Published on March 20, 2014
Natural England – Experiences in the PINS process GoBe Consultants Ltd Steve Bellew
• Galloper OWF (504MW) • Triton Knoll OWF (1200MW) • Atlantic Array (1200MW) • Burbo Bank Extension (258MW) • Walney Extension(750MW) • Hornsea P1 (&P2)(1200MW) • Navitus Bay (970MW) • Rhiannon (2.2GW) GoBe OWF PINS Experience
Overview • Pre-application - engagement and advice • Examination: • Statements of common ground • Provision of advice during the examination phase • Post-consent • NE charging
Caveats • Not all NSIPS are born equal! • Not all developers (or consultants) are the same! • Examinations vary (greatly) due to Ex.A approach and interests • The views expressed are my own – although hopefully representative of the broad experience of the industry
What do OWF developers want from the planning process? • Certainty of risk • Clear targets/thresholds • Timely decisions • Consistency • Proportionate approach • Pragmatic approach • Flexibility in the consent • Cost reduction • Recognition of broader Govt policy
Pre-application phase • Improvements from earliest OWF NSIPS very noticeable, positive and welcome • Level of engagement (and resourcing) • Timing of engagement • Understanding of the process • Communications and responsiveness • Still room for improvement? • Scoping issues out (advice to PINS) – avoid Super-EIAs! • Signing issues off pre-application (so as not to be visible in examination) – avoid clutter! • Consistency of advice throughout pre-app phase – a problem of changing faces vs an organisational view? • Common understanding of issues, terminology etc (especially for more subjective issues) • Consistency between projects? • Influence of senior policy opinion on case work
Pre-application phase (contd) Some solutions? • Recognise the national importance (but also complexity) of NSIPs such as OWFs • Are case officers always adequately supported/resourced/empowered? • Is there a need for a much more prominent (lead?) role for principal advisers from the earliest stage and throughout? • Technical experts – availability, consistency, suitability to case work? (and management of externals!) • Role of MIEU evidence plans – positive feedback and should help to avoid issues during examination (or focus areas of disagreement from the outset)
Examination Phase Statements of Common Ground • Again huge improvement since earliest OWF NSIPs • role of SoCG now generally recognised and valued • Willingness to engage and resource (up to a point!) • Willingness to agree and set aside many issues during the pre-exam stage • Willingness (generally) to stick to ‘agreed positions’ throughout the examination
Examination Phase • SoCGs – room for improvement? • Still need to ‘re-invent the wheel’ for each project? – lack of familiarity in SoCG process between case officers, differences in views on format/content/areas that can be agreed etc • Some tension between ‘statutory duty’ – written rep vs resourcing of SoCG – need for ‘bigger picture’ for examination phase? • Role for this pre-app? Ability of NE to ‘commit’ during pre-app? • Some solutions? • Establish and agree a common SoCG approach (aims, broad format, contents, policy agreements etc) • Increase staff knowledge of SoCG in broader ‘stat duty’ context for NSIP projects • Earlier SoCGs (pre-app?) – de-clutter the exam?
Examination Phase Advice during examination Again experiences much improved and feedback has been broadly positive: • Greater appreciation of the Planning Act examination process (although could be improved at case officer level?) • Very much improved communications (during examinations and during hearings) (with developers and with other stat bods) • Willingness to work together to resolve issues or be clear on disagreements • Willingness to share written representations as early as poss. • Resourcing and access to technical expertise (for example in considering clarification information etc) and attendance at meetings, discussions etc generally good • Involvement of principal advisers alongside case officers • Pragmatic approach to dealing with more minor issues, mitigation etc • Helpful advice in directing further consideration of outstanding issues
Examination Phase • Advice during examination – room for improvement? • Consistency of advice (and changing faces) sometimes a problem during examination – case officers and/or technical experts • Bottlenecks can still occur on resourcing – esp. technical experts • Late changes during examination in light of new information or change of strategic position (moving goalposts?) • Lack of certainty in advice – preference to present ‘options’ to the ExA, lack of clear thresholds etc – not helpful in the decision making process (too precautionary)? – need to recognise the weight placed on NE advice by ExA (and SoS) • Care is required in drafting written responses – awareness of influence on ExA and interpretation of advice – seek to close down rather than open up! • ‘Precedent paranoia’? Fear of changing positions in light of previous case advice?
Examination Phase • Solutions? • Adopt clear unambiguous (proportionately precautionary) advice for the ExA • Set a clear ‘target’ – and let developers solve issues • Ensure all written responses are checked (or indeed drafted) at principal adviser level to ensure the ‘right’ message is being sent in the context of the examination process and the ‘bigger picture’ • Accept that there is a ‘shut off’ point regardless of new information/strategic positions? • Better management of precedent issues – caveating of advice? Recognition of differences in cases?
Overarching issues • Urgent need to address some key issues in face of impending R3 applications: • CRM – Band models, avoidance rates • Displacement – mortality assumptions etc • Thresholds – PBR, PVA etc • In-combination – past & future projects • Need for a clear and agreed ‘coping strategy’ on these areas that allow management of risk and consistent decision making • Article 6(4) – urgent need to address IROPI/alternatives/compensation for OWF NSIPs and deal with the big questions for key species - are any of us ready!?
Post-consent – its only just begun! • Is there a recognition and understanding of the level of work required? • Monitoring requirements (strategic options?) • Pre-approvals • Design details • Mitigation plans and other documents etc • Is there a recognition of the timescales/compliance issues? • Is the resourcing in place to facilitate development programs?
NE Charging • The costs of project development are increasing under the new process • Costs are becoming an increasing issue for all projects even at planning stage But: • If charges are levied by statutory bodies then: • Charges should be reasonable • Should be reflected in a level of service: • Resourcing • Technical expertise • Consistency of advice • Responsiveness • This being the case, developers are generally positive that charging will help the PINS process
Final thoughts • Already the industry has recognised great improvements in NE resourcing and understanding of the process • Engagement and willingness to resolve issues is generally good • Consistency of personnel and advice remains a concern for some projects • Need to recognise the weight given to NE advice in the process and need to provide advice accordingly • More and earlier principal adviser engagement is beneficial for these major NSIP projects • Progress is needed on the ‘big issues’ (and probably IROPI) • Don’t forget the post-consent phase!
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