The following opinion has been submitted for the National Rural Area Program (NLPG) . The NPLG is a joint program of the Ministries of Agriculture, Nature and Food Quality (LNV), Infrastructure and Water Management (IenW) and the Interior and Kingdom Relations (BZK). The program aims to restore the balance between people and nature and create sufficient space for living, working and recreation. The opinion has been submitted to draw extra attention to the energy transition.
Utrecht, February 26, 2024. NedZero (formerly the NWEA), gratefully takes the opportunity to submit a view on the NPLG. In this view, NWEA devotes almost exclusively words to what we consider to be shortcomings in the Draft National Program for Rural Areas. This does not alter the fact that we would like to explicitly express our support for the ambition to strengthen nature and rural areas in a broad sense. Apart from the points below, we are also very pleased with the quality of the documents.
Energy transition unrepresented, horizon too close
In the introduction, the NPLG expresses the ambition to create a coherent, area-oriented and adopt a future-proof approach (P.3). But within these three pillars there seems to be a framework that leaves the energy transition underrepresented:
- Coherent: coherence is only sought between water, nature and climate. The energy transition is not taken into account.
- Area-oriented: The provincial area programs are not encouraged by NPLG to make room for wind energy and other forms of renewable energy generation.
- Future-proof: we are surprised at how the concept of Future is operationalized in the NPLG. The medium term is not specified, but the plan already sees 2050 as the 'long term'. This period has been chosen to be very short in terms of sea level rise and climate change. Even a tree planted tomorrow will not yet be mature in 2050.
Better safeguard dual use
Our overarching concern is that the energy transition theme is underrepresented in the NPLG. Energy generation and energy infrastructure are also not mentioned in the 'Wheel of the Living Environment' (PlanMER P. 42). And yet our energy supply clearly requires space, which is often suitable for dual use.
Because of our supporters, we explicitly focus on wind energy but also solar energy,
high-voltage lines and energy storage, the heat and carbon transition and circularity require (more) space and in order to maintain the pace of the energy transition, we believe that this space must be integrally planned in the NPLG.
If this does not happen, provincial area plans will irrevocably clash with, among others, RES 1.0 and 2.0, with plans for strengthening and strengthening the electricity network (including landing electricity from offshore wind), but also with the growing space needs of Defense ( see NRD Defense has need more space ) etc.
“The NPLG itself also focuses on multiple use of space. (P.63)”
However, we largely miss this guidance in the text. In our opinion, the National Rural Area Program could be much more specific about this. An example: on P. 66 it says: “Look for links with other tasks such as housing, energy, recreation, climate adaptation, vitality, work/economic activities, countryside and cultural history, provided that it contributes to the realization of the central
assignment.”
In this way, the principle of duplication of functions becomes optional, meaning that discussions have to be held again and again at area level about “Is X or Y possible here?” We fear that the 'extra function' will too often be seen as 'too difficult', which will cause unacceptable delays, especially for the energy transition (but also for housing construction). It would be much better if the NLPG could provide more guidance in this regard.
A number of suggestions to better safeguard the interests of the energy transition:
- By making it clear that search areas for wind energy, infrastructure and other initiatives in the context of the energy transition may not be eliminated as a result of area objectives formulated in the context of the NPLG.
- By always taking the possibilities for wind energy fully into account when formulating plans. After all, the actual space taken up by wind energy is small in relation to the yield. Between and around windmills, land remains suitable for agriculture, nature, water storage, etc.
The loss of yield from the square meters required for the foundation and the maintenance road to a mill is manageable and is disproportionate to the amount of energy that one modern wind turbine can supply for thousands of households. - By taking birds and bats into account in planning, which will probably adjust their foraging and nesting behavior if areas change in character. It would be tragic if, as a result of area interventions in the context of NPLG, populations were actually more at risk of becoming victims of wind turbines. There is a lot of knowledge and experience available in both the wind energy sector itself and the consultancy firms involved in wind farm plans. We advise them to join provincial planning in a timely manner. The NPLG is the right place to make this recommendation strongly.
- By making an analysis of the NPE (National Energy System Plan) , MIEK (Multi-year Infrastructure Energy and Climate Program) , KEV (Climate and Energy Exploration) , PEH (Main Structure Energy Program) and concretizing their impact/space demand in the NPLG. All these plans are already mentioned in the NPLG; it's just a matter of bringing ambitions together. Not an easy task, so if you want help from NedZero, don't hesitate to ask.
Look further into the future than 2050
Especially for Climate and Water, the future does not end after 2050. Research by the Sea Level Rise Knowledge Program shows that the sea level rise until 2100 will be about 60 to 120 centimeters (300 cm in the worst scenario). This has major consequences for the salinization of soils and, depending on the actual sea level rise, for which soils we can and cannot preserve at all.
A longer horizon offers room for real long-term planning. This reduces the chance that investments will be made in areas that prove unsustainable in the longer term. We would also like to point out that maintaining low-lying areas by pumping out water requires a large and ever-increasing energy demand. This energy can be generated locally using wind energy, creating a clear link between the cultural, social and economic values of the country and the efforts we make to preserve that land.
(Wind) energy and nitrogen, CO2
A wind farm not only emits no CO2 during the operating phase, but also no nitrogen. As soon as the wind blows, wind energy displaces electricity from coal, gas and biomass plants from the grid, reducing total nitrogen emissions in the Netherlands. The construction phase can also take place virtually without nitrogen emissions by using electric construction equipment. This makes wind turbines an important weapon against both climate change and the degradation of nature reserves due to nitrogen deposition.
Wind energy therefore deserves a prominent place in the countryside and an integrated consideration.
Making farming and farmyard mills more sustainable
It is vital for the future prospects of farmers that they must and can make their business operations more sustainable. This concerns matters such as manure production and crop cultivation, but also their energy consumption, which will be largely electrified. Farmyard mills (with an axle height of about 15 meters) are particularly suitable for this because they generate energy during harvest time and in the dark, ideally in terms of capacity matched to the actual energy needs of the farm.
This way, farmers and other rural locations can grow their electricity needs without having to wait for extensions to the electricity grid. In our opinion, a number of provinces do not yet sufficiently recognize this possibility. It would be good if the NPLG pointed this out explicitly.
We have to do it together
The Netherlands is small, busy and full. NedZero therefore endorses NPLG's analysis that multiple use of space, including in rural areas, should be the norm. Nature also becomes recreation; Farmland also becomes water storage, and both also become part of our energy supply. NedZero, but also related industry organizations such as Holland Solar, Energie Nederland and NVDE, are well aware of the many interests competing for space. NedZero is therefore happy to assist the National Rural Area Program to discuss any questions that have arisen as a result of this view with you.
You can contact the undersigned for this. On behalf of NedZero, I wish you every success with NPLG.
Yours sincerely,
Paul van Egmond
Industry specialist onshore wind
Paul.vanegmond@nedzero.nl
