2011
Attachment D Sources for UGC cost comparisons and related info, Jan 2011
APPENDIX B Summary points from the Suffolk National Symposium 19-1-11
Search the web