Failed Consultation

14 reasons why the National Grid "Pylons" Public Consultation thus far is unacceptably flawed:-

This is a list of the issues that Stour Valley Underground, together with its collaborating partner organisations sought to bring before the Infrastructure Planning Commission (IPC) at the recent meeting between the Local Authorities, National Grid, the IPC and ourselves.

(1) The structure of the consultation limits the fullness of consideration of this issue by the public. For example, by only considering environmental impact after pressing the public into choosing a route, NG have deprived the public of the possibility of considering all reasonable grid reinforcement strategies in the context of the environmental damage they cause.

(2) The consultation is untimely and National Grid knowingly brought forward a project proposal with very narrow and fixed options and objectives in a time when the whole context in which the decision is to be taken is in a state of flux in that:-

(2a) The Government Policy Statements that govern such decisions were and are out for consultation and are clearly likely to change.

(2b) The energy transmission regulatory framework administered by OFGEM has being brought into significant question and was (and is) known to be unworkable going forward in its current form.

(2c) Huge changes in the UK energy supply system are occurring and will occur in the near and foreseeable future and these have not been factored into National Grids proposals as presented at the consultation events to the public. These issues include:-

(2c1) Developments in offshore energy generation and transmission mean that the energy transmission burden for the on-land transmission grid will be reduced.

(2c2) Smart Grid technology will impact transmission capacity requirements, reducing them and replacing capacity with computer intelligent management that reduces peaks and fills troughs in electricity demand.

(2c3) Renewable energy source capacities are not simply added to capacities from constant generation sources like nuclear and variable output sources like gas powered stations. Renewable source fluctuations are compensated for by energy from the other sources to provide constancy of supply and security.

(3) National Grid failed to bring all reasonable grid reinforcement strategies before the public and when subsequently they have made some steps in this direction, they have not provided any context in which to consider the costs of these strategies. So undersea cabling for example has not been presented in the context of the fast developing North Sea grid which according to the Offshore Valuation Group, offers the very real possibility of the UK becoming a net energy exporter and therefore having such an asset generate revenue for the UK rather than simply being a cost.

(4) National Grid have failed to provide adequate external and independent sources of information with which the public might look further into this issue and have indeed precluded the accessing of such information from industry sources on the grounds that the information is commercially sensitive.

(5) National Grid have seemingly concluded that the case for this project is fatally flawed in respect of its being justified by the connection of new generation and have accordingly switched the thrust of their argument to the need to meet SQSS grid security regulation and N-2 or N-D in particular. This has not been brought to public attention. These requirements are also subject to review by OFGEM currently and in light of the massive change in the way capacity is determined (from a deterministic approach to an intelligently managed one with the advent of Smart Grid technology) and the standard will logically be lowered in light of this.

(6) An issue of semantics: National Grid have skewed the presentation of the cost of various grid reinforcement possibilities by their use of words such as "economic" Their definition refers to the upfront cost and not the cost to the average household across the lifetime of the infrastructure invested in. It also does not consider other revenue generating possibilities such as heat capture from underground cable tunnels and rental of space in such for data cables and local energy distribution cables. Nor does it consider the revenue generating possibilities of undersea cables as part of a renewable energy export grid forming part of the fast developing European Grid.

(7) National Grid have failed to conduct "Willingness to pay" research and thus we all have no context in which to decide whether a strategy is "too costly".

(8) National Grid have failed to properly present the project as being in two parts (1) reconductoring and (2) new pylon line. Given that reconductoring will add 50% to circuit capacity and that even without this the grid can accomodate the new generation from the gas powered generators in Norfolk, this means that there is not the urgency suggested for any further reinforcement and that the case for new pylon lines is not made.

(9) National Grid have failed to present a case for the reinforcement that takes account of the high levels of slippage that are occurring in the completion dates for the new generators, currently of the order of half a decade, nor of the impact of changing Government plans which currently include Smart Grid and Undersea Grid implementation commitments, both of which majorly impact the case for a new pylon line.

(10) National Grid failed, by their own admission to adequately research even those alternative reinforcement strategies that they included in the "Optioneering Report". The information presented to the public is therefore clearly inadequate for the purposes of fully informed public consultation.

(11) National Grid failed to include obvious alternative reinforcement strategies in their Optioneering Report such as direct undersea connection of North Sea generation to London. They included costed though technically impossible strategies such as undersea HVAC and yet failed to look at obvious strategies such as upgrading the existing pylons to carry even higher capacity conductors and adding a switching station at the Twinstead Tee to address system security issues.

(12) Significant enhancements to local grid security have not been included in the consultation or Optioneering Report. An example would be the possibility, expresses to us by an engineer, of placing a switching station at the Twinstead Tee that would allow the two circuits going south to have their full capacity potential realised. Currently the circuit from Pelham to the Tee, then going south is highly underutilised for the majority of the time. Such a switching station would deal with the "transient instability" security issue that NG are trying to deal with in this project.

(13) National Grid have consistently reduced the possibility of exchange of ideas between respondents within the consultation. It can be argued that important insights into the issue can be gained by individual respondents being aware of the views of other respondents. This is true both at consultation meetings for councillors and with respect to public respondents written responses on National Grid's consultation event forms. The responses on the forms have never been made publicly available. Organising "drop in" meetings also tends to reduce the liklihood of concillors all being present together at one time to learn from NG responses to their colleagues questions and assertions. This issue directly and negatively impacts the openness and quality of "consultation".

(14) New corridor options have become part of the discussions (2C) but this option actually takes the pylons through two parishes that have not been part of the consultation. It is therefore the case that some people who could be directly affected by the consultation and the decisions that flow from it have not been consulted.