Select Committee on Welsh Affairs Written Evidence

Written Evidence from Countryside Council for Wales


  1.  It is critical that the planning and delivery of energy policy in Wales fully reflects the National Assembly for Wale's Scheme for Sustainable Development and the Welsh Assembly Government's Spatial Plan.

  2.  CCW supports the UK Government's long-term aim of a 60% reduction in CO2 emissions by 2050. This should be the major driver of energy policy.

  3.  Achieving the RCEP's 60% CO2 reduction target demands a twin track approach:

    —  far greater emphasis on demand-side management and on energy efficiency; and

    —  the development and utilisation of RE technologies.

  4.  The key to the development of RE is to ensure "the right technology in the right place". This requires a strategic approach to the planning and siting of new RE developments, on land and at sea, including the Strategic Environmental Appraisal of different options. This would allow consideration of potential cumulative impacts of new technologies.

  5.  For onshore wind, the TAN 8 approach has our strong support. We would advocate the equivalent of a TAN 8 for the sea and CCW would be keen to input positively to this.

  6.  In the context of ongoing power generation development proposals at Aberthaw and Pembroke, the applications and their timing allow an excellent opportunity to encourage an integrated assessment of the proposals in terms of their wider strategic consideration under the sustainable development duty of the Welsh Assembly Government. We would strongly advocate such an approach.


  1.  The Countryside Council for Wales champions the environment and landscapes of Wales and its coastal waters as sources of natural and cultural riches, as a foundation for economic and social activity, and as a place for leisure and learning opportunities. We aim to make the environment a valued part of everyone's life in Wales.

  2.  Our comments below are structured according to the Terms of Reference of this inquiry.

UK Government policy in relation to: (a) the current and future energy needs of Wales; and (b) the current and future provision of energy in Wales

  3.  It is critical that the planning and delivery of energy policy in Wales fully reflects the following high-level strategies:

    —  The National Assembly for Wales' Scheme for Sustainable Development and the Welsh Assembly Government's Sustainable Development Action Plan;

    —  The Welsh Assembly Government's Spatial Plan, People, Places, Futures. We recommend that this should be extended to cover the marine environment.

    —  The Welsh Assembly Government's emerging environmental strategy.

    —  The Welsh Assembly Government's strategic framework for economic development.

  4.  The Royal Commission for Environmental Pollution recommended that UK CO2 emissions should be reduced by 60% from current levels by 2050, and this target was embedded in the Government's Energy White Paper Our energy future: creating a low carbon economy. CCW supports this long-term aim which, by implication, should be the major driver of policy.

  5.  We consider that it is important to address both the supply and the demand aspects of energy matters. The overriding issue is one of mitigating the impact of climate change and clearly measures that support a reduced level of demand for energy are as important as measures which promote low-carbon technologies. Achieving the RCEP's target thus demands a twin track approach:

    —  far greater emphasis on demand-side management and on energy efficiency; and

    —  the development and utilisation of RE technologies.

  6.  The greater the reduction in demand for electricity through demand-side management and energy efficiency, the more achievable will be the UK's and Wales's renewable energy generation targets. More emphasis is required on using tools to manage energy demand, such as

    —  improvements to Building Regulations, benchmarking and adopting European best practice;

    —  fiscal tools to further incentivise take-up of low energy and energy conservation products and services; and

    —  life cycle costing and total energy use—for example to increase the case for constructing to "excellent" BREAM standards.

  7.  Early consideration could be given to creating a stronger sustainable energy R&D base in Wales. In this way Wales can demonstrate exemplar sustainable development projects consistent with a "win-win" policy scenario. It is important that R&D in developing new sources of RE is accelerated now to enable a wiser range of RE options to come on-line sooner rather than later. There should be a key role for the Sustainable Technologies Technium at Baglan Energy Park.

  8.  We support the principle of local generation, [12]and micro generation, that occurs close to the point of demand. The benefit of local generation is that it avoids the transmission losses associated with the National Grid, and also offers the potential for ownership at community level by local communities, the voluntary sector and other and social enterprise organisations. We consider that it would be useful to undertake a full evaluation of the economic, social and environmental costs and benefits of taking forward local generation in Wales. The role of generating energy from waste (where this is consistent with the Wales waste hierarchy) should be considered as part of this approach.

The relationship between the UK Government and the National Assembly for Wales—including the division of powers—on energy policy

  9.  There needs to be better links to UK Government strategies, particularly in marine renewables. There are ongoing discussions with the UK Government in relation to section 36 and 37 of the Electricity Act. Overall, particularly in the marine environment, WAG is currently not the consenting body. Strategic planning for offshore energy therefore needs to positively encompass DTI working in partnership with WAG and its partners.

The current and future portfolio of energy provision in Wales

  10.  The WAG has recently consulted on its Energy Route Map. This confirms the WAG's target of achieving 4TWhr pa of RE production by 2010 and 7TWHr by 2020. CCW supports these targets and will be working actively with WAG, other regulatory authorities and developers help achieve them. The key is to ensure "the right technology in the right place", and this requires a strategic approach to the planning and siting of new RE developments, on land and at sea, as evidenced by the TAN 8 approach which has our strong support. We hope that the Route Map will promote and achieve such an approach, in partnership with all key players involved. We look forward to contributing positively to its achievement. In some cases this may involve early (and, if necessary, in confidence) consultation with CCW by developers, and we would encourage any such approaches.

(a)  Nuclear Energy

  11.  It is essential that Wales and the UK develop a diverse mix of energy sources and electricity generation capacity with every sector seeking to maximise efficiency and minimise GHG emissions. We cannot seek to rely on gas-turbine generation or wind-turbine generation or renewables alone. Energy efficiency has an important role to play but can only be part of our response. The UK Government's Energy White paper kept open the option of future nuclear generation capacity without committing itself to any new nuclear build. By 2023, all of the UK's nuclear plants except Sizewell B will have been decommissioned. Currently, nuclear provides c 20% of UK electricity (without any direct GHG emissions), including the contribution of Wylfa in Wales. Unless new carbon-neutral generating base-load capacity is developed then any reductions in carbon emissions achieved by reaching the 20% renewables by 2020 target will be outweighed by the almost total loss of nuclear. We would urge the Government to speedily resolve this issue.

  12.  It has long been assumed that by protecting the health of people, the health of other wildlife species is also protected from the effects of radiation. The EC through its 6th framework programme ERICA (Environmental Risk from Ionising Contaminants: Assessment and management) is evaluating the impacts of ionising radiation on wildlife. The work is due to be finished in 2007 and the results should be built into any consideration of nuclear options.

(b)  Liquefied Natural Gas

  13.  We have been involved in consultations with National Grid Transco (NGT) concerning the route for the pipeline to transport LNG from Felindre to Tirley in Gloucestershire. There has been a very constructive dialogue between NGT, CCW and other statutory bodies whilst NGT undertook a re-appraisal of corridor options for this pipeline. This has required a very large input of effort by NGT and CCW. We very much welcome the scale of effort in this early engagement which has lead NGT now to favour a corridor that is largely located within lowland agriculturally improved land where in our view the residual impacts are likely to be in much lower order of magnitude.

  14.  Concerning the above process we would note that our understanding is that once gas shippers have signalled their capacity requirements via the Ofgem regulated auction process, NGT are obliged to provide a connection and any reinforcements necessary to the National Transmission System (NTS) within three years of the auction signal. It is this three year Ofgem requirement that has determined the timescale for this project. We have highlighted our concerns to NGT and the DTI that three years is an inadequate period to design and implement a scheme of this scale within such a sensitive area. Whilst we recognise the high level of effort that NGT are making to find an acceptable solution, we remain concerned about the pressure that the Ofgem rule places on this project's timescale and minimising impacts on the environment.

  15.  Additionally, we have concerns regarding the proposal to construct and operate a 2,000MW CCGT power station at West Pennar, Pembroke. These relate to:

    —  Thermal emissions and direct/indirect impact on habitats and species.

    —  Habitat loss/modification.

    —  Ingress and entrainment of species.

    —  Water quality issues.

    —  Air Quality issues.

    —  In-combination effects and cumulative impacts.

    —  Lack of consideration of mitigation and alternative solutions.

  16.  Nevertheless, that the development of the Pembroke proposal offers highly significant environmental benefits compared with the proposal to expand Aberthaw (which we comment on below).

  17.  We note that, as separate planning applications the two power station developments (Aberthaw and Pembroke) are being considered individually by the planning and pollution regulators. The applications and their timing allow an excellent opportunity to not only examine the site specific implications of the separate development proposals but to encourage an integrated assessment of the proposals in terms of their wider strategic consideration under the sustainable development duty of the Welsh Assembly Government. We would strongly advocate such an approach.

(c)  Clean Coal Technology

  18.  We support the WAG's objective (stated in its Energy Route Map consultation) to establish Wales as an attractive location for a Coal/carbon capture and storage initiatives. It is inevitable that there will be continued reliance on fossil fuel electricity generation capacity well into the 21st century (within UK and elsewhere) therefore research and the development of CCS technology within Wales could in the long-term provide major economic and environmental benefits. The sooner the technology and feasibility of this is explored and developed the better.

  19.  We look forward to contributing positively to the Coal TAN Technical Advice Group.

  20.  We have concerns relating to the proposed partial upgrading and increased generation of electricity at Aberthaw Power Station. Despite a proposed investment to fit FGD at Aberthaw, the increase in electricity production will significantly increase other pollutants:

    —  Without the installation of NOx removal, Aberthaw will represent the second largest point source of NOx in Europe, which at full load could release approximately 41,000 tonnes of NOx per annum. Aberthaw is situated at a particular inappropriate location in relation to the impacts caused by such a large emission source. CCW advocates additional control measures to remove the oxides of nitrogen (NOx).

    —  Increased generation at Aberthaw represents a major new source of CO2 emissions, emitting approximately 10 million tonnes per annum at maximum output.

(d)  Wind Farms

  Onshore wind

  21.  CCW welcomes, and has long advocated, the overall policy approach set out in the Ministerial Interim Planning Policy Statement and TAN 8 in particular the use of a strategic all Wales spatial approach to finding suitable locations together with an increased emphasis on energy efficiency and conservation. The strategic spatial approach potentially provides a framework to facilitate positive planning to address climate change identifying positive solutions, the right type of development in the most appropriate locations, thereby helping secure government targets whilst minimising environmental cost.

  22.  CCW is concerned to ensure that the TAN 8 implementation process provides clarity and certainty for all involved in the development process, supported by a decision support tool developed to help inform the decision making process within the planning system. Without a proactive approach within the Strategic Search Areas, CCW is concerned that the strategic approach will stall.

  Offshore wind

  23.  CCW have attempted to be proactive in the marine renewable field and take a precautionary but pragmatic approach. We have worked closely with the Welsh Assembly Government (WAG), Defra, Cefas, Crown Estate and many other bodies. We have encouraged developers to involve us early in the planning process, recognising that early dialogue is invaluable in reducing conflict.

  24.  Through CCW's technical support program we have commissioned new research to promote a better understanding of offshore wind farm impacts and ensure that our advice is based on up-to-date information and robust science. We have also provided tools to help developers tackle landscape issues in their EIA's in our seascapes guide. Often developers need to collect data for a wider area than their site and CCW have taken a proactive role in bringing developers together and coordinating large-scale bird surveys. In addition the interest on deposits paid to the Crown Estate by developers has been used to fund research on impacts and CCW have participated fully in this.

  25.  The UK's first major offshore wind farm, North Hoyle, is in Wales, off the north Wales coast. It is now consented, constructed and generating. We supported the application for this development, and have forged a good working relationship with npower who developed the site.

  26.  The original application for the other round one site off the north Wales coast, Rhyl Flats, proposed an unusual design of two long lines of turbines. Our main concerns, on landscape grounds (spread across the horizon), and ornithological issues (potential barrier effect) were, in part, resolved by working with the developers and a more compact design being proposed. This development was then consented.

  27.  We consider that increased collaboration between ourselves, Crown Estates, DTI, WAG and developers would facilitate the achievement of offshore wind development in Wales.

  28.  We also suggest that issues of public awareness and education are considered. The strength of public feeling seen at the Scarweather Sands offshore wind farm proposals, if repeated, have the potential to cause problems for future offshore wind farm development in Wales. We need to address public engagement actively in regard to offshore wind development.

(e)  Biomass Energy

  29.  Biomass energy can be drawn from a range of sources including wood (from existing woodlands and plantations), short rotation coppice, energy crops and waste (timber co-products, waste wood, animal manures/slurries, sewage sludge and food waste). Biomass energy has the benefit of being continuous, and is most efficient when the source is close to the end use, to reduce transport impacts. The recent report by the Biomass Task Force (October 2005) to Defra was produced in an England context, but much of the information it contains is applicable to Wales.

  30.  Biomass from plant sources, whether existing (woodlands and plantations) or newly established short rotation coppice or energy crops must comply with best practice to ensure that there are no negative environmental impacts. Further work is needed to expand the suite of best environmental practice guides (for example, for Miscanthus and other energy crops).

  31.  Biomass-fuelled heat is deemed to be more efficient than biomass-fuelled electricity production, though combined heat and power generation is efficient. In Wales, the best solution seems to be to concentrate on smaller scale installations, such as schools or institutions, and small scale local heating/energy generation. Examples of these already exist, and can act as exemplars to encourage others to adopt these systems, and to refine them both technologically and administratively. Coed Cymru has developed a small scale wood pelleting process which supports the development of such initiatives, allowing pellets to be produced locally.

  32.  We support the use of biomass for energy and hope to contribute to the forthcoming Biomass Energy Strategy for Wales. [13]Evidence in the Biomass Task Force report suggests that biomass-fired heat has an 80% energy extraction efficiency and the technology is available; lack of confidence appears to be a major barrier to uptake. In Wales, the Centre for Alternative Land Use is researching and promoting biomass energy, and the Forestry Commission has secured funding from Objective 1 and 2 for the Wood Energy Business Scheme. Opportunities for capital grants for equipment (boilers or anaerobic digesters and associated infrastructure) for community, farm scale and domestic use should be pursued. Such grant aid could be targeted geographically (this is an issue which the forthcoming WAG biomass energy strategy should address). The Biomass Task Force point to the need for such policies to be in place for the medium term, (5-7 years) to build confidence and to achieve a significant impact.

(f)  Geo-thermal Energy

  33.  No comments.

(g)  Tidal and Wave Energy

  34.  The development of the marine renewables sector in Welsh waters requires a process of strategic planning to give an indication of the most appropriate technologies and potentially suitable locations. Criteria which take into account potential nature conservation and landscape impacts and sensitive areas around the Welsh coast should be included. Adopting a Wales wide strategic approach would allow adequate consideration of potential cumulative impacts of these technologies.

  35.  DTI has recently launched its consenting policy for wave and tidal renewable energy projects. CCW and the other Country Agencies were consulted in its development. We welcome DTI's approach to setting out a fair process which will allow developers to progress demonstration projects whilst recognising that there are environmental constraints and certain measures which must be taken in order to avoid significant impacts on the marine environment. However, in our view the guidance would be stronger if it contained guidance recognising environmental issues and constraints concerning site choice, duration and scale of demonstration projects. It is important that we learn as much as possible from this pre-commercial phase to contribute significantly to any Strategic Environmental Assessment conducted before any commercial deployment of these devices.

  36.  There are many unknowns about the potential impacts of these technologies. A precautionary approach to their siting should be taken. We recommend some form of marine spatial planning exercise be undertaken at an appropriate scale to plan for both offshore wind and wave and tidal whilst taking full account of the needs of other sectoral objectives, including nature conservation. Whilst marine spatial planning should enable strategic decision making in the marine environment it is critical that any planning exercise takes full account of terrestrial considerations as well (and visa versa). This could improve integration between planning for the management of the terrestrial and marine environment and thus contributing to Integrated Coastal Zone Management and more joined up thinking. From a Welsh renewables perspective the outcome of this could be in the form of the equivalent of a TAN 8 for the sea and CCW would be keen to input positively to this.

  37.  A critical role can be played by pre-commercial demonstration projects in enabling us (and others) to understand about impacts. We will work with WAG to support their objective (stated in it's Energy Route Map consultation) to "try to ensure that major demonstration projects are located in Wales by 2010". We have already been approached by a number of developers looking to deploy pre-commercial demonstration devices in Welsh waters and we are engaging in early dialogue about site selection with them.

  38.  CCW has already undertaken some work, which could be used as a starting point[14] to help achieve the development of marine renewables in Wales. This work looked at which sites are potentially the most likely to attract certain types of renewable development and then identified which habitats and species are present at the specific sites, so that we could look at potential impacts and provide advice to developers very early in the development planning. We have already been engaged in dialogue with developers considering Welsh territorial waters for the deployment of their pre-commercial demonstration devices and will continue to talk to these and others.

  39.  There are many uncertainties about the environmental impacts of wave and tidal technologies, which may take some time to address and this must be reflected in the adoption of a precautionary approach at sites where data gaps are identified or impacts are unknown.

  40.  We suggest that WAG (and others) need to work with DTI and Crown Estate to ensure there is an appropriate consenting policy in place to enable the development of marine renewables in Wales.

  Tidal energy

  41.  The Government's Energy White Paper states that "it is clear that plans for a Severn Barrage would raise strong environmental concerns and we doubt if it would be fruitful to pursue it at this stage" (para 5.54). We were therefore surprised to see the statement in the WAG's Energy Route Map consultation "look to keep open consideration of the long-term Severn barrage option". Our advice would be that this option should not be kept open due to the concerns about the impact of this option on the natural environment.

  42.  The Severn Estuary has been designated as a Site of Special Scientific Interest (SSSI), Special Protection Area, and a Wetland of International Importance (Ramsar). Furthermore the UK nature conservation agencies and JNCC have recommended to Government that the area be put forward as a Special Area of Conservation (SAC). At present the Estuary has possible SAC status. The estuary is important because of its extreme conditions, and the habitats and species present in the estuary are a function of this dynamic physical environment. It is inevitable that features of European and UK importance would be damaged and/or lost if a scheme like the barrage were to go ahead.

  43.  Work in 2002 on the Severn Barrage[15] notes that "within the basin formed by the barrage the hyper-tidal nature of the estuary would alter significantly and no measures to compensate for the loss of this particular feature could be engineered". This is a critical issue. Under the Habitats Directive it would be necessary to compensate for such losses, a requirement further clarified by the recent Dibden Bay decision. We doubt that the coherence of Natura 2000 could be secured if such a scheme were to go ahead.

(h)  Hydro Electric Energy

  44.  We support the development of small-scale hydro subject to appropriate location. We would cite as good practice the development of a small-scale hydro electric turbine at Talybont-on-Usk, following a feasibility study funded by the National Assembly for Wales' Sustainable Development Fund. The turbine will produce an annual energy output in the region of 240 Mwh valued at around £17,000. The electricity generated will be sold under the Renewables Obligation to a Public Electricity Supplier via the National Grid. Talybont-on-Usk Energy (a limited company with charitable objects) will re-invest the proceeds from the sale of the electricity in a range of further energy projects in the Talybont-on-Usk community council area. All this will be managed by and for local people, and has the potential to be a model for small-scale renewable energy generation.

9 December 2005

12   This is sometimes referred to as decentralised energy (DE) systems. Back

13   Energy Wales: route map (Consultation document) Welsh Assembly Government, 2005. Back

14   ABPmer (2005). Potential Nature Conservation and Landscape Impacts of Marine Renewable Energy Developments in Welsh Territorial Waters. CCW Policy Research Report 04/8. Back

15   "The Severn Barrage-Definition Study for a New Appraisal of the Project"-January 2002, ETSU Report No T/09/00212/00/REP. Back

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