Select Committee on Welsh Affairs Written Evidence

Written Evidence from Dave Bradney

  1.  Structure of evidence: As requested I have numbered the paragraphs of this evidence (1 to 27). Where I have asked a specific question or made a specific request for action I have marked it thus: "***.........***" So it should be easy to locate all these requests by searching for "***" within the electronic version of this text. Should you require this evidence to be validated with a covering letter or complete hard copy, please contact me urgently. If validation is about checking that I am who I say I am, I am in the Ceredigion Electoral Register at the above address and listed in the Aberywtwyth 2005-06 Phone Book.

  2.  Source of evidence: I have a first degree in biochemistry and a postgraduate diploma in journalism studies. I have worked most of my life as a journalist, on general and specialist publications. Since 1986 I have been an activist in the Green Party, standing in elections for the London Borough of Brent, the National Assembly for Wales (1999), the European Parliament (2004) and Westminster (2005). Within the Green Party I have edited the England and Wales Green Party's newspaper, co-chaired its Regional Council and acted as Treasurer for Wales Green Party. I have lived in Ceredigion, in mid and west Wales, since 1991, and have worked as a journalist in Aberystwyth since 1993.

  3.  My evidence will be mainly about large-scale onshore wind-energy schemes—about their centrality or lack of centrality to the effective prevention of climate change, and about whether they provide the lowest-cost route for generating large amounts of renewable energy. When I say "cost" here I am talking about environmental damage, although I accept that financial cost is also a criterion that should receive some consideration.

  4.  I have been concerned about large-scale wind-energy schemes since 1998, when I was preparing to stand in the first National Assembly elections. As you may appreciate it is not easy for anyone in the Green movement to cast doubts on the desirability of renewable energy, but the unconvincing nature of the arguments and information available make rigorous questioning essential. Particularly when the damage that large-scale onshore wind installations inflict on the countryside and visual amenity is so manifest.

  5.  The core of this work for me was the consideration of the proposals for a large windfarm at Cefn Croes, between Cymystwyth and Devil's Bridge in Ceredigion. This led to Wales Green Party taking a stand against the scheme, and to Ceredion Green Party submitting a formal objection to it (see Annex A).

  6.  Cefn Croes was commissioned early this year, with 39 turbines of around 100m overall height on 750ha of remote upland plateau, dominated by peat bog. At the time it commenced to generate I believe it was the largest working windfarm in Europe, although now of course there are several larger—even much larger—schemes proposed and in preparation. But the exact position of Cefn Croes on the hugeness "league table" is unimportant—what I would suggest to you is that since it is big, modern, up and running and in Wales this is the model to have in mind when you are considering the current round of large-scale wind-energy proposals.

*** I recommend that inquiry members visit the Cefn Croes site, on a day when visibility is good! **

  7.  Future large-scale windfarm developments which are anticipated in Ceredigion include the Camddwr scheme, which would stretch along the ridge of the Cambrian Mountains between Strata Florida and the Teifi Pools in the north to Llyn Brianne in the south, and one or more contiguous developments in the Nant y Moch area north of Aberystwyth, which has been designated by the National Assembly as a TAN 8 Strategic Search Area (see comments later).

  8.  Throughout my involvement with these issues, I have been struck by two general observations. Firstly, that there is a group of people who speak and act as though building large onshore windfarms is the key to preventing climate change (which it demonstrably is not, as I will discuss later). And secondly, that this same group of people speak and act as though there has already been a Great Debate about how to tackle Climate Change, in which the countryside has already been specifically chosen to bear the brunt of the damage (clearly there has been no such debate, and therefore the countryside has not been designated in this way).

  9.  I have also been struck by the paucity and unreliability of the infornation available on a range of issues which are central to assessing the role which large-scale onshore wind-energy can and should play in an overall package of climate change prevention measures. I attribute this situation largely to the fact that the relevant information is to a considerable extent in the hands of the energy companies and their developers, who tailor the information which they see fit to release to suit the cases which they wish to make.

  10.  Select Committees of course have considerable powers to require the provision of detailed information, and so providing they know what questions to ask they are a powerful tool for getting at the truth. The establishment of your inquiry comes at a pivotal time in the expansion of the onshore wind industry in Wales, and the information that you gather and promulgate this year could prove crucial in the avoidance of any unneccessary damage to the Welsh countryside.

  11.  Accordingly, the core of my evidence will consist largely of questions to which as a single individual working more or less alone I have been unable to obtain credible answers.

*** My sincere hope is that your inquiry will address the right questions and accept nothing less than rigorous and convincing answers—commissioning independent research whenever there seems to be a significant gap in the information available. ** In this way your inquiry will have done a great service not only to Wales but also to the fight against climate change, which in my opinion we have left so late to begin that we really cannot afford any false starts.

  12.  To conclude this introduction, here are some general points which I believe it is essential to keep in mind as part of any framework for considering the role of large-scale onshore wind installations in the prevention of climate change, in the international, UK and Wales contexts:

    (a)  To avoid the worst consequences of climate change, we need to reduce global carbon dioxide (CO2) emissions by something like three quarters on 1990 levels. Broadly speaking this statement represents mainstream professional opinion within the science of climatology. Of course there are always contrarians.

    (b)  Renewable energy installations do not magically soak up CO2—all they do is provide an opportunity to "retire" an equivalent amount of carbon-based generating capacity, while maintaining overall electricity generation at the same level. Therefore, the simple act of bringing a windfarm on-stream does nothing of itself to prevent climate change.

    (c)  Wales already generates roughly twice as much electricity as it consumes (*** please confirm exact figures **).The excess passes across the National Grid—less the substantial transmission losses—for consumption in England. The generation of yet more electricity in Wales would therefore not seem of itself to be an objective that should be allocated a high priority.

    (d)  Already, onshore in mid-Wales, there is roughly as much installed wind-energy capacity as exists in the whole of England (*** please confirm exact figures. **) To anyone who knows the industrial history of Wales within the UK—coal, steel, water—this should ring alarm bells.

    (e)  There is ten times as much wind energy available offshore as is available onshore (DTI figures, quoted in the Friends of the Earth publication "Wind power: your questions answered").

  13.  Here are the main questions for which I would like the inquiry to seek convincing evidence. I have made no attempt to put them in any particular logical sequence.

  14.  Pay-back period analysis is obviously applicable to wind-energy projects. CO2 payback is tricky, since any calculations depend on which particular carbon-based generation technology or mix of technologies is deemed to be cancelled out. Energy payback is a more straightforward way to look at this. Figures for the energy payback period of a modern wind turbine with a working life of 20-25 years are often quoted in the region of 6-8 months, but I find this implausible. If I had been told the figure was 3-4 years I would probably never have questioned it, but 6-8 months seems entirely beyond belief. Remember, this payback calculation has to include: the energy cost of extracting and processing all raw materials, manufacture of components, transport of components to site (typically from Germany), site preparation (digging huge holes, creating a network of wide, graded roads around the site and an access connection to the public highway, laying underground cables, office buildings, hydrological work), assembling turbines (huge concrete foundations, high-level work with large cranes), creating a powerline connecting the windfarm to the National Grid (the Grid Connection), site security, maintenance and decommissioning and disposal. All carried out in quite challenging, hilly terrain.

*** Please would the inquiry establish the real energy payback period for a modern windfarm, eg Cefn Croes, taking evidence from independent engineers as well as industry experts? **

  15.  As I understand it, the energy output of each turbine is measured at the turbine itself, and it is on these figures that payment for the electricity generated depends. It has been suggested to me that transmission losses across the length of the Grid Connection are considerable, so that the power that is actually delivered onto the Grid is considerably less than the amount that left the individual turbines of the windfarm. If true, this would mean that much less electricity is being delivered to the National Grid than is being paid for.

*** Please would the inquiry establish what transmission losses should be expected across a Grid Connection, eg the Grid Connection at Cefn Croes, which I believe is quite a long one? **

  16.  Roughly twice the electricity that Wales needs is currently being generated in Wales (see para 12c).

(*** please confirm exact figures **).

It would seem unavoidable that the surplus is intended for use in England, but because electrical power is a perishable product much of it will have been wasted in transmission losses by the time it has been shipped across the National Grid to England.

*** Please would the inquiry establish what proportion of the surplus electricity generated in Wales is wasted during its transmission for use in England? **

*** Please could the inquiry establish how much electricity could be saved (a) in Wales and (b) UK-wide if electricity was generated close to its main centres of demand—eg if all electrical power was generated within 50 miles of its intended consumers? **

  17.  We are told that the purpose of renewable electricity generation is to reduce CO2 emissions, but as discussed in para 12b renewable energy installations do not directly absorb CO2, they merely provide an opportunity to make corresponding reductions in carbon-based generation. If it is public policy to pursue this transition, to assist with the prevention of climate change, a coordinated plan for achieving maximum effect through an orderly progression of incremental adjustments might be expected.

*** Please could the inquiry establish whether any plan for a transition from carbon-based electricity generation towards renewable electricity generation exists? If there is no such plan, is there any intention to create one? And if there is such a plan, why is its existence such a well-kept secret? **

  18.  Although windfarms do not directly absorb CO2, disturbing evidence has recently emerged that windfarm sites can EMIT large quantities of CO2. The expert committee responsible for monitoring environmental changes at the Cefn Croes site has been told that the consequences of partially draining the raised bog into which the turbines have been inserted have been "dire", and that a "huge amount" of exposed peat around the turbines is gradually drying out and oxidising, leading to the emission of "huge" amounts of CO2 to the atmosphere. The news story which exposed this situation can be found at Annex B.

*** Please would the inquiry interview members of this committee to establish the nature and extent of the problem, and its likely progression? Please would the inquiry be sure to interview Becky Jones, the Environment Agency's Senior Environment Officer for Ceredigion, who is quoted in the newspaper story? **

*** Please would the inquiry establish, if the present hydrological arrangements at the Cefn Croes site persist, what proportion of the supposed CO2 saving from the operation of the windfarm will be cancelled out by the release of CO2 from the surrounding bog? **

  19.  Leading on from para 18 there is a wider question—did the CO2 described above arise because the hydrological arrangements at the Cefn Croes site were poorly done, or does the Cefn Croes experience demonstrate that it is impossible implant large-scale wind-energy equipment into raised upland bogs without wrecking those bogs as a precious habitat and releasing "huge" amounts of CO2?

*** Please would the inquiry seek to establish whether it is practically possible to instal a large, modern windfarm in a peat bog without creating major damage and CO2 emissions—taking evidence from independent engineers and ecologists as well as industry experts? **

  20.  Recently there were press reports of an incident in Scotland in which a rotor blade of a large wind turbine shattered, with large fragments being scattered across some distance. There have also been reports that in cold weather large chunks of ice can build up on turbine blades and fly off, landing some distance away. The incident with the broken blade is described at Annex C.

*** Please would the inquiry establish what the safety record of large, modern wind turbines is, as regards a) rotor breakage and b) ice hazards in cold weather? **

*** Please would the committee establish what the minimum safe distances from modern wind turbines should be, for (a) households, (b) pedestrians and (c) ridden horses? **

  21.  There are repeated reports of individuals who claim to have experienced serious psychosomatic illness in the vicinity of windfarms. This is often attributed to "low-frequency sound", by the individuals affected or on their behalf. A number of General Practitioners are understood to be carrying out small-scale epidemiological studies, but as far as I know there is little academic research work being carried on this. An account of one such case of illness, in west Wales, can be found at Annex D.

*** Please would the inquiry do what it can to establish whether "low-frequency sound" (or whatever it actually is) from windfarms is a hazard to human health, taking evidence from independent doctors and acoustical engineers as well as from industry experts? **

*** Please would the inquiry consider whether it should recommend that further research on this phenomenon would be desirable? **

  22.  It is often claimed that large-scale onshore wind installations are of major benefit to the local economy, by creating permanent (ie post-construction) employment.

*** Please would the inquiry establish what the track record of large-scale onshore wind developments is in creating permanent employment within (say) a 30-mile radius of the site, taking evidence from independent economists and employment experts as well as industry experts? **

  23.  The inquiry's terms of reference include investigation of the division of powers over energy policy between the Westminster Government and the National Assembly for Wales, and it seems to me that this is a vexed question. In the Government's proposals for a Welsh Assembly ("A Voice for Wales", White Paper, 1997), energy is not mentioned in the list of responsibilities (page 7) which the devolved assembly would take over from the Secretary of State for Wales; and in the fine print (Annex A) the only reference is to the "promotion of energy efficiency". Immediately before the creation of the National Assembly, "Making the Difference in Wales: A Guide to the powers of the National Assembly for Wales" (Devolution Unit, Welsh Office, February 1999) gave a detailed account of the powers being transferred. A table under the head "Industrial, Economic and Social Development" allocates "energy efficiency" to the Assembly, and "regulation of the privatised . . . electricity . . . industry" to Whitehall. In the Energy Review (Performance and Innovation Unit, Cabinet Office, February 2002), Box 1.1 on page 16 states quite unambiguously that powers to promote renewable energy have not been devolved to Wales, and yet at that time work by the Assembly's Economic Development Committee on this topic was already ongoing (Review of Energy Policy in Wales: Part 1: Renewable Energy, April 2002), and this work has continued strongly. All this is suggestive of the possibility that the National Assembly actually has no standing in the field of renewable energy (except as regards town and country planning), and has been carrying out considerable programmes of research and policy development work in this policy area on an ultra vires basis.

*** Please would the inquiry establish precisely what powers in the field of energy have been transferred to the National Assembly, and in particular whether there has been and continues to be a legal basis for the Assembly's involvement with renewable energy policy and planning? **

  24.  Another aspect of the division of powers between Westminster and the National Assembly arises in the town and country planning system, because of the operation of Section 36 of the Electricity Act 1989, which provides for renewable energy schemes with installed capacity of 50MW and upwards to be decided by the Secretary of State for Trade and Industry rather than through the usual planning process, which would provide for initial decision by the local planning authority, with the possibility of review and modification of that decision by the National Assembly for Wales. The DTI process does offer the possibility of a local planning inquiry, providing a statutory consultee indicates that this would be desirable, but even so it can be argued—and I would do so—that decisions on large windfarm schemes in Wales should be taken within the Welsh planning system. It can also be argued that the failure to transfer Section 36 powers to the National Assembly was no more than a technical oversight, arising during a period of legislative overload. However, this latter suggestion seems to me to be less likely.

*** Please would the inquiry consider whether it would be more appropriate for the planning powers which currently reside within Section 36 of the Electricity Act 1989 to be transferred to the National Assembly? **

  25.  Next there is the question of the National Assembly's new planning guidance on renewable energy, Technical Advice Note 8 (TAN 8), and its associated Ministerial Interim Planning Policy Statement. I will try to keep this brief, because I am really not sure whether your inquiry will consider that TAN 8 falls within its remit. TAN 8 has come into being perhaps because of the Assembly's strong interest—rightly or wrongly—in the development of renewable energy in Wales, but even if the interest was originating from Westminster it would still be the task of the Assembly to reflect it in some way through planning policy guidance. Stated very simply, as I understand it, TAN 8 designates a series of areas in rural Wales—called Strategic Search Areas—as being suitable to accept large-scale wind-energy developments, and seeks to diminish the grounds for objection to such schemes through the operation of the planning process. A TAN 8 draft was the subject of a consultation process last year, during which as I understand it the overwhelming response was adverse, including adverse reaction from a number of local authorities in Wales. Nevertheless the final version of TAN 8, as far as I understand it, was essentially unchanged. The stripping away of the public's rights to scrutinise and object to proposed developments which are claimed to be in the national interest would appear to be undesirable, and doubtless reflects the Westminster Government's impatience to "streamline" the way that the planning system handles major infrastructure projects. It is easy to imagine the TAN 8 approach being applied to nuclear power stations, airports and motorways. I have heard it suggested that the use of TAN 8 may be in breach of the UN's Aarhus Convention, which covers public participation in decision-making and access to justice in environmental matters. The UK became a signatory of the Aarhus Convention early this year.

*** Please would the inquiry consider whether the designation of Strategic Search Areas under the new TAN 8 guidance is a desirable innovation within the planning system in Wales? **

*** Please would the inquiry consider whether the implementation of TAN 8 constraints on the public's use of the planning system in Wales could constitute a breach of the Aarhus Convention? **

  26.  Finally—even though I am rapidly running out of the time I have available in which to compile this evidence—I cannot resist some general comments on future patterns of energy demand and supply in Wales. Currently it would appear that Wales is roughly 100% oversupplied with electricity (para 11c). However, in the future the closure of the Wylfa nuclear power station (approx 1GW) can be anticipated, and carbon-based electricity generation needs to be drastically cut back as part of a general package of climate change prevention measures (para 11a). After the closure of Wylfa, electricity oversupply in Wales might be of the order of one third above demand. Proposed and existing wind-energy schemes already offer substantial amounts of renewable energy, especially the proposed 750MW windfarm Gwynt y Mor, off the coast of north Wales. Tidal current generation would appear to offer considerable opportunities in particular locations around the Welsh coast and in the Irish Sea, eg Bardsey Sound. Tidal current schemes can be visualised as groups of stubby wind turbines, but under water. The crucial differences are: (a) water is roughly 800 times more dense than air, so much more power is available, and (b) the tides are highly predictable, unlike the winds. I am aware of tidal current generation development work off the coast of north Devon, but as far as I know there is no active development or exploration work in Wales. Joint ventures with the Irish Republic should be given active consideration. Tidal lagoon projects also offer generation opportunities, and I believe there are detailed proposals in the Swansea area and on the north Wales coast near Rhyl. Microgeneration seems to have been completely overlooked so far, and micro-hydro and small-scale wind schemes serving individual properties and small groups of properties should receive major encouragement. One major issue is the upgrading of Building Regulations, so as to oblige the building industry to incorporate energy-saving features and micro-generation features into all new dwellings, offices and factories. If it is true (Energy Review, 2002) that control of Building Regulations has not been devolved to the Assembly, this is an issue that this inquiry could focus upon, and on which inquiry members could follow up during their ongoing work as MPs. The most difficult aspect of the problem, I believe, is how to introduce a substantial stream of renewable energy into the transport consumption sector. For this I propose the skipping of any number of intermediate solutions in favour of developing the "hydrogen economy", so that scattered renewable energy installations can be used to generate hydrogen, for storage on site and collection for individual consumption by hydrogen-powered vehicles. This would amount to a network of renewable energy "filling stations", and would largely eliminate the need to transport automotive fuels. I realise that there are still engineering issues to resolve with the hydrogen economy, but I also know that several nation states (eg I believe Iceland, Finland and the US) are working on development and planning, so why not the UK and within it Wales?

*** In line with para 17, please would the inquiry investigate the feasibility of developing a plan for the progressive elimination of surplus carbon-based electricity capacity in Wales (leaving in place a sufficient reserve to cover predictable fluctuations in demand, and emergencies, of course), with matching increases in renewable electricity generation in England, and make detailed recommendations? Such a plan would minimise wasteful transmission losses, and at the same time offer rapid reductions in CO2 emissions from the electricity generation sector. **

*** Please would the inquiry explore ways in which the Building Regulations could be used to increase and maximise the incorporation of energy-saving features and mico-generation features into new-build dwellings, offices and factories, and make detailed recommendations? **

*** Please would the inquiry evaluate the potential of the "hydrogen economy" within Wales, taking detailed evidence on the ongoing planning and development work being carried out in other countries, and make detailed recommendations? **

*** In particular, please would the inquiry evaluate the potential of the disseminated generation of hydrogen fuel from renewable energy, as a means of creating a major route for renewable energy into the transport sector, and make recommendations? **

  27.  This concludes the evidence I have to offer (four annexes lettered A to D follow). Thank you for taking the time to consider this evidence, and I hope it will help you in your deliberations.

25 November 2005


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