Select Committee on Welsh Affairs Written Evidence

Written Evidence from Cefn Croes Action Group


  1.1  The Cefn Croes Action Group is a Welsh group which was formed to oppose the construction of a wind power station at Cefn Croes, Ceredigion. Cefn Croes is the largest consented wind power station constructed in the UK. The CCAG initiated proceedings in the High Court of Justice in 2002 in an attempt to halt the development at Cefn Croes.

  1.2  The CCAG remains active, both with regard to perceived illegalities in connection with the Cefn Croes development and with the proposed development of a major wind power station at Camddwr (Upper Tywi Forest) and elsewhere in the Cambrian Mountains.

  1.3  The CCAG has considerable experience and expertise regarding wind power as a result of its researches and the knowledge of its members, not least because of its involvement in the High Court litigation mentioned above. Alone amongst Welsh organisations, it has had the courage and energy to confront the Government. Further legal actions are currently being considered.

  1.4  The CCAG's monitoring of the construction of the Cefn Croes Power Station and its transmission lines proves conclusively the deleterious impact of such development upon the landscape; such impact is caused not only by the visible nature of wind power turbines, but also by the construction of approach roads, turbine foundations and power lines and substations. The bulldozer is not a friend of the natural environment. Eight hundred acres of land were clear-felled to provide the site at Cefn Croes. This amounted to the felling of an estimated 80,000 trees.

  1.5  It is salutary to note that there has been a reluctance on the part of the decision makers to inspect the Cefn Croes site. The Rt Hon Patricia Hewitt, Secretary of State at the Department of Trade and Industry forebore to visit prior to giving the consent to develop (23 May 2002) and has declined subsequent invitations to visit. Members of the National Assembly for Wales have been similarly reluctant to inspect the damage caused by the infrastructure.

  1.6  The CCAG is beholden to no-one: it receives no financial support from any source, not does it have any financial or commercial interests in this controversial matter. It consists of concerned individuals who wish to preserve the Welsh landscape. It also aims to prevent the exploitation of Wales yet again. As yet Wales has received little benefit from the exploitation of coal and other minerals, water resources or indeed afforestation.

  1.7  The CCAG supports all efforts to promote energy saving.

  1.8  It should further be stated that the wild places have no-one within their areas to speak out on their behalf. by their very definition they are uninhabited; they are silent. CCAG seeks to give voice to such concerns.


  2.1  The objects of the CCAG may be stated clearly and simply: it opposes any industrial development of the Cambrian Mountains. Wales's wild places must be protected.

  2.2.  Once the wild places have been industrialised, they are lost forever (whatever lip-service may be paid to decommissioning and restoration). Even the most superficial inspection of the Cefn Croes power station will reveal the irremediable damage caused to the landscape, the ecology and the environment.

  2.3  The CCAG seeks to educate decision makers and the public as to the limitations of wind power: it is not the panacea its proponents advocate. Reference may be made to CCAG's website

  2.4  The CCAG is willing to suggest practicable and realistic ways of supporting and benefiting local communities.

  2.5  The CCAG is agnostic regarding nuclear power. (The CCAG has no connection, formal or otherwise, with the nuclear industry.)

3.  TAN 8

  3.1  It is interesting to note that, of the consultative bodies for on-shore power developments Annex A 2 p 16, there is not a single one situated in Wales. Should Wales place its destiny in the hands of such institutions?

  3.2  The CCAG considers that Wales and its resources are being exploited.

  3.3  It is also germane to note that as far as the Cefn Croes development is concerned, there has been minimal Welsh involvement: the contractors are admittedly from Ruthin, but the equipment is foreign, the turbine towers are Danish, the nacelles and rotor blades are German; even the abnormal load transport drivers are Dutch and Swedish. Jones Bros of Ruthin are currently the subject of a prosecution by the Environment Agency for an "alleged" pollution incident involving a peat slide at Cefn Croes.

  3.4  The developing company was registered in Scotland; it had American shareholders and it is now wholly owned by Falck Renewables, an Italian company registered in Milan.

  3.5  There has been little benefit to the local community during construction, other than the provision of lodging and catering. Most of the roadside aggregate was quarried illegally from on-site "borrow-pits" without planning permission, and the concrete was made on-site.

  3.6  It is not unreasonable to question who drafted TAN 8: it is not impossible to discern the hand of the proponents of wind power.

  3.7  It is noteworthy that the sites identified by TAN as being suitable for wind power development consist of some of the wildest remotest mountain areas of Wales: eg Nant-y-Moch, Drosyol. There is a 53'% congruity with the public estate holdings managed by the Forestry Commission.


  4.1  It is difficult to avoid the conclusion that the Government's promotion of wind power is a cynical gesture to demonstrate that it is doing something to combat global warming: wind turbines are by their very nature very visible. Is it a sop to the green lobby?

  4.2  In this area, as in others, government policy is based on an artificial horizon of five years, imposed by the electoral cycle. Climate change and the energy needs of Wales and Great Britain require a proper long-term view.

  4.3  This being so, the English government and the National Assembly for Wales have embarked upon an expensive and radical programme of action, as outlined in the Energy White Paper 2003, which places undue emphasis on the development of renewables, in particular, wind (based on an alarmist view of climate change). The landscape of Wales is being sacrificed upon questionable economic, scientific and engineering arguments.

  4.4  For example, it is suggested that Wales can become a world leader in renewable energy. This may indeed be so in connection with technology still to be evolved (tidal wave, biomass); it is both futile and mendacious to assert that this can ever apply to on-shore wind turbine power when all the major players are foreign. Does Wales expect to emulate or indeed exceed the Danish, Spanish and German wind power companies—or indeed the Italian?

  4.5  It is clear to the CCAG that catastrophic changes are being imposed on the Welsh landscape in an over-hasty and panic stricken way. Devastation becomes widespread for very little gain or benefit.


  5.1  This response does not propose to analyse each provision of the Consultation Paper in detail. Indeed the arguments put forward above should render such analysis redundant. Neither does it propose to analyse the technical and engineering aspects of wind power. It must be pointed out however that the nomenclature employed is misleading: "windfarms" they are not: they are industrial installations, large and very visible, supported on substantial foundations, with substations and overhead power lines expanding across the landscape. The National Grid will need substantial reinforcement, and new transmission line and substations in wild places where currently there are no transmission infrastructures

  5.2  The Map 2—Strategic Areas is misleading in that it omits the Camddwr development proposals. This represents one of the largest wind power stations planned for Great Britain, or indeed Europe. Is this a mistake, or does TAN 8 presume that planning permission will be granted for this development?

  5.3  The map shows Nantymoch as a strategic area (Strategic Area D: Map 2). As with Cefn Croes and Camddwr, once that area has been developed industrially, all the remote wild places in Wales (apart from the National Parks) will have been developed. This is a prospect which appals all true Welshmen. Is it necessary to despoil a whole mountain landscape for developments which have, at best, only the most minuscule impact upon greenhouse gas reduction and electricity production?

  5.4  TAN 8 proposes relaxations of the planning rules governing wind power stations. Upon its past performance it is difficult to discern what difference this would make to the Planning Committee of Ceredigion County Council, given its previous rubber-stamp attitude towards all applications regarding wind power.

  5.5  When considering the Cefn Croes application the Planning Committee of Ceredigion County Council approved the application, after minimal discussion and against the professional advice of its own Planning Officer. Similarly, with applications for anemometer towers, the precursors of more wide-ranging wind power applications. In any case, the consent for the development of the Cefn Croes power station was taken in London, at the Department for Trade and Industry.

  5.6  The government targets are only targets; they have no force of law. They impose no legal obligations, although that is often how they are interpreted.

  5.7  It is not irrelevant to state that Ceredigion already produces more electricity generated by renewable power than it consumes: Cwm Rheidol Hydroelectric power station produces sufficient electricity for 49,000 households—but there are only 33,000 households in Ceredigion. Then there are now four wind power stations operating: Ystumtuen, Mynydd Gorddu, Ceredigion therefore produces more than three times its domestic electricity needs from renewables.

  5.8  In 1992 Dyfed County Council (CCC's predecessor) instituted a landscape assessment, to search for areas for wind power stations—but this was dropped because of planning blight.

  5.9  TAN 8 completely ignored the impact of mass wind power installations upon the Welsh tourist industry. Why gamble an industry which produces real jobs and wealth and which is here now against weak promises of a bonanza from wind? Ceredigion's main source of income is already tourism, which exceeds the income derived from agriculture. Indeed, farmers are exhorted to diversify into rural tourism.

  5.10  TAN 8 states that wind power sites will be "environmentally friendly"! George Orwell, would'st that thou were here now.

  5.11  TAN 8 (cl 43) refers to local community involvement. The issue of wind power is of paramount NATIONAL significance; to allow such issues to be decided by a few local communities—no doubt ill-informed and subject to overwhelming commercial and other pressures—is to demonstrate the most cynical application of the policy of "divide and rule".

  5.12  It should further be pointed out that a policy of local community consultation lends a spurious "democracy" to the issue of wind power. The consideration of wind power, renewable energy, conservation of energy supplies, reduction of CO2 emissions and global warming are complex and will be subject to controversy for many years to come. Such issues must be decided upon technical and, engineering and scientific the CCAG would argue, upon aesthetic grounds. And if it is suggested that wind turbines improve a landscape, surely it is impossible to improve upon nature?


  6.1  The basic problem with wind power is that the wind blows intermittently. There must therefore be "rolling" back-up. "Rolling" back-up means conventional fired-up power stations, whether coal or gas-powered (or even gas turbine fired ie jet engines). It takes considerable time to fire up such installations; they cannot be switched on instantaneously. "Rolling" back-up therefore represents duplication.

  6.2  Wind turbines cannot operate if the wind blows too strongly—or not at all.

  6.3  Engineering studies indicate that wind power stations can, at best, deliver only some 35% of their theoretical capacity. Over time their output is less. And at times, of course, their output is nil. Figures from OFGEM confirm that wind factories actually only produced 24% of their installed capacity.

  6.4  CCAG have endeavoured to get figures from the national Assembly for Wales, government departments, electricity supply companies and Falck Renewables for the daily or overall electricity production from Cefn Croes. The fact that there has been a refusal to disclose such figures leads to the conclusion that the expected amount of power generated has not been achieved. They seem unaware of the existence of the BETTA obligations and of the fact that power flows are metered in real time to determine the actual quantities of electricity produced and consumed at each location. The Select Committee is requested to press from this information.

  6.5  It would be instructive to know the amount of power generated by Cefn Croes on Tuesday, 22 November (a very cold day). CCAG suggests that it would be less than a torch battery.

  6.6  This question of the actual amount of electricity produced is the central and fundamental question regarding wind generated electricity. Cefn Croes, being the UK's largest on-shore wind power station to date and presumably state of the art, should be meeting its projected targets. That there has been a refusal to reveal its output figures leads, inevitably, to the conclusion that its projected targets are not being achieved. (If it were otherwise, the figures would be trumpeted to the four winds.)

  6.7  If this is the case—and CCAG has no reason to suppose that it is mistaken—the whole of the wind power policy is based on a fallacy. If Cefn Croes cannot produce, then no other wind power station can do so either. It would be irresponsible in the highest degree to base national policy on figures known to be wrong.


  7.1  The damage to the site at Cefn Croes is considerable: the peat has been bulldozed, the water table interfered with, the flora and fauna irrecoverably disturbed.

  7.2  The approach roads represent major engineering feats, with consequent damage.

  7.3  It is not an overstatement to describe Cefn Croes as an environmental and ecological disaster.

  7.4  The CCAG earnestly request members of the Select Committee to visit Cefn Croes, and to walk the site on foot, to gauge the extent of the devastation—in particular around the peat bog areas of turbines 19-21, 25-30 and 31-39.

  7.5  Such devastation will be wrought by most, if not all, new wind power station installations on the wet upland and afforested sites proposed under the Assembly's SSAs.


  8.1  The CCAG have good cause to believe that the construction of the wind power station at Cefn Croes was illegal, as it was built on land subject to the Forestry Act 1967, so that it contravened the objects of that Act and the provisions of the Wildlife and Countryside Act 1985.

  8.2  This submission is not the place to discuss complex legal issues but reference is made to the correspondence with the NAW (Mr Carwyn Jones) by the CCAG's Solicitors Messrs Hawkins & Co of Dudley, which gives an indication of CCAG's contention (see Appendix).

  8.3  The NAW, in placing reliance upon Section 39 of the Forestry Act, contends that it gives the Minister unfettered discretion to dispose of forestry land as he sees fit. If the NAW's interpretation is correct, it is difficult to discern the purpose of the Forestry Act in relation to its estate.

  8.4  CCAG strongly contends that such an interpretation is wrong, so that the objects of the Forestry Act, in relation to Cefn Croes and other similar sites in the future, have been and will be breached.

  8.5  Such disposals by the Minister will be facilitated by the proposed amendment to the Forestry Act currently under consideration by the Regulatory Reform Committee.

  8.6  It is unrealistic to expect the NAW, or the Forestry Commission to acknowledge the illegality which CCAg alleges. Accordingly, CCAG must take legal action to enforce the law.


  9.1  Much more attention must be paid to energy conservation. For example, wind power presently produces 1/27th (3.7%) of the power lost through transmission inefficiency.

  9.2  Public awareness of the need to conserve energy must be fostered, both by persuasion and compulsion (ie taxes, tax incentives). In particular short-haul air travel will need to be controlled; the public will need to be educated that cheap air travel is not an inalienable right.

  9.3  There are opportunities for Wales: development of insulation from wool; this would benefit sheep farmers. Photovoltaics, solar panels, geothermal and micro-hydro water warming devices are also relevant.

  9.4  The example of Basingstoke's successful energy conservation measures must be replicated widely.

  9.5  It if clear that the Western World faces considerable problems with oil and gas supplies. At the time of writing Brent Crude is $56.56 per barrel—and is not likely to reduce; gas prices are fluctuating wildly.

  9.6  This will have a most adverse effect on all Western economies, Wales included. One of the first industries to be affected will be airlines: it is not unreasonable to suggest that the age of cheap air fares is already over (see 9.2). There will be more demand for holidays in Great Britain; Wales is at present well-situated to benefit from such a trend—but not if mass wind power industrialisation has taken place. This is a most important argument against wind power stations in the Cambrian Mountains.

  9.7  Wind power stations are industrial installations; they must be placed near to industry and centres of population.

  9.8  The CCAG is aware of the problem of local rural unemployment, but the needs of the unemployed must not be allowed to dictate policy to the detriment of the greater good. In any case, the development of tourism represents the best chance of absorbing local unemployment. Wind power will not encourage tourism—and, if there is doubt about this, once mass wind power installations have been constructed, it will be too late to undo the damage.



    —  What's in it for Wales?

    —  What benefit does Wales derive from supplying water to Birmingham and Liverpool?

    —  What benefit will Wales derive from supplying Power to the National Grid? (It is accepted that certain individuals will benefit greatly.)

  10.2  The Select Committee is urged to recognise that wind power is not the answer to Great Britain's—and Wales's—energy problems.

  10.3  Wales's wild places must be protected.

  Aros mae'r mynyddoedd mawr—and am faint hirach?

  Corfwch Cefn Croes—Calfaria Cymru

Appendix:  Correspondence (recent) between Hawkins & Co and the Minister for Environment, Planning, and the Countryside NAW.

November 2005

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