A Response to National Policy Statement Consultation (NPS) Guidance EN1 and EN5
This response represents the view of Stour Valley Underground, a pressure group set up by a number of Parish Councils in North Essex and the south of the consultation area identified in the National Grid Bramford to Twinstead Overground Power Line Project. See our web site at www.stourvalleyundergroundfor more details.
The following comments address issues contained within both EN1 and EN5 within the National Policy Statements.
The National Policy Statements seem to be founded in the notion that the only economic way to distribute bulk electricity is by power lines on pylons. Clearly this is no longer the case. We are on the cusp of what will perhaps be the largest step forward in energy generation and distribution technology yet seen. Throughout Europe, HVDC undersea cable technology is being implemented to link the grids of all of our continental neighbors. The BritNed connector is a current example with the EDF UK-France link having been working for some years. The CEO of National Grid has been reported as describing the use of this technology as a "no brainer" because it is the cost effective solution to carrying bulk energy from (say) the highlands of Scotland to England down the west coast. National Grid have also ruled out the use of overground HVAC cabling to link Scotland to North Wales, opting instead for an undersea HVDC link on cost grounds. So clearly HVDC cabling and undersea strategies should feature in any national policy statement. We believe therefore that EN1 and EN5 need to be redrafted in light of this.
It is clear that the regulatory framework that is a consequence of current national policy has hamstrung the development of the UK electricity grid because of its adherence to an interpretation of the word "economic" that leads to up front cost being the dominating factor as opposed to whole life cost or annual cost to the end user (the household). Certainly the cost of underground and undersea cabling technologies is coming down, reaching parity with HVAC over ground lines for longer distances. There are other technologies that are in use and developing such as "superconductor" transmission systems that should be included in EN1 & EN5 such that policy does not rule out the adoption of these technologies in a timely manner. A whole new Europe wide grid is developing using Cross Linked Poly Ethylene (XLPE) cables and currently an undersea grid is in development for the North Sea. Accordingly, the XLPE and other emerging cabling technologies should be covered by EN1&EN5.
Whole life cost benefit analysis for any given transmission technology should form the basis of any determination of which is most economic and not just up front costs. This should be calculated across the full working lifetime of the proposed installation taking into account the likely life expectancy of the attached generating technologies. We would expect this period to be of the order of 40 years for HVDC. In calculating the cost benefit, transmission losses should also inform the calculation.
The carbon footprint of any transmission technology should also be a key aspect of any electricity transmission project to be put before the planning authority of the time (currently the IPC). The current overhead power lines shed a vast amount of energy direct into the atmosphere (as much as 1Gw) in the form of heat, directly impacting global warming. Preference should be given to technologies that include the economic capture of this energy such that is can be put to good use.
Section 2.1: Climate Change Strategy, which endeavors to bring the policy in line with the Carbon Change Act of 2008. There is no mention of the transmission losses or of the recapture of lost energy in the form of heat. It should be incumbent on any transmission project proposer to include the carbon footprint impact of transmission losses in calculating the overall carbon footprint of the proposed transmission strategy. Measures should be demanded to offset any unmitigated losses by other measures within the proposed project.
Section 4.5.3: This section speaks of Good Design but is incorrect in indicating that there is little choice in the design of electricity pylons. There is clear evidence from countries such as Denmark that more aesthetically acceptable pylon designs are indeed possible, the "Eagle Mast" being one such design. Section 4.5.3 should prioritise mitigation of aesthetic impact of pylons on the landscape through good design. Full consideration of, and the development of strategies to mitigate their impact on the landscape involved should be a clearly stated obligation for the project proposer
Section 4.1: The section on Health Impacts should in our view be advocating a precautionary approach to the placing of unshielded HVAC power lines and should stipulate at least 200 metre distances to individual dwellings and at least twice this to schools. We accept that the evidence for the effects of electromagnetic radiation from AC transmission lines is as yet inconclusive but note that currently the evidence for EMF's from HVAC lines causing childhood leukemia is currrently impacting planning decisions. We believe that prevailing European standards in this respect should be enshrined within EN1. Current Health Protection Agency Guidance on the risks from EMF's from overhead HVAC power lines is under revision and in the mean time we believe EN1 and EN5 should be precautionary in stance and should rule out any possibility of power lines passing either near or over schools, something the current wording would allow.
Section 4.15: Security, as covered in Section 4.15 fails to address the real possibility of malicious damage to electricity transmission equipment. Some of the currently proposed "reinforcements" to the grid would put high levels of transmission capacity into close proximity. If damaged, these would gravely impact the economy of the nation due to the facts that the grid can only sustain the loss of 2 circuits before blackouts result and in some cases, 4 or more circuits would run in the same place. If you consider proposed reinforcements in East Anglia, a terrorist act against the proposed reinforced Bramford -Twinstead link could shut down the City of London and the costs could be counted in £billions. Clearly, such vulnerable, over ground, high capacity installations are already susceptible to increasingly volatile atmospheric conditions due to global warming and should in any case be avoided on energy security grounds. We note the precautionary approach to this issue in the USA in deciding on which technology to employ in the New York -Jersey connector. Homeland security considerations ruled out the use of overground pylon lines.
Section 2.3.5: The most efficient or rather right solution must take into account environmental and social costs as well as economic and this must be calculated across the working life of the transmission equipment involved which we take to be of the order of 40 years. The carbon footprint should be considered alongside the economics of the transmission technologies being considered and the economic strategy that produces a carbon footprint most in keeping with the objectives of the Climate Change Act should be selected.
Section 2.7.4: In the last paragraph of the Holford Rules, we believe you should rewrite it because the wording does not take account of new technological developments in electricity distribution. Since the drafting of the Holford Rules in 1959 technology has moved on and the last decade has seen a step change with undersea and underground cable technologies being rolled out on a huge scale throughout the world. We note that long distance undersea HVDC cabling technologies in particular can offer numerous advantages including lower installation and running costs, reduced transmission losses and markedly reduced environmental impact in all senses of the word. This together with faster implementation times due to reduced planning delays. We believe all new energy distribution strategies should be developed in light of Europe wide grid developments and that policy should see this as a cornerstone.
The statement that underground cables cost 10 -20 times as much to implement as over ground lines on pylons is incorrect and there is much evidence to show that whilst underground installations are generally more costly initially, they can reach parity with overground in some instances.
Section 2.7.8: It is misleading to consider only the installation costs for transmission equipment and the running and maintenance costs (which can be considerable) should also be factored in when comparing the economics of transmission technologies for a given proposal.
Section 2.7.9: The technologies that are embedded in this section are pre-war and utterly out of date. The whole section needs rewriting in light of developments in transmission technology, especially in XLPE cabling as is widely in use in Europe and also superconductor technology as has been implemented in the USA. Policy must leave room for the current rapid level of development.
Section 2.7.10: This section is based on the erroneous view that underground and undersea cabling are always more expensive than power lines on pylons. This section should be rewritten such that costing is calculated on a whole working life basis (40 years for HVDC) taking into account environmental (inc. carbon footprint) and social together with economic considerations. The section should be more distribution technology neutral such that the policy remains relevant in a time of fast changing energy distribution methodology and equally fast changing generation technologies. The advent of smart grid will also bring great change to the distribution system and will require policy to be flexible enough to encompass innovative new local and national distribution strategies.
Section 2.7.13: Mitigation of visual impact should be made a priority in bringing forward proposals for new energy distribution projects and as mentioned earlier, new pylon designs of the sort being developed in Scandinavia should be considered in preference to the ugly utilitarian lattice designs that have been used since the 1920's.
Section 2.9: With respect to potential EMF related health issues, as mentioned in our response to EN1, we believe a precautionary approach should be adopted to the siting of power lines near dwellings and places where people collect such as schools. We advise a minimum distance from any dwelling of 200 metres.
NB. We are sure that it is unnecessary to fully reference the above as the information is widely known. We are however happy to provide such information if required.
We hold the need for the revisions we have suggested to be clear and obvious even to the general public and note the views of the CEO of National Grid, Mr Steve Holliday, published in an article in The Independent published 23rd July 2009.
“In the UK, the main item on National Grid's agenda is to refresh the electricity infrastructure itself. The grid's architecture – designed around a central spine connected to a relatively small number of very large sources of power – is simply not appropriate for the 21st-century energy mix, with lots of smallish wind farms, both off and onshore, as well as the new nuclear power stations. According to the Energy Networks Strategy Group, Britain's power grid needs £4.7bn of unavoidable investment, 75 per cent of which will come from National Grid. But rather than simply boosting the existing network, the group has a more radical scheme to build new links running down each coast under the sea. The plan for the west coast – from Scotland to just south of Liverpool – is the most advanced. It is no more costly than the more conservative upgrade plan. And although there are some challenges – such as shifting the current to DC when it goes offshore, and AC when it comes back on again – none of the technical novelties is a showstopper. "I just don't think anyone ever thought of doing this before," Mr Holliday says. The plan for the eastern half of the plan has yet to be proven. But the western undersea grid is a "no-brainer", Mr Holliday insists, even for a company as risk-averse as National Grid. Ofgem seems to agree. The regulator has made a rare exception to the rules and given National Grid the go-ahead to start work on the project before the business case is fully worked out.
Clearly, this shows that the current wording is out of step with current developments.
Europacable_Presentation_Overview_of_EHV_cables.pdf from www.europacable.com
Full campaign details at www.stourvalleyunderground.org.uk
This response was prepared by David Holland
for and on behalf of Stour Valley Underground, 5th February 2010
Contact details: David Holland, Court House, Church Road, Twinstead, Essex, CO10 7NA, Tel: 01787 269693 email: firstname.lastname@example.org