Introduction and Overview
New Anglia Energy (NAE) welcomes the opportunity to respond to the draft Local Industrial Strategy (LIS). NAE is run by Nigel Cornwall, a recognised independent commentator on energy policy and markets. We are committed to applying learnings from the low-carbon energy transition through facilitation of decentralised energy markets to the benefit of householders and businesses in Norfolk and Suffolk.
The draft LIS is a useful consolidation of activities and aspirations, but it falls short of being a holistic plan for delivering clean growth and a bespoke regional industrial strategy through to 2036. It would have benefited, in my view, for execution of underlying reviews in key areas such as infrastructure, supply chains, transport. It relies heavily on a number of actions already taken (Cefas, ORE Catapult, OrbisEnergy etc. and case studies that probably cannot be replicated or scaled), without asking what the growth objective should be and what additional steps are needed to deliver it.
Responses were invited on 14 August 2019 with a deadline of the 27 August straddling the August bank holiday This is not an appropriate timetable for providing responses on such a key consultation that has clearly been in the pipeline for some time. As Community Action Norfolk and no doubt others have pointed out in their published responses, this does not meet the standard of “extensive consultation” set out by BEIS.
The LEPs are competing for finite resources to deliver regional strategies, but the aim surely must be to have the local economy making a greater contribution to the national economy and to secure as large a share as realistically possible of future growth. Ideally, I would have had time to cross read the draft with the other LIS statements already adopted or being consulted on to provide a better sense of relative ambitions, how NALEP is positioning the region and how its proposals compare against emerging best practice. This is not an academic exercise; its about understanding relative positions and securing competitive advantage.
This response focusses on clean energy growth rather than agri-food and ICT/digital creative areas of the draft LIS, of which I have little real experience. Its preparation has been greatly limited by the time available, and in my opinion significant further dialogue will be necessary to deliver a Local Industrial Strategy that comprehensively meets the needs of local communities and stakeholders if it is be properly inclusive. It would also have helped had there been some focussed consultation questions around the key judgments and decisions already taken to inform the plan as these are largely taken as given.
I have therefore focussed on three themes that I believe could be built on in sense-checking and further developing the document. They are:
- Increasing the level of ambition, especially in the light of adoption of net zero
- Rebalancing and broadening the energy focus, and
- Turning aspirations into assessable action plans.
In short further work is needed before the draft can be submitted to the LEP Board for approval. The 25 September date is self-imposed and should be relaxed.
Increasing the level of ambition
There are many positive elements in the draft LIS, which rightly builds on the strong record of clean growth already achieved in the region through development of a handful of large energy projects, which are in the process of being added to. Overall, however, it is not clear either how the plans and projects outlined will enable the delivery of key growth targets or existing carbon budgets (which it is recognised cannot be attained even under the current policy umbrella), or how they should be upgraded in the light of the new, much tougher 2050 net zero target. It could be argued – erroneously in my opinion – that delivering net zero should be grafted on to the foundations of policies and actions delivered in the nearer term.
The Science and Technology select committee chaired by Sir Norman Lamb MP (North Norfolk) published earlier this month a fair but hard-hitting critique of the Clean Growth Strategy (CGS). Obviously this narrative post-dates the publication of the draft LIS, but there is only one reference in the document to a net zero carbon future, and much of the document reads as if it were authored prior to adoption of the new target. It is already clear, however, that several assumptions underpinning the CGS will need to be revisited and the areas of energy, transport and land use will be at the centre of this re-evaluation.
As a minimum it is essential the draft LIS demonstrates awareness of these changes and how the strategy might be future-proofed to take account of them.
A much more ambitious framework is required, with clear alignment of proposed programmes and actions against adopted targets, including the 2050 net zero target although it falls outside the strategy period, together with how the strategy has been stress-tested and upgraded to address the much tougher objective and a clear narrative around what this means for adopted growth targets and policies.
Rebalancing the energy focus
The document focuses on progress already largely banked in established energy sectors, concentrating on green electricity. This is understandable given the record of offshore wind and onshore nuclear development, which is an area of obvious local pride and has created considerable local growth through development of supporting supply chains. But the flip side of this is that we need to increase concentration on the vibrant, low-carbon, hi-tech sectors that are emerging regionally. They are noted usually on a by exception basis, and this is in notable contrast to for instance the plan recently published by the Cheshire and Warrington LEP, which is very technology-centric. The tone of the Cambridge plan is also very different in this respect.
Oil and gas is also assumed to provide new opportunities albeit from decommissioning, but is also assumed to play a vital role in the clean energy transition, although it is likely much of this gas will be sourced from overseas markets (but not necessarily through Bacton and BBL). The gas network could be repurposed for use by hydrogen but there is no consideration of how gas will be decarbonised, and I agree CCUS and hydrogen could play a part in a “test and demonstration zone”. But this is all very aspirational and could be read as little more than a “wish-list”, and there are tough issues and trade-offs that need to be addressed for each.
The decarbonisation of heat also offers immense challenges, especially in many areas which are off gas grid, but therefore real opportunity. How can local authorities in the region be supported to develop pilot schemes, and how can this be combined with measures to assist hard to heat homes and fuel poor and vulnerable customers?
The same can be said of transport decarbonisation and vehicle automation, which is the sector that is now the greatest contributor to emissions in the economy. Developing an Electric Vehicle Plan is to be commended, but how will this be delivered in an area that is already falling behind in the adoption of EVs and the supporting charging infrastructure. Where does
the East-West corridor and other inter regional transport routes figure and how can clean freight be supported and prioritised? What intra-regional transport networks are needed to support these for SMEs and communities? What are the particular challenges facing charging roll-out and autonomous vehicles in diverse, dispersed areas?
Shipping gets one mention, and its electrification is a problem area to a sector that already has a significant regional footprint. Is this a risk or opportunity for Felixstowe? Where are the regional clean air blackspots and can the strategy enable these to be tackled? Whilst there are references to new types of mobility services, what are the public and community transport models that can help both reduce carbon emission and support access to employment.
There are also few references and specific proposals as to how the energy efficiency in the built environment will be promoted and severe legacy problems tackled. How can retrofitting properties be prioritised and supported, and how can this work be integrated with aggressive targets to build new homes? In this context, the strategy should also explicitly embrace a significantly greater strategic commitment to increasing the levels of affordable housing across the region. Again, there should probably have been a review carried out as this is likely to be a key focus in the new net zero world.
The hydrogen economy is a potentially rich and complex area of the new energy economy, especially as the offshore wind industry continues to proliferate and will create renewable energy surpluses for large parts of the year with lower demands. However, hydrogen only gets three brief mentions in the document.
There are also other gaps outside of the energy space that need filling: health, social care and retail sectors do not seem to be actively debated within the draft LIS.
There needs to be a rebalancing in the document with much more focus on decarbonisation of heat and transport, a linking of housing and infrastructure planning and specific consideration of how to transform energy usage in the built environment. There needs to be specific objectives with regard to hydrogen development given the starting advantages that the region enjoys, but the problems over the longer term associated with decommissioning oil and gas facilities as they approach depletion needs to be addressed too.
Turning aspirations into assessable action plans
There is an abundance of documentation setting out the vision both at national and regional level. What is not clear is how aspiration will be turned into evidence-based policies and specific actions, and then how these will be monitored and evaluated. The draft LIS refers to “an annual stock-take of progress” and “an evaluation programme” but there are few details. More generally it is not clear who is tasked with doing what under the draft LIS and how it will be operationalised and governed. It is clear, however, that new, more synergistic partnerships will be required between the LEP, local authorities, the Greater South East Energy Hub and other stakeholder bodies.
In this context Client Earth has recently written to councillors and planning officers from areas that are revising their local plans, reminding them of their legal responsibilities. These duties include setting targets and policies based on the local potential to reduce emissions, and that are at least in line with the Climate Change Act 2008 and the need to plan for full decarbonisation. In this context eight local authorities in Norfolk and Suffolk are cited as presently not meeting their obligations against the pre net zero baseline.
Client Earth said that, for carbon targets to be meaningful, they need to be incorporated into local planning policy as a core objective against which all other policies and decisions will be tested. Local planning authorities also need to monitor performance against local targets at least annually. The same applies to the strategy.
Governance of the process is also very important if it is to have local ownership. Other stakeholders need to participate in finalisation of the strategy and its oversight. How will the LEP be supported by key stakeholders to address these issues, and where does the Greater South East Energy Hub fit into this?
The LIS also needs to reference the role of the VCSE sector, including community groups, more explicitly and respond to the particular challenges it faces to ensure proper participation. It needs to explain how it will foster delivery of the government’s Civil Society Strategy.
Delivery needs to be pursued through development of local action plans, build on existing structures and be inclusive both in terms of delivering benefits but also in achieving ownership of the strategy. A new approach to achieving stakeholder participation, including the VCSE sector, and ongoing engagement needs to be developed.
We would like to see the delivery and monitoring framework much more clearly set out. Its governance needs to be clearly understood so there is accountability. More inclusive processes are needed to ensure a wider range of stakeholders can be involved and have their views registered and taken into account.
Please let me know if you have questions on this submission and whether I can provide anything further.
New Anglia Energy
11 September 2019