Select Committee on Welsh Affairs Written Evidence


Written Evidence from Mynnydd y Gwynt Ltd

1.  INTRODUCTION

  Mynnydd y Gwynt Limited is pleased to submit this evidence to the Welsh Affairs Select Committee for their Inquiry into Energy in Wales. The company faces windfarm development issues in respect of TAN 8 guidance on the siting of windfarms and would appreciate the Committee's consideration of possible solutions.

  As this case is unlikely to be unique, it would seem appropriate that the Committee might consider it as part of their inquiry. The degree of flexibility or discretion that local authorities may adopt in their implementation of the TAN 8 is likely to play an important role in helping Government to achieve its 2010 renewable energy targets. Public consideration by the Committee of the circumstances of the Mynnydd y Gwynt proposal could therefore greatly contribute to this wider debate.

2.  BACKGROUND

Planning Policy Wales—TAN 8 Planning for Renewable Energy

  In July 2005, the Welsh Assembly Government published the Technical Advice Note 8, known as "TAN 8". This document supplements Planning Policy for Wales and the Ministerial Interim Planning Policy Statement (MIPPS) on Renewable Energy.

  TAN 8 provides detailed guidance on the siting of windfarms. The strategic assessment of the opportunities for major wind power capacity in Wales is based on the premise that there are environmental, landscape, technical national security and economic constraints that will determine the location of major wind power proposals.

  TAN 8 proposes seven "Strategic Search Areas" (SSAs A—G) for preferred wind farm locations. Indicative targets have been set to achieve at least 800 MW of onshore wind generation. The SSAs have been designated to maximise efficiency, to allow investment in distribution infrastructure and to minimise environmental impact.

  Mynnydd y Gwynt Limited wishes to develop a windfarm in Mid Wales to contribute to Government renewable energy objectives. However, the restrictive terms of TAN 8 are such that the Company is seeking support to allow Powys County Council and the Welsh Assembly Government to vary and/or substitute part of an SSA to reduce environmental impact and achieve certain delivery of renewable energy targets.

  As such, this case highlights the potential limitations to windfarm development which may result from overly rigid interpretation of TAN 8 guidelines. The Company believes this is therefore relevant to discussion of renewable energy in the Welsh Affairs Select Committee Inquiry into Energy in Wales.

3.  THE PROJECT

  The company, Mynnydd y Gwynt Limited, is proposing to develop Mynnydd y Gwynt Windfarm in Mid Wales located at Y Foel and the Sweet Lamb Rally Complex, Glanrhyd, Llangurig. It will comprise 27 x 3 megawatt turbines to be erected on 2000 hectares of agricultural land. The purpose of the development is to generate 75MW per annum of electrical power without releasing carbon dioxide to the atmosphere and thus assist the UK meet its target for the reduction of greenhouse gasses under the Kyoto Protocol.

  The windfarm will involve the development of less than 6 ha for the turbine bases and access tracks on upland grazing land, all within a 2000 hectare site. The site is located in the Cambrian Mountains at the head of the River Wye, approximately 20 miles east of Aberystwyth and 5 miles west of the nearest settlement, Llangurig. The highest point of the site is Y Foel at 546m.

  A full Environmental Impact Assessment (EIA) of the development in relation to humans and sensitive landscape and ecological areas is being prepared. The site is well placed with access to the national trunk road network direct from the A44.

  The site is subject to a Tir Gofal agreement and is principally in agricultural use. There is an extensive track network within the site and this is used as a Motor Rally Centre This is an example of a successful farm diversification business, providing training and testing facilities for rally teams and individuals as well as having a variety of competitive layouts.

  Development of Mynyydd y Gwynt offers a unique opportunity to meet Government renewable energy objectives whilst reducing environmental impact elsewhere in Mid Wales. For these reasons, Mynnydd y Gwynt was originally prioritised for inclusion in a TAN 8 Strategic Search Area. At the time however, the site was subject to a Ministry of Defence objection in respect of flightpath designation. Following detailed consultations concerning design and turbine types, the MOD objection has now been withdrawn. However, this decision was reached too late to include Mynyydd y Gwynt in the relevant TAN 8 Strategic Search Area.

  The proposed site is thus currently not included in Strategic Search Area D, although it lies immediately to the eastern boundary of the Area. In order to proceed, the developers would need agreement by the local authority, Powys and the Welsh Assembly Government to extend SSA Area D.

  At present Welsh local authorities are operating strictly within the TAN 8 guidelines of the SSAs. The developers are seeking local authority, Welsh Assembly Government and Parliamentary support to extend Area D and/or substitute Mynnydd y Gwynt with part of SS Area B or C, by demonstrating that Mynnydd y Gwynt would have less environmental effect than developments in these areas.

4.  STRATEGIC SITE AREA D

  TAN 8 allows for the refinement of an SSA by local planning authorities and the developers hope this can mean an extension of SS Area D. However, under TAN 8, land adjacent to an SSA can only be considered for windfarm development where it has a lower or equivalent environmental footprint than other land within the local SSA.

  Mynnydd y Gwynt (at Y Foel OS reference 283346 285077) was initially considered for inclusion in the Nant y Moch Strategic Site Area D. It has a capacity to generate in excess of 75MW. As stated above, it was ruled out simply because of an MOD objection that has since been rescinded. As a result, Area D now encompasses land to the west of the Plynlymon Ridge.

  The site at Mynnydd y Gwynt performs better on all counts than land to the west of Plynlymon Ridge in relation to the criteria in TAN 8 because it will have a lower impact on the Snowdonia National Park and the important settlements of Aberystwyth and Machynlleth.

  However, a situation has arisen whereby because Area D has now been defined that Mynnydd y Gwynt land that has been in the original area cannot now be considered because it would extend the visual effect of turbines, albeit into a remote, sparsely populated area to the east.

  This exact application of the designated SSA area is to ignore the fact that the Mynnydd y Gwynt site performs better than the land in the current Area D for the following reasons:

    —    Mynnydd y Gwynt meets all the criteria for a Strategic SSA listed in TAN 8, combined with a high windspeed (9 m/s) and most importantly, an existing access and track network that is substantially complete, meaning that the site can be developed with minimum additional landscape impact.

    —    The site could make a contribution of 75MW of installed capacity (over 50% of identified Area D potential) and would reduce the pressure on sensitive landscapes within Area D.

    —    Land within the SSA D, the Nant y Moch area, is very remote and has few access points. Developing land within SSA D would require construction of a significant number of roads that would affect the landscape of this remote and wild area.

    —    Mynnydd y Gwynt is visually constrained by the Plynlymon ridge to the west and north. This prevents any visual intrusion into the National Park to the north and to the towns of Aberystwyth and Machynlleth. This is not the case to for all the land currently defined as SSA D.

    —    The land within the current Area D is a more remote and wild area. It is therefore much more sensitive to development within it. The Mynnydd y Gwynt site has a history of development from lead mining to rallying—developing this site would therefore not violate a presently virgin, wilderness area.

    —    Most importantly, feasibility studies show that Mynnydd y Gwynt can deliver and make a significant contribution to the TAN 8 Targets for 2010. It is unlikely that any capacity to extend the grid to take power out of SS Area D would be available for at least seven years. Development within Area D is thus unlikely to make any contribution to the generation of renewable energy before 2013, three years after the target date set for TAN 8.

    —    It is a very sparsely populated area and development of this site would relieve pressure on other, more densely populated areas of Powys covered by Areas B and C.

5.  POSSIBLE ALTERNATIVE SOLUTIONS WITHIN POWYS

  As currently constituted, TAN 8 does not allow for the substitution of land between SSAs, even where development of an alternative area might have a lower environmental impact within the local authority jurisdiction.

  If, as outlined above, the local authority Powys could amend Area D to include Mynnydd y Gwynt, it could, for example, also substitute this for a less appropriate, more sensitive site in Area C.

  Area C, Newtown South, is a small area 5 km to the south of Newtown where development has to create the potential to add additional environmental impact on the settlements of Newtown, Llanidloes and Rhayader. Area C is identified as having the capacity of 70MW. Due to its proximity to Newtown, it is also however likely to exert a significant visual impact on Newtown, a major settlement in Powys.

  The same capacity of up to 75MW could be accommodated within Mynnydd y Gwynt without causing the same degree of visual impact on important communities. This would allow Area C to remain unspoilt and undeveloped. Additional capacity could also be achieved without significantly adding to the visual impact by re-powering existing wind farms in the area using modern higher capacity turbines.

  However, due to the drafting of TAN 8, Mynnydd y Gwynt cannot be considered as replacement capacity for Area C as local authorities only have the ability to refine an SSA, not substitute or exchange land within them.

6.  CONCLUSION

  The Mynnydd y Gwynt site is highly suitable for inclusion as a preferred site in the Strategic Site Area D. Its exclusion from TAN 8 was on the basis of an MOD objection that has since been resolved. It does not seem logical therefore to continue with a policy that seeks to exclude this area and instead develops land elsewhere that does not represent the best environmental impact option. It also means that the Government could miss an opportunity to meet a key objective of renewable energy generation from Wales by 2010.

  In considering this matter, the developers of Mynnydd y Gwynt are most grateful for the opportunity to bring this case to the attention of the Welsh Affairs Select Committee as part of their Inquiry into Energy in Wales. We would welcome a site visit by Members and meanwhile would be pleased to supply any further information, including copies of all technical, planning and environmental studies and plans that would help the Committee's deliberations. We would also welcome an opportunity to give oral evidence and to bring forward expert wind energy and environmental witnesses engaged in the project.

December 2005





 
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