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Today's entry reports on further delays to the National
Networks National Policy Statement.
The suite of National Policy Statements (NPSs) forms the basis
for the declaration of need and for the assessment of impacts of
the nationally significant infrastructure projects covered by the
Planning Act 2008.
The Act covers 16 types of project, and so far there are NPSs in
place for 10 of these - six covering the eight types of energy
project, one for ports and one for waste water. For a table of
the correspondence between NPSs and projects, see
this blog entry. There is a further NPS in draft that
will cover hazardous waste projects. The remaining six types
of project are highways, railways, strategic rail freight
interchanges (SRFIs), airports, water transfer and
dams/reservoirs.
An airport NPS and water supply NPS are looking unlikely, partly
due to the expected absence of projects of those types coming
forward. There are indeed none of those types amongst live
and forthcoming projects on the Planning Inspectorate's list.
Perhaps there should be NPSs anyway, but that's another story.
[Stop press: an airport project has appeared today]
That leaves highways, railways and SRFIs, which are all due to
be covered by a single NPS, the so-called National Networks
NPS. In this case there are actual projects under
consideration and anticipated: there is a live highways project and
four anticipated ones, two live railway projects and four
anticipated ones, and three anticipated SRFI projects -
constituting 20% of all projects and 25% of live ones.
The Planning Act is therefore not working as intended for the
live applications, as there is not even a draft statement of
whether the projects are needed, and no list of impacts that
promoters should address in their applications and the Planning
Inspectorate should assess when examining them. The key test
for refusing an application, whether the impacts outweigh the
benefits, will be all the more difficult to ascertain if the basis
for neither side of the equation has been set down.
Where is the National Networks NPS, you may therefore ask?
In the first 'route map' of timings in July 2009, the then
government gave a date of 'autumn 2009' for this. If
we take the midpoint of autumn as 5 November, then that was just
over 900 days ago. That is no small delay. First,
incorporating High Speed 2 was given as the reason for the
delay. Then, the 2010 election intervened and the government
changed, causing further delay. By the end of 2011, we were
told that the NNNPS was finally 'imminent'. That
remained the case until March this year.
I now understand that it is no longer imminent. The
reasons given are twofold: that the Prime Minister's office is
taking an interest, and also that updated policy on roads is about
to be proposed. In November 2011 policy on SRFIs broke away and was updated,
looking something like the text that would appear in the
NNNPS. It seems that roads are to follow suit with new policy
but this time we will have to wait for the NNNPS as a result.
There is certainly a lot of roads activity at the moment - see
our recent
newsletter - but that does not necessary mean delaying the NPS.
There will always be forthcoming changes to policy - waiting until
policy is settled would mean waiting for ever.
The criticism of prematurity was levelled by the Energy and
Climate Change Select Committee against the energy NPSs but the
government finalised them anyway. And this isn't even the
hardest transport policy - aviation is surely more difficult.
The further delay is regrettable, and means that three live
projects will be examined in a vacuum. So, in the near words
of Dexy's Midnight Runners - come on Justine!
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