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
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.
1. DIVISION OF
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
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
2. LACK OF
CO2 REDUCTION AND
PACT and DART would like to see more distinction
made between policies to achieve:
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
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.
7. WALES' ENERGY
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.
8. EMPHASIS ON
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.
6. CONFLICT OF
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.
7. TURBINES IN
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.
8. WILDLIFE IN
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.
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
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
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
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 ActList of Mammals and
Birds of Principal Importance for Conservation of Biological Diversity
Note: Sightings of species in Clocaenog Forestin
|Arvicola terrestris||Water vole
|Barbastella barbastellus||Barbastelle bat
|Lepus europaeus||Brown hare
|Myotis bechsteinii||Bechstein's bat
|Rhinolophus ferrumequinum||Greater horseshoe bat
||Lesser horseshoe bat|
|Sciurus vulgaris||Red squirrel
|Acrocephalus paludicola||Aquatic warbler
|Circus cyaneus||Hen harrier
|Emberiza schoeniculus||Reed bunting
|Melanitta nigra||Common scoter
|Miliaria calandra||Corn bunting
|Miliaria striata||Spotted flycatcher
|Passer montanus||Tree sparrow
|Perdix perdix||Grey partridge
|Pluvialis apricaria||Golden plover
|Sterna dougallii||Roseate tern
|Stretopelia turtur||Turtle dove
|Turdus philomelos||Song thrush
|Tetrao tetrix||Black grouse
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
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
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 initiativesdeveloping package
holidays, and an equine network.
Improving access to the countryside through
Enhancement of the area's characteristic
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
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
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.
10. RAMBLERS AND
The Ramblers' Association North Wales (RANW) welcomes the
opportunity to contribute to the debate on energy provision in
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;
"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 WalesPeter
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
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.
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
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
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
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
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.)
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
". . . 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:
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.
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
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
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
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)