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NETWORK / 24 / MAY 2018 ENVIRONMENT Considering alternatives Martin Broderick, visiting Professor of environmental and social impact assessment, impact assessment unit, Oxford Brookes University, explores common misconceptions regarding alternatives in environmental impact assessment (EIA) of electrical networks. only examine an alternative that has formally been put forward as part of the application. Alternatives considered by the developers The developers all produced a Strategic Options Report (SOR) that set out the costs of the engineering options available to connect the generating facility (the A) to the electricity network (the B). The options included: • Alternative technologies; • Alternative routes. A recurring theme during each stage of the consultations was the desire of Interested Parties (IPs, comprising of statutory bodies, non-governmental or - ganisations (NGO) and members of the public) who responded to the consultation to see the connection put completely underground. The developers approach to defining alternatives: The developers broadly adopted the following methodology for the assessment of alternatives. The first step was to initially identify an: • Area of search between Point A i.e. generation station and Point B i.e. a suitable link to electricity transmission system (Map 1- schematic): The developers then outlined their: • Preferred route corridors (Maps 2 and 3): The develop- ers carried out consultation to assist in the selection of the preferred route corridor. Corridors are identified utilis- ing the following guidance of: o Only seeking to build six distinct steps in the PA2008 development consent process which can be viewed at https:// infrastructure.planninginspec- torate.gov.uk/ NSIP case study This article reviews a number of anonymised NSIPs of what the author considers to be good practice in the treatment of alternatives and the strategy for stakeholder engagement. Applications for development consent, are submitted under the Planning Act 2008 (PA2008) to the Planning Inspectorate (PINS) pursuant to sections 14(1) (b) and 16 of the Act, for the installation of a high voltage electric line above and below ground. The develop - ments considered include the construction, operation and maintenance of new connec- tions between a generating facil- ity (the point A) and an existing Over Head Line (OHL the point B) https://infrastructure.plan- ninginspectorate.gov.uk/pro- jects/register-of-applications. Key issues The following were the key issues identified during the ex- aminations of the applications: • The route optioneering con- cept and process; • Consideration of the infra- structure against the 'Holford Rules' (seven guidelines for the routing of new high volt- age overhead transmission lines developed in 1958 by Lord Holford); and • Proposed undergrounding. The starting point in the consid- eration of alternative routes un- der the PA2008 is that PINS can T he consideration of alternatives and the associated engage- ment of stakeholders is a key foundation of environmental impact assessment (EIA). However, even where stakeholders have been engaged in a transparent manner at an early stage (more than two years prior to the submission of the application) and iteratively (three rounds of consultation), some stakeholders still fail to ap - preciate how to engage with the process of proposing alternatives. The new Infrastructure Plan- ning (Environmental Impact Assessment (EIA)) Regulations 2017 ("the IP Regulations") (SI 2017/572) require the EIA to con - sider and compare "reasonable alternatives" and provide the rationale for the options chosen for the nationally significant infrastructure planning (NSIP) regime. This article explores this new requirement of "reason - able" alternatives and crucially explains that this requirement will apply equally to developers and stakeholders. "Reasonable" is not defined in the directive but the author adopts the ordi - nary English definition of "be- ing in accordance with reason or sound thinking". Relevant UK legislation (England and Wales only) The planning process for dealing with proposals for nationally significant infra- structure projects, or 'NSIPs', was established by the Plan- ning Act 2008 (PA2008) (as amended). The PA2008 sets out thresholds (s16(3)(a) i.e. 132kV) above which certain types of infrastructure development are considered to be nationally significant. NSIPs require a type of consent known as 'develop- ment consent' under procedures governed by the PA2008. The consenting process involves an examination of major proposals relating to energy, transport, water, waste and waste water, and includes opportunities for people to have their say before a decision is made by the relevant Secretary of State. The PA2008 regime only applies in England and Wales. The Planning Inspectorate (PINS) and NSIPs In England, PINS examines applications for development consent for all NSIPs. In Wales, it only examines applications for energy and harbour devel - opment, subject to detailed provisions in the Act. There are six energy National Policy Statements (NPS), setting out Government policy: • NPS for overarching energy (EN-1) • NPS for renewable energy (EN-2) • NPS for fossil fuels (EN-3) • NPS for oil and gas supply and storage (EN-4) • NPS for electricity networks (EN-5) • NPS for nuclear power (EN-6) Any developer wishing to con - struct an NSIP must first apply for consent in the form of a De- velopment Consent Order (DCO) to do so. For such projects, PINS examines the application and will make a recommendation to the relevant Secretary of State, who will make the decision on whether to grant or to refuse development consent. There are