SVU’s Formal Response to the Consultation

SVU’s response comprises four main parts:-

A rejection of the project as proposed.

•A rejection of the need to express any preference for any of the corridors put forward.

•A complete rejection of the validity of the consultation process as it has been conducted thus far.

•A range of solutions which we deem preferable as ways to ensure that the bulk electricity distribution grid is fit for the 21st century.

•

It was prepared by David Holland and Richard Barnes of SVU

SVU's Formal Consultation Response

Sunday, 28 February 2010

This is the text of Stour Valley Underground’s Formal Response to the National Grid’s proposals for an Overhead Powerline Grid Reinforcement from Bramford to Twinstead

Preface

Stour Valley Underground consider the whole of the consultation process to be fundamentally flawed because in our view, the public are essentially being asked the wrong questions and are being asked to answer them with woefully limited information. We hold that both the questions to be answered and the information provided have been contrived simply to provide an answer that suits energy industry needs and not the wider interests of the general population. We have left the providing of this response as late as possible such that all information forthcoming from National Grid might be taken into consideration but our questions remain unanswered. We note with some alarm that the head of the similar consultation process in Somerset, David Mercer, has recently stated that he is not willing to reopen the consultation process to bring in information about undersea and underground strategies and that he does not see the projects in Somerset and East Anglia as in any way linked. Clearly this is not the case.

We also note from a recent written answer from the IPC to NG:-

“Advised National Grid (NG) about the risks of identifying the initial choice of route options and then setting out the case against undergrounding or an undersea route, without explaining fully why (in NG’s view) they should not be taken forward. This approach could be seen by other parties as predetermining the choice of a route(s) and cloud the approach of all to any subsequent consultation.

Advised that the limited correspondence that the IPC has been copied into so far suggests that substantially more work needs to be done to increase the level of understanding in the respective local communities about the environmental, cost and technical implications of undergrounding the line and / or the undersea route. Advised that NG may wish to consider resolving this issue before embarking upon the second stage of consultation, and identifying the preferred route.

Advised that whilst the advice being given was not in any way judgmental on the part of the IPC, the position appeared to be an impasse in relation to the adequacy and appropriateness of the consultation to date. The IPC could not and should not get involved in the merits of the approach taken by NG. However, it would be willing to facilitate, if all parties agreed, a meeting to identify and clarify the extent and nature of concerns and objections by relevant parties and the public to the consultation and approach of NG. It would be for the parties to try and reconcile their apparent differences, the IPC remaining neutral in any meeting.

Following the meeting mentioned above, NG may consider that a different approach is appropriate.

Given that there are in fact clear similarities between the projects and the consultation strategy adopted by National Grid we believe that National Grid should now restart the consultation process, bringing before the public all reasonable reinforcement strategies including underground and undersea, in line with the IPC demands indicated above. For this reason, our response is a briefer one that we had originally intended and we will flesh out our response in light of what we expect to be a fresh round of public consultations which would in effect be a rerunning of phase one of the consultation.

The need for grid reinforcement

We acknowledge the fact that the consultation process has been triggered by the real need to make the grid fit for the new generation and distribution technologies that will be implemented with the objective of meeting the UK target of 15% of energy generation from renewable sources (EU Renewable Energy Directive) and cutting CO2 emissions by 1/3 from 1990 levels by 2020.

The ENSG Reports

Ref: ENSG ‘Our Electricity Transmission Network : A Vision for 2020’

to be found at:- http://www.ensg.gov.uk/assets/ensg_transmission_pwg_full_report_final_issue_1.pdf

Logically, National Grid had a large part in producing the report to the Energy Networks Strategy Group (ENSG) that the Government has adopted and which is now driving the proposed reinforcement projects as they are currently presented to the public. ENSG’s members are almost exclusively from the energy industry. (See www.ensg.gov.uk/assets/ensg_membership_ensgr_2008005.pdf) The overall strategies are therefore essentially the product of prevailing energy industry thinking and National Grid thinking in particular. The thinking is clearly based on reinforcement of the existing grid and the overall strategy is not fully integrated into current Europe wide grid developments and the need for major levels of renewably generated energy to be exported by the UK. We consider the thinking and strategies contained in the ENSG reports to be focussed and first and foremost, on the best interests of the energy industry as they were seen at the time with too little regard to wider environmental and social costs. This thinking has lead to the proposed strategies for an overland reinforcement being an old technology patching up of a failing system. Seen in the context of the developing Europe wide renewable energy distribution grid and the proposed "North Sea Super Grid" in particular, these proposals are very short sighted and a very poor investment at a time of very limited short term fiscal resources and burgeoning technological developments that are surely leading to a revolution in energy distribution. We consider it to be myopic in the extreme to bring the renewably generated energy ashore and then along with the new nuclear generated power, bring it inland, down through the countryside to London, only to take a huge amount of it back out to the coast to export it via the undersea cable technology that could and should have been used to free the valuable landscape of the blight of pylons.

For more on current off shore grid developments see The North Seas Countries' Offshore Grid Initiative at http://ec.europa.eu/avservices/services/showShotlist.do?out=PDF&lg=En&filmRef=67310

Overground Power Lines and Unspoiled Countryside

Importantly and with respect to overground power line proposals, Stour Valley Underground hold it to be utterly unconscionable to blight unspoilt rural landscapes with pylon lines. The landscape is a priceless resource for all people, a resource that will be needed to rebuild the rural economy and it is not for any utility company to preclude this simply to cut their up front costs for changes to their own assets. We also note that there is no representation within the ENSG membership to prioritise any “Non Pylon” method of transporting electricity.

The Timing of the Consultation

Having devoted a great deal of time to researching this issue, Stour Valley Underground have reached the inescapable conclusion that the timing of this consultation and proposal from National Grid is simply wrong. Currently, Government policy statements (particularly EN1 & 5) are out for consultation and not fixed. At least two recent Government initiatives with respect to grid developments have been deemed unsupportable by the current grid according to public statements by National Grid's own CEO (See the Times newspaper articles at http://business.timesonline.co.uk/tol/business/industry_sectors/natural_resources/article6941944.ece

and also http://business.timesonline.co.uk/tol/business/industry_sectors/utilities/article6924255.ece).

This suggests that Government has yet to come to grips with the revolution in distribution technology that is about to burst upon us all. The energy regulator Ofgem is on record as publicly stating that its own regulatory framework and methodology is no longer fit for purpose and is advising a major rethink of the regulatory regime (see www.ofgem.gov.uk/Markets/WhlMkts/Discovery/Documents1/Discovery_Scenarios_ConDoc_FINAL.pdf and BBC reports at www.news.bbc.co.uk/1/hi/business/8494899.stm). Taken together with the recent putting back of on-line dates for the new nuclear generators on the East Coast, this suggests that National Grid are trying to come up with a fixed reinforcement strategy when all other aspects of energy generation and distribution are in a state of flux. We hold it to be obvious that in these circumstances, decisions as to how to reinforce the grid should wait until a clear picture emerges as to how the grid is to develop in the longer term and until the capacity that will be needed in specific locations can be more credibly be ascertained. Put simply and metaphorically, we believe we should not start a journey until we know where we are going.

Local definitions:

For the purpose of this document, the words "grid reinforcement" are taken to mean bulk electrical energy distribution grid reinforcements, upgrades and/or developments. The word "Corridors" refers to the four corridors identified by National Grid in their consultation documents.

Stour Valley Underground's response to National Grids Branford to Twinstead Overground Powerline Project proposals comprise four primary parts.

They are:-

(1) A rejection of the project as proposed.

(2) A rejection of the need to express any preference for any of the corridors put forward.

(3) A complete rejection of the validity of the consultation process as it has been conducted thus far.

(4) A range of solutions which we deem preferable as ways to ensure that the bulk electricity distribution grid is fit for the 21st century.

(1) Stour Valley Underground reject the current NG proposals on the grounds that they are not in keeping with local people's or the Nation's needs and best interests for a number of reasons:-

Locally

(1.1) It is clear that the proposals are designed to bring bulk power inland and then south to London. This strategy has the effect of blighting the landscape and impacting the quality of life of people who are not the end users of the energy being transmitted. This means that the environmental price is being born by people who enjoy no benefit from the energy.

(1.2) In so blighting the East Anglian Landscape, National Grid would be compromising the ability of the East Anglian's to develop new utilisations of the historic and amenity values of the land so that hard pressed rural economies can regenerate through the recreation, leisure and tourism industries.

(1.3) The values of property in the so blighted area would be reduced with no possibility of recompense because National Grid only compensate those with power lines actually over their property and not those whose property and amenity values are reduced due to visual blighting of the views or environs of their property.

(1.4) It is clear that even the threat of more lines of larger pylons is adversely affecting the saleability of property in the proposed corridors in the south of the consultation area.

Nationally

(1.5) The proposed reinforcements lack the long term capacity to deal with all of the potential output from renewable/nuclear generation on and off the East Coast.

(1.6) The proposed reinforcement is not compatible with future needs to integrate the renewable/nuclear generators into the Europe wide grid that is needed to mitigate the fluctuating nature of renewable generation and varying demand levels.

(1.7) The proposed reinforcement represents poor value as it will be made redundant by necessary redevelopment of the grid to meet future energy distribution needs and the impact of new distribution technologies which will take bulk energy distribution offshore.

(1.8) The proposed reinforcement strategy flies in the face of the Holford Rules which amongst other things argue against the production of a "wirescape".

(2) Stour Valley Underground Reject the need to express any preference for any of the overland corridors proposed by National Grid because:-

(2.1) National Grid have failed to make the case for this reinforcement with its attendant costs to the local community and environment because the projected generation sites and capacities are far from certain and have in any case been put back by at least half a decade.

(2.2) The consultation has only considered and brought before the general public, a small subset of the reasonable options available for grid reinforcement.

(2.2.1) National Grid have, by their own admission not researched other reinforcement strategies (as presented in their "Optioneering" document) fully enough particularly, with respect to total underground and total undersea strategies.

(2.2.2) National Grid have precluded full research by local organisations and people of other possibilities by refusing cost data and access to contractors on grounds of the "commercial sensitivity" of data requested.

With reference to this issue we copy an extract from an NG email received by SVU:-

“We understand you have been in contact with Morgan Est regarding the cable tunnelworks at Croydon.I am also the Project Manager for this project, which is still in the construction phase therefore, I would request that any related questions are directed towards myself.In advance, I would advise that because of the stage this project is currently at, I will not be in a position to release any commercial information from some time.”

(2.3) A number of the other grid upgrade or development strategies need no corridor. An example would be an underground tunnel strategy from Bramford to Twinstead which logically would be either straight line or dependent on local geology.

(2.4) An undersea reinforcement would require no on land corridor and only brown field costal sites near existing industrial blighted landscape to be identified.

(3) Stour Valley Underground reject the validity of the consultation process as it has been conducted thus far because:-

(3.1) National Grid have failed to consult on all reasonable grid reinforcement strategies in that:-

(3.1.1) far from bringing forward a full range of strategies for grid reinforcement for public consideration, National Grid have used a limited definition of the word "economic" to rule out numerous possible upgrade strategies with the objective of presenting only those with the least upfront fiscal cost for public consideration. Stour Valley Underground contend that economic assessments should be made on the basis of the effect on the end users energy bill with the investment cost amortised across the lifetime infrastructure involved.

(3.1.2) National Grid have, by their own admission, not fully researched and brought to the consultation process, fully costed assessments of all reasonable reinforcement strategies that the public have clearly indicated they want considered. Put simply, the "Optioneering " is currently and at the end of the first stage of the consultation, inadequate to the task.

(3.2) The consultation process fails to fulfill the statutory obligation incumbent on National Grid for a full and open consultation.

(3.2.1) Neither a full set of options, nor a full and reasonable level of depth of research of alternatives has been presented to the public by National Grid.

(3.2.2) National Grid have hampered those groups wishing to fully research other grid reinforcement strategies by precluding access to data and or contractors on the basis of "commercial sensitivity".

(3.2.3) National Grid have not made public responses to their proposals as sent to them through their web site available for the public.

(4) Stour Valley Underground have researched and presented to the public, a range of strategies that would achieve the needed grid reinforcements without blighting the landscape further and which would in fact lead to a pylon free landscape in the long term.

Stour Valley Underground's view of how to transmit the projected output from he new gas powered power stations at New Holland and Kings Lynn together withthe planned renewably generated power from the east coast windfarms and the new nuclear generators proposed for Sizewell should be by a long term built up or incremental strategy which is a multi faceted approach comprising three partsthat:

•

is compatible with new and international developments in energy distribution

•

is in the best interests of the entire nation

•

eliminates the need for new pylon lines

•

works toward a completely pylon free landscape

Preference 1

A strategy that integrates appropriately into the developing European grid and is in the best long term interests of the entire country. The strategy comprises three parts which are:-

•

To increase the capacity of the existing pylon lines (as is included in NG's proposals) as a short term expedient to transmit the power from the proposed South Holland and Kings Lyn Gas Fired Powered Power Stations.

To connect the proposed Sizewell Nuclear Reactors along with the proposed east coast Wind Farms to London via the Thames Estuary by undersea cabling thereby integrating into the coming North Sea Undersea Grid.

To bury underground the existing local distribution pylon lines along with all other local distribution cables

Refs:

www.trec-uk.org.uk/resources/siemens_uhvdc_october_2009.pdf

http://business.timesonline.co.uk/tol/business/industry_sectors/natural_resources/article5142622.ece

http://www.greenpeace.org/raw/content/eu-unit/press-centre/reports/A-North-Sea-electricity-grid-(r)evolution.pdf

Preference 2

To be used only if reinforcement of the on-land form outlined in the ENSG report is unavoidable. The strategy comprises three main parts which are:-

•

To reinforce the grid in keeping with the needs identified in the ENSG report by :-

•

Constructing 2 x concrete lined tunnels at depth by boring between Bramford and Twinstead

•

Placing a number of 400kV circuits plus 1 x 132kV circuit in Tunnel 1.

•

Placing a number of 400kV circuit plus 1 x 132kV circuit in Tunnel 2.

•

Installing the new 400kV circuits in the tunnels only when required - staggering cabling investment.

•

Demolishing the existing EDF 132kv pylon line .

•

Leaving the existing 400kV overhead line in place for now and upgrade power lines as planned but secure a longer term commitment from NG to underground this line by 2040.

•

Capturing the heat from the tunnels and put it to good use.

To bury underground the existing local pylon mounted distribution lines along with all other local distribution cables

Ref: Elstree - St Johns Wood 400kV Tunnel Project details at :-

www.nationalgrid.com/NR/rdonlyres/DE8F660E-4056-413E-8D69-9616506065FB/36543/UGCaseStudy2.pdf

www.murphygroup.co.uk/uploads/documents/Elstree%20to%20St%20Johns%20Wood%20Cable%20Tunnel.pdf

Key Sources (References)

The National Grid Web Site

ENSG ‘Our Electricity Transmission Network : A Vision for 2020’

Bramford to Twinstead strategic Optioneering Report

The Crown Estate Wind Farm Connection Study

Further details of SVU’s under sea and under ground cable grid reinforcement proposals can be found at www.stourvalleyunderground.org.uk