NAS CONSULTATION RESPONSE: DECC – Planning for New Energy Infrastructure Revised Draft National Policy Statements for Energy Infrastructure

The Noise Abatement Society welcomes this opportunity to respond to consultation on revised draft National Policy Statements for Energy Infrastructure. This response focuses on aspects of proposed policy that have changed, or particularly important issues which NAS believes should change. However, NAS would also draw the Department’s attention to the Society’s response dated 22 February  to consultation on earlier drafts and would request that points of principle made therein should be reconsidered alongside this submission.  

 
Overall Comments
 The Noise Abatement Society welcomes the additional consideration that has been given to noise in this second round of consultation. NAS believes that this will make a significant contribution to making the new processes more effective for all parties, and trusts that this strengthened coverage will be maintained in final editing.

More generally, some of the wording of the NPSs is imprecise and does not reflect their role as statements of policy rather than provision of background information to the applicant and decision maker. The number of instances is too great to itemize, but for example, in paragraph 2.6.97 of EN-3, where it is evident that offshore piling noise can kill or injure statutorily protected marine mammals, it is insufficient for the NPS to say that monitoring “can be undertaken”. Monitoring should be a requirement in specified circumstances.

Further editing is required if NPSs are to give the required clarity for IPC/MIPU, applicants and communities. However, such editing should not, of course, convey certainty where specific issues remain uncertain. Also, IPC/MIPU and applicants should still be encouraged to use the most up-to-date evidence and best practice, e.g. where there may inevitably be some lag between developing knowledge and NPS review.

The resources available to local planning authorities (LPAs) to participate constructively and in a timely fashion to the decision-making process, remains an issue, particularly the production of Local Impact Reports (LIRs). LIRs are likely to require considerable input from local authority planners, supported by their environmental health colleagues and other specialists.

Local authority staffing is, of course, under increasing pressure from spending cuts. If NPSs are to part of a successful process, Government should reconsider how adequate funding can be provided to support the contribution of LPAs to the process, e.g. from part of applicants’ fees.

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