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Fighting the Pipe: neo-liberal governance and barriers to effective community participation in energy infrastructure planning Christopher Groves, Max Munday, and Natalia Yakovleva Abstract Development of effective participatory mechanisms within infrastructure planning governance has been dependent on how far the outputs of participatory processes have an impact upon strategic policy priorities. However, neoliberal modes of governance are characterised by recentralisation within arms-length regulatory bodies and private corporations. Tensions between participatory governance and re-centralisation are exemplified by the relationship between energy privatisation and energy infrastructure planning. This study examines these tensions using a case study of a critical infrastructure project in the UK, the South Wales Gas Pipeline. Findings confirm arguments in the literature that siting conflicts often centre on policy issues as much as local concerns. The study reveals that the neoliberal recentralisation of some governance functions exacerbates such conflicts. It argues although new efforts to secure effective participation in neoliberal regimes are necessary, they will face obstacles in the form of risk-based governance structures, as exemplified by the privatised energy sector. Keywords Infrastructure planning, participatory governance, pipelines, planning cascade, privatisation. Introduction The heart of conflicts over the siting of nationally-important infrastructure is often seen as a clash between not-in-my-backyard (NIMBY) local interests and national policy. It has also been argued, however, that siting conflicts over such infrastructure often act as condensation points for wider concerns, which can cross scale from the interests of a specific community to connect with national and even international issues such as mitigating climate change, protecting indigenous peoples rights and so on (see Owens 2004). As a result, participatory planning may be seen as more than just a means of improving procedural fairness, as emphasised by some commentators (e.g. Gross 2007). By linking siting proposals to broader political priorities, genuinely effective participation has a substantive dimension, exemplified by the case of the Mackenzie Valley gas pipeline in Canada (Gamble 1978). Nonetheless, Owens (2004) and Cowell and Owens (2006) have pointed, in the UK context, to how a countervailing streamlining tendency in land-use planning can close down opportunities for participatory decision-making, reducing siting decisions to a trade-off between national need and local interests. In this paper, we explore how such trade-offs, and conflicts driven by them, are the product of forms of governance which characterise neo-liberal societies, with the aid of a major energy infrastructure case study from the UK (the South Wales Gas Pipeline, or SWGP). Our argument is that, while participatory decision-making has made inroads into governance within contemporary societies, the decentralisation of power associated with neoliberalism (and in our case study, with energy privatisation in particular) brings with it a distributed re-centralisation of decision-making. Such re-centralisation may intensify streamlining tendencies within planning governance, and can prevent participatory mechanisms from taking forms which achieve either procedural fairness or true effectiveness, i.e. substantive impact. We show that, in line with significant recent literature, that substantive issues often form the focus of planning conflicts. We also suggest that, based on our case study, how the power to shape the policy priorities that drive infrastructure

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development is distributed may be among these issues. The paper is structured as follows. First, it examines the literature in order to argue that the effectiveness of participatory mechanisms is dependent on whether they allow second-order reflection on the policies and purposes which drive infrastructure development. Second, it shows how this mode of substantive participation stands in tension with risk-based modes of neo-liberal governance exemplified by the privatised national energy network in the UK. Third, the paper explores the history of the SWGP project and investigates how community groups engaged with the planning process, before discussing how this case can help us understand the tensions between the drive for more participation, and the re-centralisation of governance. We show how, although the Pipeline was built under a planning regime that has been superseded in the UK following the 2008 Planning Act, the issues it raises are perhaps even more significant under the new regime. Background Participatory governance Since the 1970s, land-use planning has seen a variety of experiments with participatory processes as an alternative to the classic technocratic model of decide-announce-defend, often associated with a high modernist model of government (Scott 1998). Simultaneously, the emergence of neo-liberal forms of economic governance during the same period gradually transformed the relationship between the state and society. Increasingly, the state became a facilitator of development rather than its agent. The privatisation of public utilities in many societies since the 1980s has consolidated this new role. However, as has been observed in the case of the UK, this new form of state may have its own utopian projects quite as ambitious as those of high modernism (Moran 2007 p. 6). The need for society to be legible to an administrative centre did not decrease. Indeed, it increased proportionate to the degree to which administrative responsibilities are re-distributed and more and more activities become subject to audit and measurement. Further, the auditing gaze does not simply survey the present. It also takes on a new temporal aspect by seeking to render the future more legible, through risk thinking (Rose 1999). A new focus on participation, along with risk thinking, represent two tendencies within a broad stream of governance reform that flowed through the 1960s to the 1990s (Walls et al. 2005, pp. 641-643). On the one hand, greater participation is seen as a means both of enhancing the ability to anticipate perhaps overlooked negative outcomes of action, and of also improving the legitimacy of governance by balancing the privatisation of governance with greater involvement of stakeholders in decisions. On the other, the internalisation of risk thinking as a discourse of quantification and auditing within organisations became a way of creating another model of legitimacy for governance. The tense relationship between these two tendencies is important for understanding how infrastructure planning has evolved under neoliberalism. In what follows, we set out, in more detail, key features of the two tendencies in relation to planning. With respect to participatory governance, it has been argued that it may improve decision making with regard to the potential social and environmental impacts of infrastructure development (Ward 2001). Participatory processes may marshal a more comprehensive and inclusive evidence base that draws on a variety of perspectives including local knowledge. In this sense, they can be instrumentally useful. They may, however, be preferred on account of justice. By allowing more perspectives on a proposal to be included, they can enhance distributive and procedural justice (Gross 2007). They may also enable

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greater recognition of historical injustices, including e.g. local accumulations of polluting infrastructure that stigmatize particular places and communities (Walker 2009). To be effective in serving these three purposes, participation should ideally be early, when alternatives are still open; be inclusive and feature two-way communication; allow access to key information; offer genuine opportunities to influence or even veto decisions; take into account the diverse values of participants; and be transparent (Bond et al. 2004). However, participation may be effective in another sense by allowing public reflection on substantive issues including what kind of society participants wish to inhabit, questions of national interest, and other matters. In this way, participation around planning concerns at local and regional scales can provide an arena for focused reflection on the assumed purposes of national strategies (Cowell and Owens 2006, 2011). Consequently, participation can embody reflexivity in an expanded sense, even if it takes place downstream of strategic decisions. If a piece of infrastructure is a kind of solution to a problem, then participatory governance may, by including more perspectives, enable the problem itself to be examined, along with the ways in which it has been framed as a problem. In this way, whether participation is effective or not depends on how far it enacts secondorder reflexivity towards both means and presupposed ends. Substantively effective participation may be imagined as creating a feedback loop (Rough 2011), which begins with an examination of localised impacts, benefits and risks associated with a given proposal. Widening participation in examining these illuminates, in turn, considerations which may lead to a critique and re-framing of the policy problem to which the planning proposal appears as a viable solution. In this way, local planning conflicts can lead to modifications in assumed definitions of the national interest, even if they do not end in consensus (Owens 2004). Risk thinking, power and energy infrastructure planning under neoliberalism We now turn to the second of the aforementioned tendencies, i.e. the internalisation of risk thinking within governance as a legitimatory discourse, and how this shapes the distribution of power in planning. The relationship between this tendency and the evolution of participation as a form of second-order reflexivity is often conflictual. The tension here derives from the opposed logics of power which characterise the two tendencies. Where effective participation demands dispersed power (Ward 2001), embodied in institutionalized processes that drive critical scrutiny of policy problems as well as solutions, neo-liberal enrolment of private companies and other governance actors decentralises while simultaneously recentralising. The creation of new centres of calculation (e.g. privatised energy utilities, industry regulators) is accompanied by the need to render the field in which they operate legible to government, both in the present and with a view to its projected futures requirements in which risk thinking plays a significant role. In the next section, we will explore the internalisation of risk thinking within the UKs planning regime in relation to energy privatisation, and how risk knowledge and power are linked. As noted at the beginning of the previous section, the neo-liberal state can be viewed as evolving, in some respects, out of the high-modernist state. The high-modernist state evolved a set of tools for transforming an uncertain future into a meaningful parameter of planning, one that could be both told and tamed (Adam and Groves 2007). State bureaucracies developed quantitative criteria for measuring the success or failure of policies, depoliticizing decision making in the process and recreating the domain of politics in a way amenable to bureaucratic management (Rose 1999, pp. 198-199). Representing the future in terms of risk,

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and developing methods for estimating and comparing risks, extends the legibility of society into the future. Neoliberalism re-affirms this legitimatory role for risk. In relation to the UK, Moran (2007) observes that the contemporary British neo-liberal state has adopted a role of regulating and balancing markets as providers of public goods. The amount of statistical information the new regulatory state requires means that new and closer relationships have to be built between government bureaucracies and expert advisors. The persistence of a centralised and linear predict and provide approach to the future in contemporary British infrastructure planning has been noted (Cowell and Owens 2006; Marshall 2010, p. 30), a durable highmodernist element of a British political system where the stress, historically, has consistently been upon strong, centralized, efficient government, rather than responsive government, and in which the government has traditionally been seen as the sole judge of the national interest (Marsh and Hall 2007). What changes with energy privatization is that the centre where information is collated and future risk scenarios produced is no longer singular and located in Whitehall, but multiple and dispersed located in the corporate headquarters of privatised utilities and of regulatory agencies (Scott et al. 1998). An important UK example of these changes is energy privatisation. Before privatisation in the 1980s, the production and distribution of energy in the UK was a public duty of statecontrolled bodies. With privatisation, this universal obligation is lost (Guy et al. 1997). Instead of one organisation, a multitude of providers is created, who have public service obligations but also private commercial obligations. Away from energy production, the electricity and gas distribution network was signed over to a private monopoly (National Grid plc, formerly Transco, the sole transmission network operator or TNO in England and Wales). Part of the public duties falling on National Grid (NG) as a TNO is to forecast future demand and infrastructure needs and inform policy frameworks. In fulfilling the duties, NG produces annual ten-year statements (e.g. National Grid 2005), which inform white papers, statements of need and other elements of government policy through fora which have included (between 2001 and 2006) the Joint Energy Security of Supply Working Group (JESS), whose remit was to assess risks to the UK's future gas and electricity supplies (Department for Business Innovation and Skills (BIS) 2009) and to identify relevant policy issues and consider implications (Winstone et al. 2007, p. 5). Under the new planning regime introduced by the Planning Act 2008, this information continues to be the main source of demand forecasts which inform the National Policy Statements (NPS) relevant to gas and electricity infrastructure (DECC 2009, p. 11). As a result, policy answers to the essentially political question of what is in the national interest with respect to energy are significantly influenced by essentially administrative bodies such as JESS. NG thus plays the role of a key centre of calculation, providing future demand forecasts which help tame uncertainty, while also being a developer that constructs infrastructure in response to these forecasts. Following privatization, the commercial arrangements for downstream supply of gas became much more complex. Increased uncertainty and risk for investment in infrastructure created a greater need for stability, so that long-term supply contracts guaranteeing stability of supply could be signed (Manners 1997, p. 302). In contrast, the Government itself is no longer a developer, nor is it a strategic planner, having adopted a governance role of non-decision making (Cowell 2004, pp. 312-313). Another such centre is the energy industrys regulatory body, the Office of Gas and Electricity Markets (Ofgem), which was responsible, along with the then Department of Trade and Industry (DTI), for chairing JESS. Ofgem was created in 1999 with the primary remit of making privatised energy production utilities accountable to consumers (Moran 2007) and of

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facilitating a predictable environment for investment through forward price signals (Department of Trade and Industry 2003, p. 14). The need for a regulatory regime stronger than that which operates across the rest of the private sector is necessitated by the statutory duties which fall on utilities (established in the UK under, inter alia, the Gas Act 1986 and Electricity Act 1989) to provide essential goods. Ofgem is often seen as an agency whose primary goal is to encourage competition and hold energy producers accountable for their pricing strategies. Nonetheless, it also has responsibilities for regulating the wider environmental and social impacts of electricity and gas provision, including the infrastructure which NG constructs. It has, however, proven difficult to translate these responsibilities into concrete practice (Guy et al. 1997, p. 214; Cowell 2004, pp. 319-320). At the strategic level, then, the relationship between NG and Ofgem as centres of calculation is not strictly one of regulated and regulator, as Ofgem has historically concentrated on its duties as a representative of energy consumers. NGs input into policy means that it occupies a special role in the UK system, consolidated by the predict and provide strategic approach to energy infrastructure, in which demand is something to be met, rather than managed. Since the 1970s, the need for longer-term energy demand forecasting in neo-liberal societies has increasingly been framed in terms of maintaining energy security (Marshall 2010), an issue defined by the International Energy Agency in terms of interlinked systemic risks (Winstone et al. 2007, p. 1). Such discourses locate policy debates within narratives of necessity, in which the national interest is assumed to lie in providing for projected energy demand, which will in turn generate more economic growth (Cowell and Owens 2011, p. 15). This generates the fundamental set of policy problems, in relation to which technical advice (from companies like NG), white papers and infrastructure proposals (from companies like NG) represent steps towards solutions. The position of energy utilities, TNOs and regulatory agencies within high-level planning processes is thus defined within these narratives of necessity. Their power to affect spatial planning is proportional to their role as centres of calculation of need and risk, joined to their role as developers. While Ofgem is active in trying to regulate energy markets, it is not so in regulating infrastructure planning in any high-level strategic sense. This is left to downstream processes of impact assessment and review within the planning system. The lack of strategic regulation of environmental and social impacts reinforces what Owens (2004) has described as a planning cascade, in which policy problems, cloaked in necessity, drive policies which define national need, before being translated into concrete infrastructure proposals. Only at this latter stage can participatory mechanisms be activated, solely to determine where the infrastructural solution to the policy problem should go, rather than enacting effective, substantive reflection on strategic problems. In this way, planning conflicts emerge as, primarily, conflicts between local interests and the national interest, this latter having become largely insulated from reflection and critique in the process. Recent changes to the UK planning system Making the situation still more difficult for effective participatory governance are changes in the mechanics of planning governance.1 Until 2008, the Town and Country Planning Act (TCPA) was the chief legal instrument for oversight of land use planning in England and Wales. For larger installations of national importance, consents were traditionally granted by the relevant department of the UK Government, a system of deemed consent which overrode the need, under the TCPA, for developers to seek permission from a local planning
1

Note that this discussion applies primarily to the situation in England and Wales within the UK. Planning governance in Scotland and Northern Ireland differs in relation to many or all of the following considerations.

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authority (LPA). This made it less imperative for LPAs to map out forward-looking policy on the acceptability of different kinds of energy infrastructure in particular locations (Kellet 1993, p. 96). Consequently, the relationship between local authorities and privatised utilities with regard to planning was generally, though not always (Guy et al. 1999), a highly reactive one (Scott et al. 1998, p. 539). With respect to regional and local spatial planning local or regional spatial development plans (LDPs, RDPs) were the medium through which LPAs translated into policy the short- and longer-term interests of communities for whom they were responsible. How the centralized decision-making processes of utility companies related to these spatial strategies within the planning system was therefore complex and often problematic (Guy et al. 1996). LPAs which attempted to use its LDP or RDP to ensure that a particular area that had been historically burdened with hazardous and/or polluting infrastructure developed along a different economic path have generally found that this was not enough to stop planning permission being granted for more infrastructure of this kind (Scott et al. 1998). Provided consent was given by the Secretary of State, then the only further obstacle was having a proposal called in by a government minister, something which opponents could request. Nonetheless, this system saw a series of significant, successful challenges brought against major infrastructure projects in the 1980s and 1990s. As such, the planning system contained counterweights to technocratic, predict-andprovide-style planning. These challenges created a perception within government and industry that the planning system was subject to blockages and in need of being modernised. At the same time, the increased demand for participatory governance in planning was acknowledged. The result was an uncomfortable synthesis of proposals for streamlining planning and for public engagement in spatial planning, manifested within the Governments Planning: Delivering a Fundamental Change Green Paper in 2001 (Cowell and Owens 2006, p. 407). The subsequent Barker Review of Land Use Planning (2006) added to the momentum behind modernisation, ahead of the 2008 Planning Act, which included two main innovations. First, new strategic policy instruments (National Policy Statements or NPS) relevant to large infrastructure of national importance, and second, a new centre of calculation, the Infrastructure Planning Commission (IPC), whose role was to assess planning proposals designed to fulfil needs identified in an NPS. The IPC could, in theory, find against a proposal which might impose excessive costs on local communities, but would have to disregard representations that relate to the merits of policy set out in a national policy statement during [...] decision making (Woolley 2010, p. 236). Without a clearly negative net local effect, the IPC would be likely to decide quickly in favour of the national interest, as defined by an NPS, over local interests in any given case. This led some commentators to interpret the new regime as reinforcing planning cascades by closing off opportunity structures within which objectors could link particular proposals to reflections on strategic concerns, in the way that substantively effective participation demands (Rough 2011, pp. 4041). Although some consultative input was allowed into the formation of NPS, the level of abstraction involved here meant that these consultations were unlikely to benefit from the energetic mobilisation of different perspectives with which local campaigns often connect localised impacts to national policy (Woolley 2010, p. 237). Not long after the Conservative-Liberal Democrat Coalition took power in 2010, the IPC was dissolved, with its role and powers being assigned to a section of the Planning Inspectorate. Revisiting their 2006 paper on the modernisation of planning, Cowell and Owens (2010) noted that, under the Coalition, infrastructure planning would likely not be materially different to the streamlined cascade structure established by the 2008 Act. The significance of the localism governance agenda introduced by the Coalition, most notably with the

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Localism Act 2011, for these issues remains to be seen, although some have suggested that negative impacts from the Act are likely to be felt on local democracy generally, and planning in particular (Cowell 2012; Le-Las and Shirley 2012). The potential for planning cascades shaped by high-level, technocratic processes of need and risk management is thus characteristic of the UK planning system, before and after the 2008 Act, and is particularly evident in relation to energy infrastructure. The delegation of legitimate authority to manage future energy risk by government to privatised utilities renders decision-making non-transparent, creating facts on the ground to which LPAs and communities affected by infrastructure plans have to respond when the cascade reaches them. This reinstates a technocratic, modernist decide-announce-defend model of planning strategy within neo-liberal governance (Hardy and Ritchie 2010, p. 15). The opportunity for wider participation in the planning process comes far downstream from the point where a piece of infrastructure has been judged nationally necessary, and a set of alternative sites determined (Cotton and Devine-Wright 2011, p. 954). Consultation with regard to NPS notwithstanding, the regime established by the 2008 Act does not establish opportunity structures that might counteract the cascade, by allowing effective and substantive participatory reflection on policy and the national interest. Under the neo-liberal governance regime that prevails in energy privatisation, the responsibilities and power delegated to TNOs like NG appears to put them in a unique position, where their strategic role is counterbalanced neither by significant strategic regulatory oversight of the social and environmental impacts of their activities, nor by upstream participatory negotiation of the priorities they help define. Some have argued that the need for such counterweights is underlined by the concern that with privatisation comes potential conflict between the public duties of utility companies and their private obligations to shareholders and others, which can result in negative consequences for service users and those affected by planning decisions (Defeuilley 1999; Hall and Lobina 2004). Case Study: The South Wales Gas Pipeline (SWGP) The South Wales Gas Pipeline project, in which NG was a major actor, was framed by NG and government against the background of an impending energy crisis linked to the dependence of the UK on imported gas (e.g. Department of Trade and Industry 2003). Official definitions of national need reflected assumptions that the country would experience continually-growing demand for gas and other resources (Marshall 2011). In the first years of the 21st century, two consortia of petrochemical companies submitted plans to build LNG terminals at sites around Milford Haven in West Wales in response to policy signals regarding future demand for gas. NG signed contracts with these consortia that imposed upon it an obligation to provide infrastructure to connect these terminals to the UK National Transmission System (NTS) at a site across the English border in Gloucestershire. The pipeline to connect the Milford Haven terminals to the NTS would be of unusually large diameter (1220 mm, 48 inches) and run at a pressure higher than usual for the UK NTS (94 rather than 75 barg). The pipeline construction work comprised two phases (see Figure 1). Phase 1 ran from Milford Haven to Aberdulais, with a length of 120 km (75 miles), and Phase 2 ran from Felindre to Tirley, being 196 km (122 miles) long. The pipeline fell outside the scope of powers granted to the Welsh Assembly in the 1998 Government of Wales Act. Our research into how communities experienced the planning process for the pipeline took the form of a series of 17 semi-structured interviews during 2007-09. Studying the impact of network infrastructure like pipelines presents particular methodological difficulties. In order to provide as comprehensive a picture as possible of concerns along the route, interviews

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were conducted with representatives of various campaign organisations from flash-point sites along the full length of the pipeline, including Safe Haven (Milford Haven and Waterston, the sites of the two terminals), CRA (Cilfrew Residents Association, concerned with a pressure reduction station), CRAG (Cwmtawe Residents Action Group, at Trebanos, concerned with Phase 1 of the pipeline), a looser group centring on Brecon and Hay-on-Wye (concerned with Phase 2) and CAPRI (Campaign Against the Pressure Reduction Installation, at Tirley). Participants were selected using a snowballing method (Bryman and Bell 2007). Interview material was transcribed, coded and qualitatively analysed with NVivo 8 software to identify and compare community concerns and how campaigns (and their primary concerns) developed over time. Secondary materials were also used to help construct a timeline of events. These included press reports, publications and press releases from NG, its contractors, and the Milford Haven Port Authority, and planning documents. Case development also drew on research undertaken on the impacts of LNG in West Wales by one of the authors for Pembrokeshire Business Initiative during 2007 (Bryan and Munday 2007; Bryan et al. 2007).

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Figure 1: The South Wales Gas Pipeline, Phases 1 & 2 Initial stages and early conflicts Interviewees in Milford Haven, a town with a long history of petrochemical infrastructure development, reported first being informed of the LNG terminal projects via exhibitions held in the town during 2004, at least a year after the planning proposals had been submitted to Pembrokeshire Council. They reported that local people had not being given any opportunity

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to comment on the applications during the period prior to this, when the proposals were being considered by the LPA (Interviewee, Waterston, 31 July 2008). Concern began to crystallize around how the risks of allowing LNG tankers into the narrow and busy Cleddau estuary had been assessed, particularly following the Sea Empress disaster in 1996. Unsuccessful requests to the terminal consortia and to Milford Haven Port Authority (MHPA) for risk assessments in November 2004 resulted in a court case being brought by the members of what would become the Safe Havens campaign group to compel MHPA to release the relevant information. This case was unsuccessful, largely because the request had come too late in the planning process for the release of the information relevant to make a difference: theyve spent millions of pounds, therefore youve lost your window of opportunity (Interviewee, Milford Haven, 23 July 2008). Safe Havens felt that the proposal had, thanks to concerns about energy security, too much momentum and that Milfords existing concentration of heavy industry had made it the ideal destination for the terminals, despite international best practice recommendations on LNG facility siting recommending that they be sited offshore (Interviewees, Milford Haven, 23 July 2008, and Waterston, 31 July 2008). When risk assessment information was made available, after a ruling against MHPA from the Information Commissioner, the content was felt to be generic rather than specific to the conditions in the Cleddau. Attempts to persuade the Welsh Assembly to intervene were unsuccessful, an experience shared by Welsh campaigners against the pipeline later on. Although the Assembly has no powers regarding strategic assessment of proposals of this kind, it was a statutory consultee in both cases, and some interviewees expressed surprise that it had not objected on the grounds of the Welsh Assembly Governments obligation to promote sustainable development (Interviewee, Cilfrew, 22 July 2008). For its part, NG submitted planning proposals for the two phases of the pipeline in 2004 in line with the requirements of the Public Gas Transporter Regulations 1999 (subject to deemed consent rather than to the TCPA). In its proposals, it justified the pipeline by invoking an energy security national interest argument, buttressed by demand forecasts. In addition, it stated the pipeline was also necessary for it to fulfil its public service obligations under the Gas Act 1986 to maintain efficient and economical gas supply infrastructure. This second argument concerning public duties resurfaced at subsequent planning inquiries alongside invocations of national interest. The relationship between these duties and NGs private interest in fulfilling the contracts it had signed with LNG importers to finish the pipeline by early 2007, would prove of particular interest to campaigners. To what extent, campaigners would ask, were the criteria of efficient and economical an adequate way of understanding NGs public duty, given that the fulfilment of private contracts for completion by a certain date would determine how efficient and economical the infrastructure would be. Campaigners were suspicious that consultation was kept to a minimum as a way of avoiding siting conflicts and thus reducing commercial risk. The possibility of conflicts of interest ran alongside a lack of incentives for NG to promote participatory engagement. Research suggests that energy infrastructure companies tend to view consultation as primarily one-way and informational (Barnett et al. 2012). Network infrastructure, such as pipelines or overhead power lines, which connect together multiple sites, presents particular practical obstacles for public engagement. In such cases, researchers have also documented assumptions held by developers about the publics inability to take the strategic view necessary for looking at the network as a whole (Cotton and Devine-Wright 2010a). The process of impact assessment and route choice for the two phases of construction provided the first opportunity for opposition to the pipeline to crystallize. During 2004-05, NG provided assessments of the viability and impact of a number of potential offshore and onshore pipeline routes. Following the granting of consent for Phase 1 in December 2005, the

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selected route options for Phase 2 produced significant controversy. At this stage, the DTI sought responses from statutory consultees, including relevant regulatory bodies, LPAs and businesses. The Brecon Beacons National Park Authority, from the outset, took a strongly critical stance towards any route through the Beacons. In responding to NGs proposals, the BBNPA noted that (a) the route choices, (b) the judgement that a pipeline connecting Milford Haven to the NTS was necessary for NG to fulfil its public obligations and in the wider national interest, and (c) that a pipeline of just this specification was in the national interest and required by NGs public obligations were all questionable. It suggested that it was for the DTI to provide its own independent judgement on these issues, preferably by means of a strategic environmental assessment of the whole project and post-privatisation governance (BBNPA 2005a, b). The objections put forward by the BBNPA exploited its position as a statutory consultee by seeking to establish a link between the potential harmful impacts of NGs specific proposals and what it saw as illegitimate policy priorities. In doing so, it presented a strategic critique of the pipeline project as a whole, rooted in its assessment of impacts on its locality. NGs statement of need was interpreted by BBNPA as being in conflict with its public duties under the Governments planning guidance on sustainable development (ODPM 2004). This was because a conflict of interest was perceived within the very choice of a predict and provide methodology for assessing national need, given that NG also had a commercial interest in stimulating gas demand (BBNPA 2005b, p. 6). Indeed, a subsidiary part of the case for new infrastructure was that it would aid development and [] give opportunities for industry and users of gas to create business opportunities (BBC News 2006). Further, the argument from need did not acknowledge concerns first voiced in the late 1990s that increasing demand for gas might create infrastructural path dependencies that could decrease energy security (Sadler 2001, p. 14) and that demand should be managed rather than met. BBNPAs argument was thus that the national need case for a pipeline was questionable, but also that no national interest case could be made for any particular route. Further, it argued that there was a clear alternative definition of the national interest: protecting National Parks held in trust for future generations, and driving energy infrastructure development faster towards better use of renewables (BBNPA 2005b). The strategic arguments first put forward by the BBNPA were subsequently employed by the various campaigning groups who became active along the length of the pipeline, as they began to coordinate and share information, thus allowing each group to create a strategic position on the need for the pipeline as a whole which shared key feature with those developed by other community groups. By the middle of 2006, Safe Havens had been joined by four other campaign groups. Cilfrew Residents Association (CRA) and Campaign Against the Pressure Reduction Installation (CAPRI) in Tirley were concerned with proposals for gas re-pressurization installations (PRIs) which, unlike the pipeline itself, fell under the TCPA and were subject to normal planning consultation processes. The PRI in Cilfrew was part of Phase 1 of the pipeline, while that at Tirley would connect Phase 2 to the main UK NTS. Cwmtawe Residents' Action Group in Trebanos (CRAG) and a looser group of campaigners around Brecon and Hay-onWye were concerned about issues relating directly to Phases 1 and 2 of the pipeline respectively. In each case, interviewees reported that the groups had organised themselves in response to what they felt was a failure on the part of NG to consult adequately, and in particularly, a failure to involve communities in impact assessment processes. In early 2006, CRA established that the PRI environmental impact assessment NG had submitted was for the wrong site (Interviewee, Cilfrew, 22 July 2008), which required a resubmission. When the LPAs planning committee approved the proposal in September

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2006, four councillors who had met CRA were excluded (Harris 2007). On the basis that this had violated procedure, CRA applied for a judicial review of the grant of approval, which they won in March 2007. The proposal was voted on again in May of that year and approved, despite continuing and largely unanswered representations from CRA regarding its social and environmental impact (Interviewee, Cilfrew, 15 October 2008). In Trebanos, CRAG discovered in June 2006 that NGs contractors intended to use blasting as part of the Phase 1 construction, following an exhibition on 5 and 6 June. CRAG objected to the blasting taking place, on the grounds that the pipeline route took it close to peoples houses, as well as through an area historically affected by subsidence and by unmapped mine workings where laying of mains gas pipes was not permitted (Interviewee, Trebanos, 25 October 2008). In addition, they discovered that planning permission from the LPA was needed, and had not been granted (Harris 2007). Following a failure to get the Welsh Assembly to intervene, the group succeeded in getting the LPAs planning committee to vote at the end of August on the blasting, which since 8 June had been taking place without planning permission. However, like the Cilfrew planning committee vote, this was also subject to procedural irregularities (Interviewee, Trebanos, 30 July 2008; Harris 2007). Thereafter, they contacted an environmental group called Rising Tide and independent activists from Newport and Cardiff, who in November 2006 organised direct action protests. Subsequently, on 22 November, the DTI contacted NG and CRAG to announce that permission to blast had been denied. Pipeline Phase 2 and the Gloucestershire PRI Phase 2 of the pipeline was given consent on 7 February 2007. The decision to grant consent drew on the application of the Silkin Test, a planning criterion set out in 1949 by Lewis Silkin MP, designed to balance the national need for certain developments against the localized impacts of such developments in national parks. This set out that development must be in the national interest and minimize damage to the park, and that no practical alternative to must exist. In applying the Silkin Test, the Secretary of State identified the national interest with the public duties of NG. The judgement stated that it was desirable that the proposed pipe-line works should be carried out in the interests of the development and maintenance of an efficient and economical system for the conveyance of gas [...] (DTI 2007, pp. 5-6) The BBNPA had suggested, as noted above, that the statement of need put forward by NG conflated its public duty, the predetermined national interest in meeting gas demand, and the private obligations NG bore to gas importers with whom it had signed contracts to complete the pipeline by a particular deadline. The decision to grant consent did not address this point. The BBNPA had also objected that the assessment regime for the project had been deficient, insofar as no high level strategic assessment had been undertaken by the DTI on the impact of gas infrastructure development across South Wales, and indeed, of the broader impact of the marketised modes of energy need and risk assessment that had emerged under privatisation. The DTI ruled against this objection, noting that the governments role in relation to gas infrastructure was not one of centralised strategic direction or installation development, and that the DTI managed only a reactive, project-oriented handling system (DTI 2007, p.3) for consents. Following Phase 2 consent, campaigners increasingly began crossing scales, by questioning in public the strategic social priorities behind the project as a whole at the same time as

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linking local impact concerns across different sites, and bringing together issues of safety and environmental risks from different localities which crystallised concerns about the haste with which the SWGP was being constructed, allegedly under commercial pressure. These efforts began largely with campaigners in Tirley and Brecon who, with assistance from civil and retired pipeline engineers living in their respective communities, began asking a series of technical questions about the safety of the pipeline. As had been the case at Milford Haven, campaigners expressed concern about the generic content of risk assessments. A brief document, relating to the pipeline itself (as opposed to the PRI) was submitted by NG as part of its planning application at Tirley (McCollum 2006). This document was criticized for failing to include actual calculations and to set out its assumptions, which campaigners felt suggested it had been prepared at head office rather than by someone with direct knowledge of local conditions which might affect the assumptions behind the analysis (Interviewee, Tirley, 24 July 2008; two interviewees, Brecon, 29 July 2008). Technical information on failure risk and what were felt to be unaddressed uncertainties were circulated between CAPRI, the Brecon group, CRAG, CRA and Safe Haven at a series of meetings involving two or more of the groups during 2006. The rationale behind the increased 94 barg operating pressure of the pipeline was subsequently widely questioned. It was suggested that the increase in pressure resulted in a significant and exponential reduction of the pipelines operational safety margin, but that it also increased gas flow rate substantially (an important commercial consideration). The strategic viewpoint adopted by campaign groups therefore focused on an alleged tradeoff between commercial interests (as distinct from the national interest) and the impacts on affected communities. In Tirley, an additional localised focus for objections was the environmental impacts of the proposed PRI on a historically unspoilt location. As with the generic nature of risk assessments in Milford Haven and at Tirley, the difficulty of obtaining information on these impacts was felt to reflect what we have referred to above as the re-centralisation of decision making after privatisation: as a result of planning and operational decisions being taken by NG at their headquarters in Warwick, and communications being run by the companys public relations staff in London, the company were not on the ground throughout the planning and construction process (Interviewee, Brecon, 19 November 2008). Subsequently, the PRIs environmental impact assessment was submitted late. When it was made available, part of its case for siting the PRI in this location was that the specific choice of site was represented as being in the national interest. CAPRI solicited over 1600 written objections to the proposal. A key point made by a significant number of objectors, as well as by CAPRI itself, was that, while it might be true that a PRI somewhere (to reduce gas pressure enough for it to flow into the NTS) would be in the national interest, placing it in one precise location could not justifiably be said to be. At Tirley, what Owens (2004) describes as the it has to go somewhere dynamic of the planning cascade became it has to go here. A direct, and to campaigners inexplicable, connection was made between the national interest in energy security and positioning a PRI in a specific field in Gloucestershire. Alternative sites were available, in particular near an existing PRI 40km away. Consequently, environmental impacts and safety risks associated with this site should not simply be traded off against the national interest, and the need for a PRI at Tirley should be assessed primarily against social and environmental considerations. The LPA agreed, and refused planning permission on the grounds that the environmental impact of a PRI at Tirley had been underplayed in NGs EIA, and would be too significant, given commitments in the LPAs LDP to preserve the integrity of the area.

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NG appealed. A planning inquiry was held in April-May 2007, at which the national interest argument for the Tirley site was reiterated (RPS Planning 2007). This inquiry upheld the LPAs decision, and refused the appeal, a decision ratified by the Secretary of State in December 2007 (Plummer and Mellish 2007). This decision denied validity to NGs assertion that granting planning permission for one specific location was in the national interest, and advised other locations should be examined. A planning application for a new site, which fell within neighbouring Tewkesbury Councils jurisdiction, was submitted in December 2008. Following another campaign by CAPRI, the council refused permission in February 2010, leading to another appeal and a further planning inquiry in July of that year. This time, the Secretary of State followed the recommendations of the planning inspector by granting planning permission. During the Tirley campaign, after the terminals, pipeline phases 1 and 2, and the Cilfrew PRI had all been consented and (mostly) constructed, the national interest and public duty arguments advanced by NG for the pipeline and associated infrastructure were finally subjected to intensive public examination on the basis of strategic arguments first articulated by the BBNPA and developed, in relation to local risks, by a campaigners network that extended the full length of the route. Nonetheless, the 2010 inquiry inspectors report stated that to serve national need, NG should carry out its licensed and contractual obligations to supply gas at the required higher volume and pressure through the pipeline, thus requiring the PRI (Tester 2010, pp. 87-88). Discussion The SWGP case, we suggest, has to be understood as a series of siting conflicts which emerged, in the first place, from repeated failures to facilitate early engagement, but which were driven by a systemic lack of opportunity structures for effective engagement. Consultation by the TNO over its strategic plans seems to have shared shortcomings with the efforts of the Milford Haven terminal developers: community campaigners reported these being partial, often late, and non-inclusive, with NG subsequently being found unresponsive and even obstructive by some. Following Freudenberg and Pastors (1992) recommendation that siting conflicts be considered as, essentially, systemic products, we would suggest that the possibility of effective engagement may be undermined by, first, the structures of governance that shape policy, and second, the planning system through which infrastructure proposals pass. We described the neoliberal de- and re-centralization of energy policy and infrastructure development as a key development through which the opportunity structures for effective engagement are restricted. By effectively black-boxing the mechanisms through which national energy needs and appropriate policy responses are assessed, these adjunct processes of privatisation make substantive, participatory reflection unlikely if not impossible. In addition, re-centralisation may lead to materially worse impact assessment procedures, and communication difficulties, as described by interviewees at Milford Haven and Tirley. Again and again, the campaigns around the SWGP sought to open up these processes to scrutiny, to repoliticise processes which, having been framed as technical operations of risk analysis and management carried out by new centres of calculation, had become depoliticised, administrative processes. Safety and environmental risks were used to open up reflexive links between local impacts and the justifiability of national policies. More importantly, they were used to reframe the nature of the planning conflict. Campaigners suggested that the question of unacceptability would appear in a different light if the focus moved to the strategic conflict surrounding the pipeline. They essentially argued that this was

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not between a fixed national interest and local interests. Instead, it was between the role of essentially unaccountable, private commercial interests in shaping the national interest, and the proper contribution which diverse localised community interests (in place, amenity, safety etc.) could make to shaping assessments of national need. Arguments about commercial versus community interest first emerged in the BBNPAs criticisms of NGs choice of route for Phase 2, which, interviewees attested, subsequently became a key reference point for campaigning (Interviewee, Gorseinon, 30 July 2008). They managed to go far beyond a focus on amenity and safety to question the legitimacy of highlevel governance mechanisms such as the capacity auctions on which future planning proposals and the private obligations entered into by privatised energy utilities are dependent (Brecon Beacons National Park Authority 2005b; Tester 2010). Instead of accepting the it has to go somewhere framing of the planning cascade and the attendant trade-off between national and local interests, campaigners questioned the assumptions about social priorities and legitimate expertise which allow such a trade-off to be constructed at all. They asked for opportunities to represent different conceptions of national interest, such as might be rooted in the kinds of often intangible and non-quantifiable values held to be the rightful concern of stewardship organisations like the BBNPA (Interviewee, Hay-on-Wye, 28 July 2008). However, the successes achieved by campaigners were mainly at planning inquiries where the main issues were ones of environmental impact to be resolved under the TCPA. Although campaigners succeeded in ventilating strategic issues, the key points of contention which they were forced to address were, in the end, ones traditionally encountered at the far end of a planning cascade, i.e. whether a particular site was acceptable. Overall, the SWGP case is an example of how major infrastructure proposals were handled under the TCPA and deemed consent system. How might the 2008 Planning Act and subsequent developments have altered things? Is there any possibility that they might have instituted new opportunity structures within which local interests in impacts could cross scales and produce strategic reflections on the relationship between proposals and policy? As noted previously, there is much uncertainty in this regard. Nonetheless, there are reasons to remain sceptical. On the one hand, since 2008, NG has demonstrated different approaches to public engagement in early and wide consultation on strategic infrastructure route options in relation to overhead lines although these approaches may still be based on traditional developers assumptions about the public (Cotton and Devine-Wright 2012). On the other, the strategic need for large projects is still settled, after the 2008 Act, in a way which promises to reproduce planning cascades. NPS present certain forms of facility as desirable in a way which is enduring, a priori to, and largely insulated from concerns about the environmental consequences that may arise from individual projects (Cowell 2012), and retain the same role for some privatised centres of calculation (such as NG) in shaping policy as existed in the days of JESS (DECC 2009, p. 11). The 2008 Act was supposed to allow Parliament more say on the content of statements on national need. Nonetheless, critical comment from MPs on the six approved energy NPS (approved in July 2011) produced only a limited number of caveats. Interestingly, these echoed the worries about gas contributing to energy insecurity registered by Sadler (2001), as well as the BBNPAs criticisms of new infrastructure as increasing rather than simply meeting demand a perverse impact of a new dash for gas (ECCC 2011, p. 84). Furthermore, the creation of a new centre of calculation by the Coalition (a special unit within the Planning Inspectorate, to replace the IPC), is likely to exacerbate concerns about transparency rather than reduce them.

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Conclusion In this paper, we began with the tension between two tendencies within contemporary neoliberal societies: increasing use of participatory governance, and developments that entrench risk thinking in new centres of calculation. We examined how this tension plays out within a specific case study, originating within a privatised energy industry that has been used as a template for international energy governance by development organisations like the World Bank (Guy et al. 1999, p. 161). This case shows how siting conflicts within neoliberal systems of governance may centre on clashes of interests that are not reducible to national need and local concern. If the need for participation is a legitimate need, then it requires, we would suggest, procedurally fair implementation which focuses on substantive concerns, including such conflicts of interests. What the SWGP case demonstrates is that, in systems of governance where power is redistributed, to some degree, to private organisations with public duties, the accountability of these organisations in assessing need and managing risk must be included in the substantive issues participation considers. We therefore concur with recent scholarship (Cowell and Owens 2006; Cotton and Devine-Wright 2010a; Cotton and DevineWright 2010b; Cowell and Owens 2011; Cotton and Devine-Wright 2012) which suggests that questions of national interest are likely to continue to prove their importance in shaping infrastructure siting conflicts. The interaction of the planning system with the assumptions and storylines (such as the centrality of risk management to governance, and the priority of energy security) through which governance is framed by the executive emerges as a key theme for further research. It is through these interactions that opportunity structures for effective, i.e. substantive participation will be shaped. The implementation of effective participatory governance faces serious obstacles, both in continued efforts to streamline planning systems (as per the 2008 Act), and in the potential for conflicts between the private obligations of private companies like NG and their public duties. Issues of commercial confidentiality, for example, particularly with respect to supply contracts, proved an obstacle to campaigners in the SWGP case seeking information about the case for national need. With such issues in mind, it is not enough to call for early and wider consultation. It is necessary to recognise that the evolution of governance under neoliberalism requires forms of engagement which address both the redistribution of power to which this evolution has led, and the continuing possibility of conflicts between private commercial interests and community interests over how the national interest, and its relation to planning, is shaped. References Adam B and Groves C, 2007, Future Matters: Action, Knowledge, Ethics (Brill, Leiden) BBC News, 2006, New pipeline 'will aid industry', 17 July, http://news.bbc.co.uk/1/hi/wales/south_west/5181336.stm Barker K 2006, Barker Review of Land Use Planning. (HM Treasury, London). Barnett J, Burningham K, Walker G and Cass N 2012, Imagined publics and engagement around renewable energy technologies in the UK. Public Understanding of Science 21(1), pp. 36-50. Bond A, Palerm J and Haigh P 2004, Public participation in EIA of nuclear power plant decommissioning projects: a case study analysis Environmental Impact Assessment Review 24(6), pp 617-641 Brecon Beacons National Park Authority (BBNPA), 2005a Response to South Wales and the West Reinforcement Pipelines Route Corridor Investigation Study (RCIS) Report (BBNPA, Brecon) Brecon Beacons National Park Authority (BBNPA), 2005b, Statement of Objection by the Brecon Beacons National Park Authority to the Department of Trade and Industry (BBNPA, Brecon)

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