Written Evidence from Countryside Council
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
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
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
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
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
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
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;
life cycle costing and total energy
usefor 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,
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 Walesincluding the division of
powerson 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
The current and future portfolio of energy provision
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.
Ingress and entrainment of species.
In-combination effects and cumulative
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
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
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.
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. 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
(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
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.
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
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
Energy Wales: route map (Consultation document) Welsh Assembly
Government, 2005. Back
ABPmer (2005). Potential Nature Conservation and Landscape Impacts
of Marine Renewable Energy Developments in Welsh Territorial Waters.
CCW Policy Research Report 04/8. Back
"The Severn Barrage-Definition Study for a New Appraisal
of the Project"-January 2002, ETSU Report No T/09/00212/00/REP. Back