Environment and Sustainability Committee
E&S(4)-02-12 paper 2
Inquiry into Energy Policy and Planning in Wales – Evidence from RSPB Cymru
Evidence from the RSPB to the Environment & Sustainability Committee
Inquiry into Energy Policy and Planning in Wales
September 2011
The RSPB is Europe’s largest wildlife charity, with over one
million members, over 51,000 of them living in Wales. The Society
manages one of the largest conservation estates in the UK, covering
more than 140,000 hectares; 16,000 of these in Wales. The RSPB also
works with a range of organisations, businesses and landowners to
bring about habitat improvements for species of conservation
concern. We work to protect and enhance habitats such as upland and
lowland farmland, heather moorland, coastal heath, wet grassland,
estuaries and reedbeds, and our reserves help to protect rare and
threatened wildlife.
The RSPB welcomes the opportunity to submit evidence to this
important inquiry into Energy Policy and Planning in Wales. In this
response we have highlighted the key areas of policy interest for
the RSPB in Wales. Over the last 10 years, in spite of government
commitments, Welsh wildlife has continued to decline. Global
climate change is compounding the long-standing threats to the
natural world and putting ecosystems under increasing pressure.
This paper reflects the position that the RSPB supports a mix of
renewables and a move away from dependence on fossil fuels. This
response highlights the importance of spatial frameworks to support
the sustainable development of renewables whilst protecting
Wales’ important wildlife. The RSPB strongly supports Wales
and UK’s greenhouse gas reduction targets, and recognises the
critical role that renewable energy will play in delivering them as
part of a wider package that prioritises energy
savings.
1. Introduction
1.1.
Climate
change is already affecting birds and wildlife in the UK and
globally, and it threatens to drive future biodiversity loss unless
urgent action is taken to reduce emissions and keep the world
within ‘safe’ levels of climate change[1].
One study published in the journal Nature indicates that
climate change could cause up to 35% of species to be committed to
extinction by 2050[2].
The RSPB therefore strongly supports the Welsh and UK
governments’ greenhouse gas reduction targets.
1.2.
The Welsh
Government’s target to reduce emissions by 3% per annum
depends on action to reduce energy consumption from the burning of
fossil fuels across all sectors, together with the rapid
introduction of low- and zero-carbon alternatives.
1.3.
Reducing
energy demand and increasing energy efficiency are top priorities,
but alone they are not enough to achieve the greenhouse gas
emission reductions needed; we also need to switch from fossil fuel
energy sources to renewable energy.
1.4. The huge amount of new infrastructure needed to decarbonise our energy supply can, however, have a detrimental impact on wildlife if poorly located and/or designed, whether at sea or on land. The Welsh Government has committed to reversing biodiversity decline by 2020; we believe, therefore, that the Welsh Government has a duty to ensure greenhouse gas emissions targets are met without compromising Wales’ natural environment.
1.5. The RSPB engages with applications for renewable and other energy infrastructure across the UK, advising developers how they can minimise the impact of their development proposals on wildlife. Where the environmental impacts of a proposed scheme are likely to be unacceptable, we will object, but our preference is to work with developers to remove any significant adverse impacts. This has meant that since 1990 we have placed sustained objections on only 5.9% of wind farm applications throughout the whole of the UK. In Wales, since the advent of TAN 8 the RSPB, as a de facto statutory consultee under TAN 8[3], has not sustained any objection to applications within the SSAs.
2. Onshore Wind and Welsh Government Planning Policy
2.1.
While we
support a mix of renewables, the RSPB recognises that for the next
10-15 years, onshore wind power – the most advanced and
widely available of the new renewable technologies – has the
greatest potential to make a significant difference in Wales and
globally, at an economic cost increasingly close to that of fossil
fuels.
2.2.
The RSPB
supports the spatial planning approach exemplified within TAN 8 in
relation to onshore wind, because we believe that this approach is
appropriate to support crucial development of onshore renewable
energy in Wales in the most sustainable locations.
2.3.
TAN 8
supports the delivery of renewables targets, whilst ensuring that
Wales’ most important designated wildlife sites are
protected. It thereby facilitates attainment of the Welsh
Government’s aims for sustainable onshore wind as set out in
A Low Carbon Revolution.
2.4.
In the
creation of the Strategic Search Areas, the “sieving
out” process identified Wales’ very best wildlife sites
with international designations[4].
This thus has the effect of securing these vulnerable sites from
damaging windfarm development.
2.5.
The
spatial approach within TAN 8 provides a level of increased
certainty for developers regarding the outcome of planning
applications for proposals within SSAs.
2.6.
Community
Benefit
The RSPB welcomes the positive context for Community Benefit within
TAN 8 which states that local issues could be addressed by means of
extending or re-creating habitats of significant wildlife
value[5].
However, experience over many years in Wales has shown us that the
way in which this is quantified and deployed is somewhat ad
hoc.
Recommendation 1: Level of Community Benefit - At present, the Welsh Government has issued no advice or guidance about how the local planning authority should set a level of Community Benefit. Whilst setting levels would be challenging, the advent of the Community Infrastructure Levy (CIL) does set out a useful precedent and possible methodology, and the recent new guidance from the Welsh Government[6] is particularly welcome in this respect. Whilst we accept that there will need to be a debate about the actual level set (the current running average in Wales stands at approximately £2500/MW/per year), the process and methodology of setting levels should be addressed as a matter of urgency by the Welsh Government via a “Practice Guidance” note analogous to the “Planning for Renewable and Low Carbon Energy – a Toolkit for Planners” (July 2010).
Recommendation
2: Environmental Community Benefit - The RSPB
would like to see greater clarity as to the nature of community
benefit and enhanced outcomes for biodiversity. During the Third
Assembly the Rural Development Sub-Committee recommended that the
Welsh Government ensure that projects aimed at renewable energy
generation and carbon or water management achieve multiple outcomes
including contributing to biodiversity enhancement[7].
The Welsh Government’s Sustainable Development Scheme
includes healthy, biodiverse and productive ecosystems within its
vision of a Sustainable Wales, and recognises that delivering
sustainable development must include enhancing the natural
environment. Furthermore, the developing Natural Environment
Framework emphasises that the natural environment underpins
Wales’ economy. It recognises that achieving the vision for a
Sustainable Wales depends on all Government policies taking the
natural environment into account, and upon working with businesses
and other partners. We suggest this aim would be supported by a
commitment to allocate a proportion of all Community Benefit
payments – for example one third – to projects to
enhance the natural environment. This should also be achieved
through guidance in the form of a ‘Practice Guidance’
note.
2.7.
Whilst we
recognise that the TAN 8 process sieved out the most important
designated sites for wildlife in Wales we nevertheless consider
that there are substantial wildlife resources of national or in
some cases even international importance within the SSAs in Wales.
Normal planning processes within the SSAs should give appropriate
weight to these.
2.8.
Recommendation
3: “Masterplanning” approach - The RSPB
supports the introduction of a “Masterplanning”
approach which “zones” areas within the SSAs for
harmonised, landscape-scale habitat restoration. The RSPB has
carried out a pilot project which aims to achieve this in SSA A
(“Clocaenog Forest”[8]).
This establishes broad habitat zones within the SSA which
developer’s habitat management/restoration proposals should
be in conformity with. This is a simple but robust means of
establishing an exciting future for the SSAs, and bringing wildlife
back to them on a large scale. The previous Assembly’s
Rural Development Sub-Committee inquiry into the Uplands
recommended this approach as its preferred means of landscape-scale
wildlife restoration in respect of onshore wind[9],
a recommendation which was accepted in principle by the Welsh
Government. The RSPB recommends that a requirement on local
planning authorities to follow this process be introduced via a
“Practice Guidance” note.
The RSPB is willing to provide the methodology employed
in this work to the Welsh Government and to local planning
authorities at no cost and is keen to enter into more detailed
discussions with the Welsh Government in relation to this.
2.9.
Recommendation
4: Clarification of the Actual Geographic Extent of the SSAs
-
Much confusion exists about whether or not a 5km
“buffer” applies to the SSAs. TAN 8 is somewhat
contradictory in this respect. Establishing a mechanistic 5km
extension to each of the SSAs in all directions would bring a
number of internationally and nationally important designated
wildlife sites under the auspices of TAN 8, and thereby render them
vulnerable to potentially damaging development. This lack of
clarity should be resolved. The RSPB is keen to discuss the
detail of how this could be achieved, in the interests both of
wildlife and of the Welsh Governments renewable energy
targets.
2.10. Whilst the RSPB supports the strategic spatial nature of TAN 8, we believe that it can be improved through provision of community benefits, both for the sake of wildlife, but also in order to help obtain wider support for onshore wind on the part of communities throughout Wales, and the wider public.
3. Pylons and Undergrounding
3.1.
The RSPB
believes that it is important to address the issue of pylons and
undergrounding on a case by case basis. There may be many instances
for example where, from the point of view of important populations
of bird species, undergrounding would remove material adverse
impacts. However, there will be instances where
undergrounding would have significant adverse impacts for wildlife
by, for example, significantly damaging the hydrology of fragile
wetland habitats.
4. Marine Renewables
4.1.
The RSPB
strongly supports continued expansion of the tidal stream and wave
industries because of the significant role they could play in
delivering low-carbon energy and positioning Wales, and the UK, as
a global leader in green growth. However, increased efforts are
needed to understand further and mitigate the potential impacts
these industries will have on marine biodiversity. Failure to do so
will result in adverse environmental impacts, and public concern
over these impacts, becoming a major barrier to further
deployment.
4.2. The RSPB welcomes the Welsh Government commissioned Marine Renewable Energy Strategic Framework (MRESF), which was a spatial exercise aimed at mapping the available tidal stream and wave resource in Welsh territorial waters. This work incorporated marine conservation features, and recommended methodologies for surveying potential impacts on mobile species, including seabirds.
4.3. The MRESF incorporated CCW’s natural environment and marine renewables energy mapping project, to which the RSPB contributed data. This work enables a high level assessment of the sensitivity of marine species and habitats to renewable energy device installation and associated infrastructure. CCW’s spatial mapping products, in conjunction with the MRESF, are tools to guide appropriate planning, and steer development away from areas of high sensitivity. They should be incorporated in the forthcoming development of marine plans for Wales. This does not detract from the need for detailed site specific environmental information to inform Environmental Impact Assessments associated with any resulting development proposals.
4.4. Another critical component of the marine management framework, to enable timely sustainable development of marine renewables, is the completion of a network of well-managed marine protected areas, including sites for seabirds. Marine wildlife is in decline[10], and development pressure is increasing. As well as being an environmental imperative, and the subject of international commitments, designation is a legal requirement under national and European legislation. Furthermore, knowledge about the location of important wildlife sites and their key features will enable developers to avoid making applications for projects that are likely to be controversial and therefore subject to lengthy delays.
4.5. The RSPB is concerned that the pace of potential marine renewable energy identification has outstripped the development of nationally important Marine Protected Areas within Welsh waters – Marine Conservation Zones (MCZs), under the Marine and Coastal Access Act 2009. We believe that in order to deliver energy production within environmental limits, the identification of areas important for marine biodiversity should be carried out prior to the development of marine renewables. As such, we recommend that highly protected MCZs in Wales are designated on the grounds of highest ecological value as the principle driver, with current and proposed socio-economic activities considered later in the designation process. While the deployment of renewable energy is critical to Wales’ success in lowering carbon emissions, we believe that the protection of marine biodiversity should be prioritised in the designation process.
4.6. Recommendations:
5. The Welsh Government should work with the UK Government to ensure that support for tidal stream and wave power in Wales is increased, ideally, to the same level as currently received in Scotland.[11]
6. Rapid progress is needed to designate an ecologically coherent network of marine protected areas in Welsh territorial waters and secure appropriate management, ensuring identification of environmentally sensitive locations to enable proper consideration of marine wildlife interaction with energy development and other offshore activities, and reduce uncertainty for the marine renewables industry.
7. The Welsh Government should collaborate with the UK government and the marine energy industry to develop a coherent and comprehensive survey programme for marine wildlife.
8. Public R&D should focus on technological innovation to reduce the environmental impacts of tidal and wave power, and a collaborative industry-stakeholder-government partnership should be established to monitor the impact of marine renewables on the environment.
9. The Welsh
Government should work with the UK Government to ensure that UK
national-level infrastructure assessments are made in relation to
marine renewable developments in Welsh waters, to assess port
infrastructure requirements and to develop a strategic approach
that will minimise overall requirement and the overall impact on
the natural environment.
5. Tidal Range Renewable Energy Technology
5.1.
The Welsh
Government’s A Low Carbon Revolution includes
provision for the generation of 18TWh of electricity from tidal
range technology by 2022, wholly or principally from the Severn
estuary. Half of this would be attributed to consumption in
England, but the Welsh balance of 9TWh represents nearly one-fifth
of total projected Welsh generation from renewable sources.
5.2.
However,
following its Severn Tidal Power Feasibility Study (STPFS), the UK
Government concluded last October that there was no
‘strategic case at this time for public funding of a tidal
scheme to generate energy in the Severn estuary’.
5.3.
The RSPB
engaged closely with the STPFS, and was on the Steering Group for
the Strategic Environmental Assessment. Whilst we objected to the
barrage proposals, which would have had an irreversible and
detrimental impact on the unique and internationally important
biodiversity in the estuary, and the hydrology and geomorphology of
the estuary itself, we were open to innovative means of sustainably
exploiting the energy resource in the Severn. We consistently
called for greater resources and effort to be put behind developing
these options, and asked that acceptable environmental impact be
considered a priority for the feasibility study. Whilst we welcomed
the Severn Embryonic Technologies stream of the study, it was
under-resourced and formed only a small part of the overall study
(£0.5million). The £20million STPFS indicated that
costs would be ‘excessive’[12]
compared to other low-carbon energy options, confirming the
findings of an earlier inquiry into the costs of a conventional
barrage which was prepared for the NGO steering group[13].
It also confirmed that a conventional barrage would be likely to
result in enormous environmental impacts in the estuary and
beyond.
5.4. We note that the Mersey barrage proposal by Peel Holdings followed a similar trajectory to that of the STPFS, with plans now shelved because of costs and opposition on the grounds of environmental impact. Whilst the RSPB supports the sustainable exploitation of tidal range power in principle, we conclude from these experiences that:
· It is extremely difficult if not impossible for a conventional shore-to-shore high head barrage to be built without detrimental impacts on biodiversity and on the hydrology and geomorphology of an estuary, and therefore to comply with environmental legislation.
·
Innovative
technologies may allow tidal range to be exploited sustainably, but
further R&D is required to develop and commercialise them. We
believe this should be the focus of the industry and any future
government intervention.
6. Bioenergy
6.1. The RSPB supports sustainable solutions to the climate crisis. The recent growth of the bioenergy sector in the UK is set to be accompanied by a dramatic shift from burning domestic wood and waste to burning massive quantities of imported wood; indeed this shift is already underway. This could have very significant impacts on wildlife and the climate, and on Wales’ global ecological footprint[14]. Imported biomass is putting temperate forests under increasing pressure and over extraction is already contributing to habitat decline. In 'A Low Carbon Revolution' the Welsh Government aims for half of the feedstock to deliver its target for energy generation through biomass to be imported. We consider this figure too high. The RSPB supports a sustainable bioenergy industry that with careful planning is able to bring unmanaged domestic woodlands back into management for woodfuel – good for biodiversity including declining woodland bird species – along with substantial additional use of waste organic material.