Select Committee on Welsh Affairs Written Evidence

Written Evidence from People Against Corwen/Cerrigydrudion Turbines (PACT) and Denbighshire Against Rural Turbines (DART)

  PACT and DART are two pressure groups lobbying against the spread of on-shore turbines particularly in the Hiraethog area of North Wales which is centred on the TAN 8 SSA A. SSA A is primarily made up of the Clocaenog Forerst plus Mwdwl Eithin to the South. Adjoining areas include: the historic A5 route to Holyhead, Snowdonia to West, Offa's Dyke to East and Denbigh Moors to North.

  We are very pleased to have been invited to submit evidence to the Inquiry into Energy in Wales by the House of Commons Welsh Affairs Committee.


  We have concern that there is a lack of clarity in the division of powers between the UK Government and the Welsh Assembly Government (WAG). Our understanding is that energy production in Wales is not a "devolved" responsibility. However, the publication of WAG's TAN 8 proposals make repeated references to ". . . the Assembly Government's targets for renewable energy production".

  In launching TAN 8, the two Ministers responsible state that TAN 8 ". . . will facilitate our sustainable development and energy strategy objective to make Wales a global showcase for clean energy by 2010".

  We suggest that this covert promotion of energy policy under Planning Policy Statements has resulted in a fundamental weakening of Local Authorities' powers of protection of the countryside of Wales.


  PACT and DART would like to see more distinction made between policies to achieve:

    —    CO2 reduction; and

    —    renewable energy production.

  At the energy policy level the TAN8 documentation blurs the distinction between the Kyoto Agreement (reducing greenhouse gases including CO2) and the separate EU Renewable Energy Directive (renewable energy production to safeguard future energy supplies).

  Our members strongly support both policies but are concerned that the lack of distinction between the two is preventing the use of the most cost effective ways of achieving both targets.

  This problem of confusion between the two issues was identified by the National Audit Office in 2005. It reported that the current Renewable Obligations system of reducing CO2 is several times more expensive than other measures. Even if the 10% renewable electricity target is met by 2010 it will cost £1 billion/year but will only save 1.7% of UK CO2 emissions.

  The same report acknowledges that direct investment in energy efficiency measures would produce better results, at half the cost. Reducing consumption directly reduces CO2.

  Separate investment could then be made into the development of renewable energy production that would provide the best long-term effectiveness whilst ensuring the least damage to the rural environment.


  We note that Wales is already generating nearly double the amount of electricity that is used within Wales and therefore its own energy needs are amply met. Even with the closure of Wylfa, Wales' electricity supply will be in surplus for some years to come.

  If it is considered that, for the future, this nuclear capacity needs to be replaced, it will need to be done by generating a capacity of a similar characteristic ie. that which is suitable for supplying the secure `base load' - reliable and one that is not intermittent.



  The detail in TAN 8 is almost exclusively about the development of on-shore wind power.

  For some reason the WAG proposals are a significant departure from the approach to renewable energy developments in England and Scotland. It deserts conventional landscape safeguards and, without corroboration, revises the balance of renewable energy in favour of onshore wind developments with virtually no increase in other renewables.

  PACT and DART argue against this one sided policy. We believe it is misguided. It would be much better for the future to concentrate on encouraging the development of a mix of technologies. A mix would give WAG a greater choice of options for the next generation of renewable generation systems and would not risk supply by focussing on a single source.


  The presentation sent directly to the Committee by Professor Cobbold gives an overview of his understanding of the effect of TAN8, and SSA A in particular. His conclusions are fully supported by PACT and DART and for that reason we ask you to look at his presentation in conjunction with this paper as we have not repeated his arguments.


  We ask the Committee to inquire into reports that the same "expert advisors" are being:

    —    contracted to advise on the development of policy at Assembly government level in Cardiff;

    —    consulted by local authorities on the modifications of Local Development Plans to accommodate the requirements of TAN 8;

    —    retained by the wind turbine development companies to produce the environmental impact studies required for each planning application; and

    —    involved in the commercial companies constructing and operating the turbine developments.

  We would maintain that each of the above strands of the development process should be meticulously independent not only to prevent corruption but to give confidence to the public.


  The SSAs include substantial areas of Forest; however turbines and trees do not mix, with a 30% reduction in output from turbines when placed in forestry. Although TAN 8 acknowledges this problem, stating "retaining trees is likely to reduce energy yield for the turbines" it offers no firm guidance on clear felling, leaving it to the local planning authorities to secure the "best outcomes".

  With the turbine developments being driven by private investment, there is going to be enormous pressure to clear-fell around turbines to increase the profit margins unless, clear and enforceable guidelines can be laid down at approval stage. It is estimated that up to 50% of the Clocaenog Forest could be clear felled.

  We ask the committee to look into the desirability of requiring the Forestry Commission to provide current felling and re-stocking maps and forestry design plans for all the areas affected by TAN 8 and that these should be integrated into the TAN 8 planning process.


Tree cover

  The tree cover in the UK is still very low; only a few countries have a lower percentage than the UK. The Clocaenog in particular is one of only three Forestry Commission areas in the UK in the middle of a long term trial of maintaining continuous tree cover. How can this policy be so easily turned around without due consideration?

  Wherever there is a woodland, both broadleaved and coniferous, there is an increase in biological diversity. Ecologists are at last recognising the variety of ecology that occurs in coniferous forests. It has only recently been found that the canopy of a coniferous forest supports a similar ecology to that on the woodland floor of a broadleaf forest.

  An example of this is the dormouse (a European protected species) which in the Clocaenog is living and breeding up in the canopy.

  As a result of TAN 8, even with the minimum felling of keyhole slots for each turbine and access routes for construction, the integrity of the forest will be compromised. The pockets of forest that will remain will not support the same diversity of wild life as does the present integrated whole.

Red squirrels

  Clocaenog has the only viable population of Red Squirrel living in Wales. The Red needs a variety of trees of different age-class, mainly medium to mature age, to stand any chance of strong survival. For example, its main food, Norway Spruce cone seed may only be produced once in three or four years in any quantity. There needs to be other tree species of seed bearing age such as pines, larch, sitka spruce, alder and birch to fill the gaps. Their cycle of major seed bearing years will be different from the Norway and will help to guarantee survival. The Red squirrels need continuous cover to move around in search of their food supplies. There is a strong likelihood tha fragmentation of the forest will have a negative effect on their ability to survive.

Other rare species including pine marten

  There are several other species of importance in Clocaenog such as Dormouse, Newts, Bats, Otters, Hares, Adders and others. There are enough good reports of Pine Marten presence for a 95% certainty; the fur and photographs giving the final proof are not far behind. This is a mammal that about 10 years or so ago had people speaking out and saying that it was extinct from Wales. Should we be destroying the habitat of something as rare as this without due consideration, for something as inefficient as Turbines?

  There has also to be full consideration given to the smaller items such as plants and insects. The rare Moonwort is present in Clocaenog. There will be a whole range of species thriving in Clocaenog, some may be new to science or at least to Wales. A few years ago a survey of Veteran Trees in nearby Chirk Castle Estate found a species of insect, new to science, in one of the trees.

CRoW Act 2000

  Section 74 of this Act places a duty on WAG to have regard in exercising its functions to conserve biological diversity in accordance with the UN Convention on Biological Diversity. In May 2003, Carwyn Jones the Minister for Environment, duly published a list of species and habitats that WAG considered important for that purpose.

  Sightings have been recorded in the Clocaenog of seven out of the 10 mammals and 11 out of the 23 birds on this published list of protected species. This diversity in birds and mammals in the Clocaenog would indicate that a large percent of the 59 protected reptiles and invertebrates and 68 protected species of plants, fungi and lichens are also present.

CRoW Act—List of Mammals and Birds of Principal Importance for Conservation of Biological Diversity

Note: Sightings of species in Clocaenog Forest—in bold
Arvicola terrestrisWater vole
Barbastella barbastellusBarbastelle bat
Lepus europaeusBrown hare
Lutra lutraOtter
Muscardinus avellanarius Dormouse
Myotis bechsteiniiBechstein's bat
Pipistrellus pipistrellus Pipistrelle bat
Rhinolophus ferrumequinumGreater horseshoe bat
Rhinolophus hipposideros Lesser horseshoe bat
Sciurus vulgarisRed squirrel
Acrocephalus paludicolaAquatic warbler
Alauda arvensisSkylark
Botaurus stellarisBittern
Caprimulgus europaeusNightjar
Carduelis cannabinaLinnet
Circus cyaneusHen harrier
Crex crexCorncrake
Emberiza citrinellaYellowhammer
Emberiza schoeniculusReed bunting
Melanitta nigraCommon scoter
Miliaria calandraCorn bunting
Miliaria striataSpotted flycatcher
Numunius arquataCurlew
Passer montanusTree sparrow
Perdix perdixGrey partridge
Pluvialis apricariaGolden plover
Pyrrhocorax pyrrhocoraxChough
Pyrrhula pyrrhulaBullfinch
Sterna dougalliiRoseate tern
Stretopelia turturTurtle dove
Turdus philomelosSong thrush
Tetrao tetrixBlack grouse
Vanellu vanelluLapwing

Ecology on Mwdwl Eithin

  Records that have been kept of wild life and Fauna on Mwdwl Eithin, the other part of SSA A, has also revealed a very extensive range of ecology which would be severely disturbed by the erection and operation of wind turbines.

Ecological survey and environmental impact study

  Because of the CRoW Act, the number of protected species involved, and the difficulty of sighting and quantifying their presence, there must be a full ecological survey carried out in the whole of the SSA A area prior to permission being granted for wind turbines. This must involve specialists in each field of study, must occur several times in the year and last an absolute minimum of two, preferably five years. In that survey full consideration must be given to the effects of fragmentation.

  This should be coupled with a full environmental impact study that includes detailed consideration to the effects of: forest fragmentation, geological and hydrological changes due to construction of access routes and foundation works, and noise during construction and from the turbines

Bird strikes

  There is likely to be a problem with bird strikes. Many species of birds will be at danger as they will be flying higher to clear the surrounding forest canopy. Specific data is difficult to measure as many strikes will be during the hours of darkness and nature, ie foxes, badgers, and other predators, will be clearing a lot before daybreak. Time of year is also an important factor, for example, it would be no good doing a count in February if the strike rate was happening when migration was taking place.


  Tourism is one of the main industries in Wales and is still growing. In 2001 it accounted for 7% of GDP at a value of £2.6 billion from 10.9 million tourist trips providing 100,000 direct jobs plus 10,000 self employed (source WTB).

Why people visit Wales

  In 2003 an independent study was commissioned by WTB of the "Impact of Wind Farms on Tourism in Wales". In the survey of visitors, four out of five respondents indicated that "the beautiful scenery" was a key influencer. Other key positive elements were "a good place to relax and get away from it all" and the "unspoilt environment".

  88% of those interviewed agreed that "The attraction of peace and quiet in the countryside and the coast of Wales" was an important factor.

  Local visitors would add "the quality of silence".

Visual impact of turbines

  If TAN8 is implemented the majority of Wales will be visually affected with large areas of the National Parks and AONBs also affected. How this is built up can be seen from the map on the following page.

  This map does not take account of off-shore turbines but there would be a double effect in the coastal areas.

  The visual effect of the on-shore turbines is so extensive because turbines need to be placed on the high ground. With the scale of turbines now in use it is not possible to find areas to site them that cannot be seen for many miles around.

National policy to increase tourism

  In the Clocaenog area specifically, there has been an extensive drive over the last five years to increase tourism and assist farmers to diversify. In 2002 an Environmental Strategy and Action Plan for the Hiraethog area (centred on the Clocaenog Forest) and part funded by the EU, proposed several objectives:

    —    The development of the local economy through sustainable green tourism initiatives—developing package holidays, and an equine network.

    —    Improving access to the countryside through wildlife education.

    —    Enhancement of the area's characteristic landscapes feature.

Horse riding

  The Wales on Horseback initiative, again part funded by the EU, is a direct result of the Hiraethog Action Plan. This is now up and running. In principle, riders book a holiday through Wales on Horseback which plans a trail and makes overnight arrangements. Riders trek through the area, stopping overnight for B&B along the way.

  In principle horses and turbines do not mix. Whilst some experienced riders may be able to ride near turbines, issues of safety would prevent holiday rides being planned near to turbines. The effect of TAN8 would therefore be to remove the whole of Hiraethog central area - threatening the viability of the scheme in this part of North Wales and preventing many properties within the area benefiting from this earning potential.

Holiday lets and bed and breakfasts

  Wales Tourist Board has been encouraging property holders to invest in high quality holiday lets and B&B's. There has been a substantial growth in this market and this success has resulted in benefit to the owners and also to the rest of the tourist market as the visitors are resident and use all the surrounding services.

  Experience from our members confirms that the prime reasons for visiting the Clocaenog Forest area is tranquillity, peace and quiet, and the wilderness.

  TAN will change the nature of the area; it will become industrialised, it will be noisy, there will be structures out of all proportion to the surrounding landscape. This is the opposite of what visitors say they want.


  Llyn Brenig is at the centre of the SSA A and is surrounded by land identified for turbines. Llyn Brenig has been developed by the Environment Agency and is now an internationally recognised centre for fly fishing. Many thousands of people are attracted throughout the season with a large number coming from abroad.

  Fishing is the epitome of tranquillity. The proposed turbines will be near, visually intrusive and generate noise from all directions.


  Evidence on rambling is given under a specific heading later on. The Clocaenog area is an 1½hr drive from Liverpool and Manchester and easily accessible to the whole North West of England.


  Under the WAG strategy "Woodlands for Wales", launched by the Minister for Rural Affairs in 2001, one of the five strategic objectives is to develop woodlands for Tourism. It reports that 11 million visits are made to Welsh forests each year.

  Under TAN8, all the woodlands identified in the SSA's will be fundamentally altered by effects of extensive felling and erection of structures over three times the height of mature trees.


  The Ramblers' Association North Wales (RANW) welcomes the opportunity to contribute to the debate on energy provision in Wales.

  RA Wales (RAW) is submitting a separate response which has the full support of RANW.

  The CRoW Act was placed on the statute book in 2000. The main plank of this is the recognition that the countryside makes a significant contribution not only to the economy but also to public wellbeing and that public access to mountain, moor, heath and down is in the national interest. The Act sets out plans to improve the Rights of Way network and addresses countryside protection.

  Appendix C attached provides evidence of government intention to meet public aspiration.

  The Consultation Paper on Countryside Access February 1998 provides evidence of government intention to meet public aspiration; it states:

    "Greater freedom would become self defeating if the landscape itself were harmed, its tranquillity eroded and its wildlife put at risk . . ."

  TAN 8 has designated seven areas (SSAs) for major wind power development. Within these areas there is a predominance of land owned by the Forestry Commission, to which open access was agreed two decades ago. In addition the SSAs cover land to which the public has only this year been granted the right of access. Outside the seven SSAs, access land, almost by definition, is deemed suitable for wind power installations.

  The RANW believes industrial installations, as wind turbines clearly are, on access land and land crossed by rights of way and recognised as walking country, are not only totally contrary to the principles of the CRoW Act but are damaging to the economy. The people of Wales and those who visit are being obliged to witness the industrialisation of the very landscapes that are synonymous with Wales and which by statute the British government has judged should be made accessible to the populace.

  Quoting from the Hobhouse Report 1947 from which the CRoW Act was born,

    "They (the proposals) will enable active people of all ages to wander harmlessly over moor and mountain, over heath and down and along cliffs and shores and to discover for themselves the wild and lonely places, and the solace and inspiration they can give to men who have been `long in city pent'. Thus we believe an effective contribution will be made to the health and well being of the nation, and an important step taken towards establishing the principle that the heritage of our beautiful countryside should be held in trust for the benefit of the people".


  The walking public are the biggest contributors to the economy of rural Wales. (The Economic Value of Walking in Rural Wales—Peter Midmore, Professor of Rural Studies University of Wales Aberystwyth, Ramblers' Association March 2000)

  The foot and mouth crisis demonstrated the importance of an open countryside to the Welsh tourist industry. WAG has set arbitrary targets for wind power installations imposing wind power on the people of Wales without their consent. Wind does not and cannot, meet the energy needs of the people of Wales, whilst its contribution to a reduction in global warming is infinitesimal and irrelevant.

  From the perspective of the CRoW Act, RANW maintains that WAG's arbitrary strategy, which is leading to the industrialisation of the Welsh countryside, runs counter to the wishes and benefit of the people of Wales and to the intention enshrined in UK legislation.

Mary Robinson

Area Countryside Secretary Ramblers' Association North Wales


  Heavy civil engineering works associated with wind farms can lead to catastrophic consequences to potable water, an example of this happened at Glendaruel, Argyll, when 17 dwellings lost their water supply due to Cruach Mohr Wind Turbine development.

  This had been envisaged by the Scottish Environmental Protection Agency (Ref: Letter SEPA dated 28 May 2002) The developer Scottish Power, at its own cost, had to provide the community with pumped potable water.

  Conwy and Wrexham Councils have the same fears with regard to possible disruption, loss or contamination of water supplies due to wind farm proposals. (Ref: Conwy Council Letter and Wrexham Council Email)

Residents on spring water

  SSA A zone A and B have approximately 150 residents in Conwy reliant on spring water and streams for their potable water supply. There are also a number of farms that rely on this water source to feed animals. Below is a map showing the springs in Denbighshire supplying homesteads and farms.

  Who would be responsible for the loss of water to any of these properties?

  Conwy CBC have made it clear during the scoping process of Mwdwl Eithin that they would not be responsible to any loss or damage to the existing water supplies and that this would be a civil claim.

  We believe this is unacceptable and that the developer should retain responsibility in perpetuity.

Scale of construction

  SSA A has been earmarked for 140MW of installed capacity, this could equate to 70 to 100 wind turbines each requiring foundations of at least 2.5 metres, crane pads, trenches for cabling at least 1 metre deep, miles of access tracks along with borrow pits (a green word for local quarrying). The ph values of groundwater can be drastically changed by the import of stone and aggregate to construct crane pads and access tracks. Borrow pits on site are used to ensure that the aggregate required for these is of a similar stone and thus ph to the surrounding geology. However the quantities needed could create devastating disruption to the aquifers and ecology of the area. All the above could have detrimental effects on the aquifers, streams and springs supplying the dwellings within the forest.

Turbine foundation at Tir Mostyn

    "Aquifers close to, or outcropping at, the ground surface are more vulnerable to pollution or physical damage that could harm both the quality and flow of the groundwater. The flow of groundwater is slower than surface water, and the deeper into an aquifer the water is, the slower it moves. This means that if groundwater becomes polluted and the pollution moves deep into the aquifer, the water can potentially remain polluted for a very long time. This could subsequently lead to a deterioration in the quality of drinking water supplied from a groundwater source or damage vulnerable groundwater dependent rivers and ecosystems" (Ref: Environment Agency 2004 Water resources Groundwater.)

12.  NOISE

Effect of noise on health

  There is now good evidence that noise from wind turbines can have serious effects on the health on people dwelling up to a mile away from turbines. A recent report to the Royal College of General Practitioners by Dr. B. Osborne puts the evidence of damage to health caused by noise from wind turbines onto a solid medical foundation. The van den Berg Report mentions a pulse like sound along with further noise issues associated with turbines (ref. Euronoise Conference 2002 - Wind Turbines at Nigth).

  DEFRA, commissioned Casella Stanger to provide general information on low frequency noise. (Ref: Low Frequency Noise Technical Research Support for DEFRA Noise Program 2001) One of their findings indicates wind turbines emit low frequency sound waves, which could lead to sleep disturbance, headaches, stress, annoyance, unease, fatigue and possible nausea.

  Furthermore Dr Amanda Harry had come across the same symptoms as described above in all but one of 14 people living near the Bears Down wind farm at Padstow, Cornwall consisting of 16 turbines. She reported that the residents were suffering from the effects of Low Frequency Noise, due to the turbine development.

  Local residents living within a mile of Hafoty Ucha wind farm have experienced a repeated thud sound emanating from the turbines at low wind speeds. This noise nuisance has been registered with the Public Protection officer at Conwy CB Council. The newly built Tir Mostyn wind farm in Denbighshire is audible from certain residences in Llanfihangel GM 2.5 kilometres away.


  Residents in the SSA A enjoy long periods during the year of absolute silence. Visitors and tourists refer to this.

  The EU Directive on Environmental Noise 2002 states: "The vision for the year 2020 is to avoid harmful effects of noise exposure from all sources and preserve quiet areas"

New research required

  In the TAN 8 section 2.17 and 2.18 "Low Frequency Noise", the core information used to arrive at the stated conclusions is from a survey carried out 9 years ago. Technology has advanced at such a rate since that date we are now looking at turbines three times the height and four times the generating capacity.

  We would like to see new research commissioned in this area.

Developers noise surveys

  Developers and their agents generally conduct noise monitoring over a two week period. From our experience the surveys have been carried out during the winter months, harnessing the noisiest time of the year as a base foundation for the acceptance of background noise levels for the whole year. This abnormally high background sound level is extrapolated to surrounding properties and is then used in the developers Environmental Impact Studies to predict that the noise of the proposed turbine development will not be heard above the background noise.

  We would like to see noise monitoring surveys conducted on a continuous basis over the four seasons at all the properties that are likely to be affected, thereby giving a true reflection of background noise levels for the areas concerned.

  We also ask that noise monitoring is carried out after completion of the development by an independent acoustics expert, at cost to the developer,


  TAN 8 states that one of the characteristics of the chosen SSA's is that they are sparsely populated. For the significant number of people who live there, the quality of life provided by the unobstructed views of beautiful countryside, tranquillity and quiet, is the counterbalance to the inconveniences of living in these isolated locations. These are qualities that they have chosen and enjoy and will be taken away, without any benefits in return, with the construction of the proposed turbines.

Public inquiry ruling in favour of private interest

  Potentially harmful effects on the value or saleability of property or upon the economic prospect of a business are often dismissed by planning officers as a private matter. However in July 2004 a Public Inquiry refused appeal to build 6 turbines at Llethercynon, Powys [ref:APP/T6850/A/03/1122720] on the basis that:

    ". . . the visual impact of the proposed wind farm on each individual resident living in the vicinity is an aspect of the public interest [our emphasis] . . . and did not consider that it is in the public interest to impose on them the severe impact that would result if the proposal went ahead."

  According to this judgment decision makers are required to take into account adverse impacts on private interests of all kinds and on residential amenity, even to the extent of interpreting property price effects as an index of adverse impacts.

  In public sector projects, "blight" on properties triggers compulsory purchase or compensation.

  In correspondence with WAG, the Minister has replied that no compensation can be legislated for as the turbine developments are to be carried out by private companies. It seems unfair and inequitable that this should remain so, as public funds are being used to subsidise the private wind turbine operating companies who are responding to a WAG development policy.

  The Minister refers to the courts, but most home owners will not have the resources nor the knowledge to sue the developers.


  We request that compensation is built into the planning process to include the following issues:

    —    Damage to Water Supply

    This has been dealt with under the heading of Hydrology. It should be the responsibility of the developer to permanently rectify at its own cost for any degradation of water supply to properties and farm land caused by the development, without the need to recourse to the courts.

    —    Noise

    The issue of noise has also been dealt with under its own heading. The operation of Tir Mostyn wind turbines has demonstrated, to those living there, that they produce a noise that is clearly audible above background sounds. The concentrations of turbines required in SSA A would create a cumulative effect. Local people are used to having long periods of silence. This is one of their rights.

    —    Visual Impact

    The enjoyment of uninterrupted views is one of the rights enjoyed by those living within and near to SSA A. The erection of up to 100 turbines, over three times the height of mature trees, will industrialise the landscape.

    The views which are rural and natural and tranquil are another of the rights of those living there that will be taken away by implementing TAN8

    —    Loss of Tourism Income

    As referred to earlier under Tourism heading, the turbines will destroy a key attraction for tourists, "the attraction of the peace and quiet of the countryside". This will mean a loss of income for those that have already invested in their tourist business

    —    House Values and Saleability

    There is increasing evidence that the effect of all the above does have a harmful effect on the price of property. In the SSA A this effect will be magnified by the cumulative result of noise and visual impact of the number of proposed turbines.

  Where a property cannot be sold because of "blight", compensation for the full value of the property should be made.

(Annexes not Printed)

December 2005

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2006
Prepared 20 July 2006