Living with Uncertainty

Chris Groves on the community impact of liquid natural gas (LNG) in south Wales
In the siting of potentially hazardous or polluting infrastructure, a central issue is how the benefits and costs that come with it get distributed. Is it fair, for example, that people in one locality should bear the risks associated with a dirty production process while others reap the benefits? Where the siting of energy infrastructure is concerned, the answer may be less obvious. Surely everyone benefits from the supply of electricity or gas? And in the contemporary world, security of energy supply is surely of national importance? So isn’t it a reasonable trade-off to expect someone, somewhere to bear the costs? However, things are not this clear-cut. The siting of a new energy plant does not happen in a historical vacuum. For example, it has long been recognised that patterns of development tend to locate polluting industries and potentially hazardous infrastructure within materially, socially and environmentally deprived areas. Faced with economic and social inequality, which may include pockets of intractable poverty and chronic ill-health, local government often finds it difficult to refuse inward investment and the promise of jobs, however they are being provided. One might think of Teesside and Cumbria in England, or the Valleys, Anglesey and Pembrokeshire in Wales. Patterns of development in Milford Haven and Neath Port Talbot attest to this law of attraction. As the sociologist William Freudenberg once remarked, it is remarkable how often technical planning criteria tend to be satisfied “on the poor side of town”, leading to inequitable concentrations of risk. If long histories of social injustice lie behind some individual siting decisions, then this brings in another, moral issue: if siting decisions imply questions about the distribution of costs and benefits (“who gets what”), then they should also force us to ask whether people have been given the opportunity to consent to bear the costs (including risks) imposed through the planning process (“who decides who gets what”). We can draw an analogy with medicine:

Planning and Protest when informed consent is sought for an operation, this (at least in the USA) means that significant risks associated with the procedure to be performed should be fully and transparently disclosed. The planning process is similarly intended to allow social and environmental impacts, including risks, to be disclosed and debated. However, a problem inherent in discussions of risk is that risk assessment, although it draws on applied scientific knowledge, cannot command the kind of consensus that scientists strive for — even though quantitative estimates of risk are often treated by policy makers and the media as objectively valid statements. Risk assessment is not an objective enterprise, it always involves value judgements about what risks are important, what kinds and levels of risk are tolerable, and what uncertainties still exist once known risks have been catalogued. This means that, in the words of the philosopher Kristin Shrader-Frechette, the main questions to be asked are not “What are the probabilities?” but “[h]ow objective is objective enough? How certain is certain enough? How just is just enough?” Consequently, if we’re going to ask whether those affected by a siting decision have had a fair chance to give or withhold their consent, then we also have to ask another question: has a consensus been arrived at as to whether a given project may bring with it significant risks? It’s true that arriving at such a consensus may be very difficult. There are limits to how far the risks of any given activity or decision can be scientifically understood, just as there are limits to scientific certainty in general. And on whether a given risk — or unquantifiable uncertainty — should be accepted or rejected, science has nothing to say, this remains a moral and political question. Early and wide formal consultation might help in making possible some form of democratic agreement on how acceptable are the uncertainties and risks of a given siting decision, but such a process would have to include transparent disclosure by operators and regulatory agencies of known risks, of the current limits to knowledge about risks, and in addition an honest discussion of potential benefits. Unfortunately, the planning system in Wales, and indeed in the UK, tends to hinder rather than help any such process of fully democratic consultation. In the summer of 2008, I conducted a pilot study in south Wales to prepare the ground for a future study of the role which an absence of consultation, consensus and consent plays in producing planning conflicts. This consisted of 13 semi-structured interviews with people from communities across south Wales and Gloucestershire since 2005 who had been involved in a range of different campaigns against the building of the 316-kilometre long underground gas pipeline that runs from new LNG terminals in Milford Haven to Trebanos and Cilfrew near Neath, through the Brecon Beacons, past Hay-on-Wye, all the way to Tirley in Gloucestershire.



Living with Uncertainty These campaigns had been conducted variously against the siting of the terminals themselves in Milford, against the routing of the pipeline, and against the siting of various pieces of above-ground infrastructure required by the pipe. They drew on concerns raised by professional engineers about the actual construction of the pipeline, in several localities along its length, which had given rise to doubts about its long-term safety. A common factor that emerged was how those involved had experienced the impact of uncertainty on their lives, and how this led them to campaign for a full discussion of vital concerns surrounding the siting decisions that had, in their view, been left unaddressed. In each case, the speed with which decisions had been taken was viewed as having prevented this kind of debate happening. In the absence of full consultations, there could be no public consensus on the acceptability of the new infrastructure, independent of the claims of the companies responsible for building it. And without such consensus, it could be argued that no consent to bear risks had been given. The stories I heard showed how people had made considerable efforts to understand the range of potential impacts associated with the infrastructure projects. As they had collated a wide range of sources of information, their anger at what they saw as a lack of transparency on the part both of private companies and public authorities had increased. Interviewees recounted how, as attempts to resolve the uncertainties surrounding the projects came to nothing, they and their friends, families and neighbours felt increasingly betrayed by local authorities, government agencies and the Assembly and Westminster Governments. The legacy of these experiences was described in terms of lingering doubts, and in many cases fears, regarding the safety and security of the interviewees’ physical and social environments. In places which in many cases already suffered significant economic, social and environmental deprivation, the experience of having additional uncertainties imposed from outside created a strong sense of fear, vulnerability and injustice. Furthermore, it brought into sharp focus for several interviewees (who used Aberfan and Tryweryn as examples of past betrayals) the distance between local communities and Cardiff Bay on the one hand, and between Wales and Westminster on the other. In every case but two, the stories I was told began with instances of the coming development being noticed too late to make a difference. Where major installations were concerned, I heard various accounts of one-way communication from company representatives after planning decisions had already been taken, presenting the coming infrastructure as a fait accompli. In places like Cilfrew, where above-ground gas stations fell under the Town and Country Planning Act, people described being told by a friend or neighbour about a planning notice tucked away in the local paper, or displayed on a lamppost. National Grid, the private company with re-

Planning and Protest sponsibility for UK gas and electricity transmission infrastructure, is responsible for building the pipeline. The two terminals are owned and operated by two separate consortia consisting of Exxon Mobil, QatarGas and Elf on the one hand (South Hook LNG), and BG Group, Petronas (Malaysia) and 4Gas (Dragon LNG). People described to me with wry humour experiences of how these companies had dealt with the public: one woman pointed out that when her local council resurfaced the road in her street, she and her neighbours had each had three letters informing them about it, but when, as she learned “by accident”, a high-pressure gas pipeline was to be built close by her community, she received nothing. Although various local authorities and other bodies were, as statutory consultees, contacted before planning permission was granted for the terminals and the two phases of the pipe, this did not mean that any information or consultation opportunities were ever provided to members of the communities where the infrastructure would actually be sited. One respondent contrasted his experiences with the example of the Beauly to Denny overhead electricity transmission line in Scotland, which was opened up for full public consultation long before it reached the construction phase, and as a result of objections received, referred to a full public enquiry. This failure to consult was noted back in 2006. Gillian Bristow, writing in the Insitute for Welsh Affairs’ magazine Agenda, pointed out that without such consultation “the concerns and fears of the local community are unlikely to be assuaged”. It also formed one of the key points of an article by John Harris in The Guardian in early 2007, one of the very rare mentions these “national interest” projects received outside the Welsh media. That these concerns had, indeed, not been assuaged was borne out by interviewees from Milford to Tirley. They recounted how they had grown increasingly concerned at a number of uncertainties which they felt had not been properly addressed within the planning process. The apparent reluctance of the Milford Haven Port Authority (MHPA) to release documents relating to marine traffic risk assessments, was coupled with what were felt to be incomplete and misleading statements from the Authority and terminal companies about scientific uncertainties surrounding LNG safety. The possibility of a gas cloud igniting following a possible spill on water, and the catastrophic consequences of such an incident, had not, they felt, been honestly and transparently discussed by MHPA or the terminal companies. In Neath Port Talbot, people in Trebanos became concerned about the mineworkings, some mapped and others not, honeycombing the mountains around them. The pipeline, in some cases laid a matter of metres behind their homes, was going to run through an area known locally for subsidence. In Brecon, carefully-researched enquiries about the op-



Living with Uncertainty erational uncertainties surrounding the safety of what, for the UK, was an unusually high pressure gas pipeline failed to produce answers that satisfied locals. In Tirley, repeated enquiries about the risk assessments supporting the planning proposal for an aboveground gas installation (AGI) failed to yield anything beyond very general statistics about pipeline safety. Indeed, one interviewee informed me that when a barrister at a planning enquiry in the Forest of Dean — which led to planning permission for the AGI eventually being refused — asked to see a copy of the original risk assessment, it “proved impossible to locate it”. Having been denied the opportunity to construct a complete public picture of the possible risks surrounding the new infrastructure, several people talked of the thirty-year lifespan of the pipeline as promising a period of extreme insecurity for their communities. They described how their attempts to get these concerns acknowledged and discussed met with intractable institutional obstacles — particularly from local government. People described gradually coming to feel a sense of exclusion from bodies that were supposed to represent their interests. In Neath Port Talbot, National Grid’s attempt to use explosives to blast in and around Trebanos led to a now infamous council meeting at which the plans were defeated by 14 votes to 12, only for an official to announce that there had been a “counting error”, rendering the decision invalid. Later, in Cilfrew, a council meeting on a proposed AGI resulted in some councillors, who had met with local residents being excluded under the “prejudicial interest” rules of the Local Authorities Order 2001. At a later court case which overturned the decision from this meeting, as John Harris noted in The Guardian, the presiding judge remarked that “it is a wonder that anybody votes on anything”. A sense of being unable to trust elected representatives to look after their safety was recounted to me by interviewees. As one put it, the expectation that “if someone is doing something bad to your area, you go to your councillor and your councillor will fight for you” had been completely undermined. Contacts with members of the Assembly proved equally exasperating, as attempts to get the projects “called in” for official review were rebuffed. People described how, as time went on, their daily lives were disrupted in unforeseen ways by the construction projects and by the unresolved uncertainties about their long-term impacts. Communities were split, the character of villages destroyed by construction traffic, and people’s feelings about their own homes changed in response to what one interviewee described as feeling that there was a “bomb in the back garden”. Others described the loss of traditional access routes to the open landscapes of the Beacons: “We used to go up there, and it’s God’s own country, you look out and you can see nothing, only mountains all the way across to Brecon. That’s been totally destroyed.” The value of such

Planning and Protest access should not be underestimated, especially in communities marked by decades of economic inequalities, belying common assumptions that “the environment” is a middle-class concern: “We’ve never had anything, the only thing we’ve ever had is the fact that we’re rural, that you can walk outside your door and you’re in country, you’re in total country”, as one interviewee put it. Where imposed uncertainty exists, vulnerability exists. Whether interviewees were describing an ineradicable sense of lurking threat, or the forcible closing-off or destruction of the significant environmental reference points which give a community its unique sense of place, narratives were generally marked by expressions of chronic, ongoing vulnerability. This was more evident in the case of interviewees from communities around Milford and in Neath Port Talbot, where a history of varying degrees of social and economic inequality may be a factor. Nonetheless, it was striking how far the experience of vulnerability described to me echoes the kinds of experiences recorded by sociologists and social psychologists like Michael Edelstein and Kai Erikson within communities in the USA that have suffered toxic contamination. This research shows that the effects of living with uncertainty caused by invisible threats and the associated community disruption can damage both the tissue of individual lives and the social bonds on which communities depend. Having to live with questions about risk that have not been satisfactorily resolved, and with a loss of faith in the capacity of social institutions to help, can have a traumatic and corrosive effect. Such lingering vulnerability, in the apparent absence of any possibility of redress erodes, as the American research makes clear, the confidence of people in their ability to determine their own futures. In localities that both suffer restricted economic opportunities and continue to attract disproportionate amounts of industrial infrastructure, from Milford Haven to Crymlyn Burrows, from Wylfa to Merthyr Tydfil, the long-term social consequences of leaving such social injustices uncorrected should not be underestimated. If people have vulnerability imposed on them, then whether they can bear this often depends on whether a consensus can be reached on any benefits which may come as a result. Where benefits are dubious, then vulnerabilities are inevitably far more difficult to put up with. It is significant, then, that their awareness of uncertainties surrounding the safety and impact of the projects led people on to broader reflections about exactly why the terminals and pipeline were said to be necessary. People found themselves asking whether the projects could indeed be justified in terms of the “national interest”, as the companies involved, the Assembly Government and the then DTI insisted. Some interviewees noted WAG’s legal commitment to sustainable development, and questioned whether the CO2 reduction targets of both the Wales and UK Governments could be sustained against the backdrop of what they saw as a new



Living with Uncertainty commitment to dependence on fossil fuels, with potential future shortages in LNG supply due to growing worldwide demand being cited by several. In contrast with the alleged uncertainties associated with relying on Russian gas, many saw much more intractable problems with relying on the whims of a global gas market. These broader reflections recall environmental sociologist Susan Owens’s observation that planning conflicts are often not motivated by NIMBYism, but concern, rather, the purposes for which the planning system is being used and the ultimate priorities behind them. Not only did interviewees express a loss of trust in the institutions they had hoped would directly represent their interests, but they could not understand why the UK and Welsh administrations would treat projections of an inexorable increase in demand for fossil fuels over the next decade to fuel “economic growth” as an expression of a vital societal need, rather than a tendency which, in the light of other claimed priorities, might have to be managed or constrained. The story of the Milford Haven terminals and gas pipeline remains unfinished. Petitions to the European Commission for a review of the projects (possibly leading to legal action being taken by the EC against the UK Government), supported by the Plaid MEP Jill Evans, remain to be settled at the time of writing. The siting of an AGI near Tirley awaits a decision in July, following successful campaigns by local people. But this unfinished narrative also opens up several pressing questions: about continuing deficits of environmental and social justice, of just what self-determination is to mean for a post-devolution Wales, and indeed of whether questionable assumptions about the “common good” both underlie and are promoted by the UK planning system. There are several issues that any response to these questions will have to consider. The record of senior Welsh Labour involvement in the story of the pipelines and terminal may turn out to be hard for Welsh politicians to escape in the future. But beyond any electoral consequences, the debate about what influence a devolved Wales has on the energy pathways it will follow remains urgent, particularly in the face of the approval by Westminster of, first, an 800MW gas fired power station at Uskmouth, and more recently a 2000MW station at Pembroke that will produce around 6 million tonnes of CO2 per year. How and why the UK planning system, even after the supposed demise of the ideology of “predict and provide” in the early 1990s, continues to reflect largely unquestioned policy priorities needs to be addressed as part of this debate, particularly with the 2008 Planning Act now passed by Westminster, and the prospect of a still more centralised approach to “national interest” planning in the offing. And then there is the question of how to rebuild a connection between consultation, consent and justice at the heart of policy. What the risks, uncertainties and benefits

Planning and Protest of different energy options actually are is an issue which deserves transparent discussion, including full public consultation with concrete and traceable effects on policy. Further, whatever the energy future holds, we cannot move forward by sacrificing the security, rights and needs of already vulnerable communities. If these issues do not move up the political agenda in Wales and the UK, then many more cases like the one I have outlined here await us in years to come, as conflicts over the balance between risks, uncertainties and benefits continue to emerge. Malcolm Wicks, the then UK Energy Minister, opening the (then, as now, still incomplete) pipeline in late November 2007, said that “for the first time, Wales is at the front end of the UK’s gas supply system.” One of my interviewees saw the situation slightly differently: “Wales is being used as an appendage of England for energy infrastructure.”


ESRC Centre for Business Relationships, Accountability, Sustainability and Society (BRASS), Cardiff University, 55 Park Place, Cardiff, CF10 3AT. References: Sven Ove Hansson, “Risk and ethics: Three Approaches” from Risk: Philosophical Perspectives, edited by T. Lewens (Routledge, 2007); Kristin Shrader-Frechette, Burying Uncertainty: Risk and the Case Against Geological Disposal of Nuclear Waste (University of California Press, 1993); Gillian Bristow, “Safe Haven?”, Agenda (Spring 2006, pp. 28-30); John Harris, “How Green Was My Valley”, Guardian (2 April, 2007); S. Owens, “Siting, Sustainable Development and Social Priorities”, Journal of Risk Research 7(2) (2004).