A Powerful Challenge Achieving a green grid for a green island Foreword and Summary Status Issues Options Recommendations May 2009 Foreword and Summary Our policy statement addresses the challenges related to implementing a new strategy for the development of Ireland’s electricity grid: to underpin economic revival and future progress, to allow for much greater integration of renewable energy sources into our grid and to benefit consumers by stimulating greater competition in electricity pricing, through increased interconnection with other European energy markets. Our statement synthesises the diverse experience and information we have gathered since North East Pylon Pressure began its campaign in favour of underground cables as the appropriate technology for the transmission of high voltage electricity in Ireland. Our policy position is informed and underpinned by robust research and analysis by reputable international consultants and is in line with the emerging best practice in other countries. It has been refined, too, by carefully listening to and considering the questions and issues raised by local and national politicians and by representative groups. Fairminded public representatives and representative organisations have shown that they are keen to understand the issues and to adopt a reasonable way forward, once they are convinced that undergrounding is feasible, affordable and attainable within a reasonable timescale. This statement charts the way forward for everyone on this issue. It recommends: The establishment of an All-Party Electricity Infrastructure Committee A specific analysis of the expert reports and technical arguments on Underground cables versus Overhead lines and pylons A re-evaluation of current national voluntary compliance levels for Electro Magnetic Fields (EMF) Implementation of the 2007 Experts Report to Government on EMF A commercial tendering process for all projects related to electricity transmission infrastructure Further Information: North East Pylon Pressure, PO Box 106, Navan, County Meath. Tel: 085 28 11 285 E-Mail: info@www.pylonpressure.ie Web site: www.pylonpressure.ie Status Europe Europe’s power system, including its network infrastructure, has to be planned, built and operated for the consumers it will serve. The need for a strengthened policy to facilitate the completion of priority infrastructure projects was underlined by the EU Heads of State and Government in October 20051. The EU plans to invest, before 2013, at least €49 Billion on electricity infrastructure alone, including €6 Billion outlined in the Trans European Networks – Energy (TEN-E ) guidelines. It is recognised that development of renewable energy resources will further increase the pressure for better developed transmission network capacities both within and between Member States. Ireland In January 2008, the Department of Communications, Energy and Natural Resources published the ‘AllIsland Grid Study’, outlining an aspirational plan, to generate an unprecedented 42% of our electricity from renewable resources, especially wind and tidal energy. For the plan to be economic, the price of a barrel of oil must be at least $200. The ability to achieve this receivables target, however, requires a major upgrading of the electricity transmission network, with an estimated investment cost of €10 Billion. Significantly, the requirement to transmit the energy generated mainly along the Atlantic seaboard of the South West and West over to the East of the country would involve the construction, using large c.40 metre high pylons, of an additional 1,150km of extra high voltage lines. A further 2,300 km of existing high voltage transmission would require an increase in their physical size and/or power levels. Additionally, an increase of 5,000 km of distribution overhead lines would be required. In October 2008 EirGrid, using the All-island Grid Study aspirations, outlined a €4 Billion plan that could profoundly change the landscape of our countryside by massively increasing the number of pylons and overhead electricity lines in almost every County (Fig 1). Grid 25 includes the two major projects already proposed for the North-East, namely the 60km Meath-Cavan 400kV power line project and the 80km Cavan- Tyrone Interconnector project. On 7th April 2009 EirGrid announced their Preferred Pylons Routes for both projects: Route 3B for Meath-Cavan and Route A for Cavan-Tyrone. Ireland is in a unique position. In contrast to other countries, we have not yet been subjected to a blight of pylons across our countryside, although this is now proposed by EirGrid. Careful, objective evaluation of all of the factors and consequences of this damaging proposal is required. Fig 1: Grid 25 plans Issues Europe In 2007, the EU recognised that progress in the development of electricity networks is insufficient and significant obstacles remain. The analysis conducted by the Commission Services1 unearthed various shortcomings: 1. Twenty of the 32 main electricity infrastructure projects face delays. This is in stark contrast to the main gas projects, where no significant delays have been reported. 2. The reasons for delays in ten of the eleven top priority electricity projects includes the common theme of opposition from the local populations for health/EMF, environmental and visual intrusion reasons. To this end, the Commission considers that ‘it is vital to reduce the planning and construction time for prioritised EU infrastructure, in a way that duly takes into account environmental, safety and health concerns.’ Ireland North East Pylon Pressure (NEPP) is the overall representative group of the people of the North East, who have built a case and made recommendations to Government to adopt the progressive, environmentally and socially acceptable alternative of using underground cables instead of giant pylons and overhead lines. This campaign is representative of the other campaigns that have or will continue to occur in relation to local population preferences for underground cables rather than overhead lines. Analysis of the rationale for the trenchant public/stakeholders’ opposition highlights the following difficulties and shortcomings (see also Appendix 1, Figs 2-3): The Processes Used 1. There has been no public consultation or involvement in the ‘All-Island Grid Study’, which makes radical proposals on a significant piece of strategic infrastructure. The decision to base our future electricity grid on a 42% renewables aspiration, and the consequential significant increase in proposed overhead lines and pylons has had no public airing or debate. This is unacceptable. 2. The Minister for Energy has handed over the ‘Grid 25’ development strategy to EirGrid as an ‘operational matter’. There has been no third party independent or stakeholder involvement. This is unacceptable. 3. The Transmission System Operator (TSO) approach to the grid development has been both biased and blinkered. EirGrid have clearly stated and have shown by their actions that they have an absolute preference for overhead lines in rural areas. EirGrid have steadfastly refused to take account of the advantages and benefits of undergrounding, for our environment, for our landscape and for the communities of the North-East. Instead, they have approached the projects solely on a one-dimensional engineering basis. EirGrid commissioned a study by their own long-standing consultants, PB Power, to evaluate and cost all the potential worst-case technical barriers to undergrounding, but not to examine any of the benefits. Practical route options for undergrounding were not even considered. This is unacceptable. Remit of the TSO There is a significant weakness in the remit of EirGrid. It arises from the undue emphasis on its responsibility and accountability for technical and engineering aspects of grid performance and development. It has no formal responsibility or accountability for the environmental and socio-economic aspects and consequences of grid development. This leads to incomplete and inadequate analyses of the overall effects of grid development on local populations and indeed the wider public. This is unacceptable. Commercial Monopoly The vast majority of TSO’s across Europe are state-owned. This has given rise to a monopolistic situation, with compulsory powers of acquisition in many cases. It has resulted in risk aversion and lack of innovation from a commercial perspective. It has fostered a culture of aggressive and dismissive attitudes to genuine consumer and public concerns. These attitudes are very evident in EirGrid’s approach to management of the grid development. This is unacceptable. Collateral Damage It is an inescapable fact that that high and extra high voltage power lines and pylons are the most objectionable form of public utility infrastructure on land. They impose significant negative effects when established, in relation to visual and environmental impact, land and property devaluation, and health and safety concerns. Yet, this clear fact is neither addressed by EirGrid, nor factored into its project cost estimates. Currently, only landowners who have pylons placed directly on their land are eligible for compensation. The fact is, that significant numbers of surrounding householders are also negatively affected, but currently have zero redress. This is unacceptable. Public Consultation/Engagement In relation to the two projects proposed for the North-East, EirGrid have failed to adequately engage with the public or address their many concerns. This is highlighted by a number of their actions: Their unwillingness to meet the public in the initial stages after the route corridor announcements. The persistently misleading claims made to the public in relation to undergrounding costs for the North-East projects, which have no basis in fact. The broken commitments made to NEPP in relation to both technical and non-technical discussion fora. Additionally, the inaccurate and misleading statements made to the press in relation to discussions with NEPP and ASKON. The disrespectful treatment meted out to Professor Noack, a leading expert on undergrounding cable technologies. This is unacceptable behaviour from an organ of the State. Unless they are dissuaded from this objectionable behaviour, EirGrid will try to replicate it in all the other counties affected by their Grid25 Report. Quality of Work There is a fundamental issue of public confidence and trust concerning EirGrid’s research, reports and statements in relation to the North-South projects. Examples include: Numerous basic errors in their constraints reports Misleading claims about underground costs in press releases and published documents Numerous basic errors in their choice of emerging preferred routes, including the proposed placement of pylons. This is unacceptable. Options The depth and breadth of issues outlined highlights the low likelihood of making constructive progress in upgrading the national grid in a realistic timeframe using the traditional confrontational and exclusive approaches with local populations and relying on pylons. Fresh thinking allied with a new mindset is required. NEPP proposes the following options: Assume Political Responsibility It is incumbent on all elected representatives, but particularly those in Government, to assume responsibility for resolving the issues related to advancing the grid network. There should be no abdication of responsibility, as countenanced by Minister Ryan, to default strategic decisions solely to the TSO. EirGrid’s role should be that of servant to, rather than masters of, the political process. Examine Practices in Other EU Countries These grid development challenges are not unique to Ireland. Other countries are addressing them in an objective and inclusive manner and are achieving progress. Denmark, in particular, is a relevant example, given its similar renewable resource objectives to Ireland. Faced with strong political and local opposition to proposed new overhead lines in 2007, the Danish transmission system operator, Energinet, commissioned a high level technical study including representatives of both local and national government departments to examine grid development and make recommendations. The result is a sound, scientifically-based political consensus across all the major parties in Denmark that rules out the construction of any new overhead 400 kV lines where these do not already exist. Energinet is rolling out a number of major activities, including the testing and planning of the first long 400kV AC cable in Denmark, and a general national cable action plan for the existing regional 132/150 kV grids, which will outline how the regional transmission grids can be undergrounded in the next few years. Independently Review the ASKON Reports and Recommendations A significant body of work2 specific to the North-South projects and directly relevant to the future Irish grid development has been produced by Professor Friedhelm Noack, a leading expert in both overhead line and underground cable technologies. This has yet to be objectively examined by independent expertise, who have no vested interests in current projects. Based on his research and the ASKON Reports Professor Noack has recently been invited to be a working member of the International Council of Large Electric Systems (CIGRE). The EU Commission has also published a report3, outlining the benefits and potential of undergrounding (Appendix 2, Table 5). Engage with Industry Expertise The monopolistic dominance by State companies of all strategic decisions, responsibilities and actions in relation to electricity infrastructure is unhealthy. It needs to be tackled by at least broadening out the discussion to include private industry. The Grid 25 Report, for instance, fails to even mention the approval of the Commission for Energy Regulation of an East-West interconnector being developed by a commercial company (Imera/Oceanteam) PRIOR to EirGrid’s own well heralded and promoted approval. There needs to be a culture and a process of tendering out all commercial projects related to strategic infrastructure, rather than defaulting to the State organisation. Recommendations Establish an All-Party Electricity Infrastructure Committee The remit of the committee will be to evaluate and agree on the principles for future expansion of the transmission grid, taking into account the following parameters: Technical and affordability issues, including feasibility Environmental and landscape/visual aspects Socio-economic and public-related issues Impact on consumer electricity prices The all-party committee would engage the appropriate expertise to address the above parameters outlined. The expertise would include relevant international technical experience, commercial experience, and and appropriate TSO representation. Public stakeholder representatives affected directly by grid development proposals should be at all times accommodated in a proportionate manner, so that constructive progress can be made. The Committee’s objective would be to make consensus-based recommendations, within a reasonable timeframe, on a new national policy for grid renewal and development. Specific Analysis of Underground versus Overhead Reports and Arguments A number of technical reports exist on this subject, with differing conclusions and recommendations. A suitable independent forum with appropriate independent expertise is required to hear and evaluate these arguments and determine their suitability and applicability to the Irish Grid. This has not been done in an objective manner by the Irish TSO. Re-Evaluate current Compliance levels for Public Health & Safety, Confidence and Acceptance Ireland’s current voluntary safety and health compliance levels in relation to electricity transmission infrastructure, as practised by EirGrid, are the lowest in Europe. In some other countries within the EU, acceptable distances from extra high voltage overhead lines are set eight-fold further away from dwellings than in Ireland. Safety levels in terms of EMF emissions in some EU countries are set 250-fold more sensitive than in Ireland. These aspects are relevant to the public, irrespective of whether overhead lines or underground cables are involved. The low levels set by EirGrid are a major obstacle in terms of public trust and confidence. Implement Recommendations of 2007 Government Report on EMF There is widespread stress and anxiety related to people’s concerns regarding the health effects from extra high voltage lines. The Government has failed to act on any of the recommendations of a major report by the Expert Group on Health Effects of Electro Magnetic Fields. Implementation of the recommendations of this report, published in March 2007, is required - including that of giving the Radiological Protection Institute of Ireland the necessary powers to become the single agency managing EMF issues, backed up by a high-powered Scientific Advisory Committee, and a Policy Coordination Committee. Appendix 1 Fig. 2: Diagrammatic representation of current imbalanced and dysfunctional infrastructure process Fig 3: Diagrammatic representation of proposed balanced and functional infrastructure process Appendix 2 References 1 ‘Priority Interconnection Plan – Communication from the Commission to the Council and the European Parliament’. COM (2006)846, 2007. 2 Study on the Comparative Merits of Overhead Lines and Underground Cables as 400 Kv Transmission lines for the North-South Interconnector Project. F Noack, U.Hass, ASKON Consulting Group, 2008 3 ‘Undergrounding of Electricity Lines in Europe’. Commission of the European Communities Background Paper, 2003.