Memorandum by the Campaign for Responsible
Energy Development in Tynedale (CREDIT)
1. I am writing in response to the House
of Lords Economic Affairs Select Committee's call for evidence
regarding the Economics of Renewable Energy.
2. I act as Secretary to the above organisation
(CREDIT), a community group formed to represent the views of local
residents (and other concerned individuals) faced with a seemingly
uncontrolled, unco-ordinated free for all by energy companies
seeking to build multiple large scale windfarms in the Knowesgate
area of Tynedale, Northumberland.
3. I stress from the outset that CREDIT
does not claim to possess either the technical or commercial expertise
to comment with any great authority on the relative costs of the
various forms of renewable energy production. However, we are
particularly keen to share our experiences with you in regard
to your questions "How do the external costs of renewable
generation of electricity—such as concerns in many affected
rural areas that wind farms and extra pylons spoil areas of natural
beauty—compare with those of fossil fuels and nuclear power?
How should these be measured and compared? Is the planning system
striking the right balance between all the different considerations?"
4. It is with particular regard to the last
issue listed above, that CREDIT seeks to draw the Committee's
attention to a factor which is routinely overlooked when the costs/benefits
of renewable energy (and in particular onshore wind energy) are
scrutinised, namely the enormous cost to the public purse in contesting
lengthy, extravagant and often wholly unnecessary public inquiries.
5. CREDIT wishes to advise the Committee
of its own experience but is acutely aware that such experience
is being repeated across most of the rural areas of England because
of the headlong rush by developers to take advantage of the huge
Government subsidies and liberalised planning regime which currently
favours the building of onshore windfarms almost to the exclusion
of everything else.
6. The Knowesgate area lies within the district
of Tynedale, in mid-Northumberland. The Committee might be familiar
with the term "Wilds of Wanney" and indeed the Knowesgate
area sits squarely within it. The area is deeply rural and, as
you would anticipate, is not densely populated. There are only
a few centres of population as such (Kirkwhelpington, West Woodburn,
Redesdale) with the remainder of residents living in small hamlets
or isolated farmsteads and cottages. There are few community facilities
and very little public transport. However residents place a high
value on the peace, tranquillity, cultural heritage and largely
unspoiled nature of their surroundings and many have founded small
businesses based on leisure and tourism activities.
7. Responding to central Government planning
policy directives, the North East Regional Assembly has prepared
a Regional Spatial Strategy (RSS)[27]
which requires that local planning bodies must include an overall
renewable energy target for the region with details of the contribution
to the total which will be made by sub-regional partners. In the
case of the County of Northumberland this equates to 212MW by
2010. It should be noted that this target is meant to cover renewable
energy from all sources and technologies. This sub target is not
broken down any further into district level contributions but,
given that the document recognises that onshore wind energy is
likely to contribute the largest share of the target, it goes
on to indicate that within Northumberland there are six "Areas
of Least Constraint" (ALC's) where onshore windfarm development
might be acceptable. The Knowesgate area of Tynedale is designated
as one of these ALC's.[28]
8. The RSS has been in production for some
considerable time and is now going through its final re-drafting
prior to formal adoption within the next month or two. It is,
in fact, this particular piece of planning policy which, in CREDIT's
opinion, has prompted the present situation in Knowesgate whereby
five different energy companies are vying to build six major windfarms
all within the space of a few square kilometres. That in itself
would be problematic enough, but the obvious difficulties are
compounded by the fact that the output from some of these windfarms
falls below the 50MW threshold whereby they are determined by
the local planning authority, whilst others exceed this threshold
whereby they are classed as Power Stations and determined by the
Secretary of State for BERR. Thus applications are submitted to
and decided by two different regimes. It is therefore not difficult
to understand the complexities which arise in considering the
matter of cumulative impact of multiple wind farm schemes.
9. As we have noted, the Knowesgate area
has been identified in the RSS as an ALC but it is clearly stated
that the area may be suitable for medium scale development which
is further defined as being between 20-25 turbines. However, despite
the fact that one particular energy company (AMEC) had been actively
investigating the possibilities of a windfarm on Ray Fell since
the mid-1990's, the policy steer provided by the Government in
the form of PPS 22, its Companion Guide, various Energy White
Papers, ministerial announcements and of course the system of
ROCs has resulted in other developers jumping on the subsidy bandwagon
and signing up willing landowners in the vicinity with a view
to erecting even more turbines. The local community has been completely
overwhelmed and, in no small measure, intimidated by the heavy
handed and irresponsible tactics used by the developers. Not only
that, but the issue is socially divisive, setting neighbour against
neighbour, landlord against tenant and, in some cases, family
member against family member.
10. The North East Assembly eventually recognised
the acute problems which this "gold rush" mentality
was causing in the Knowesgate area (although we should point out
that this situation is not unique to Knowesgate and that other
ALC's within Northumberland are being subjected to similar attentions)
and, as part of the RSS suite of documents, commissioned a series
of Landscape Capacity Studies from the Ove Arup partnership. Their
report recommended appropriate levels/locations of wind farm development
for each ALC which struck a balance between renewable energy generation
and landscape and visual considerations. The report concluded
that in the (two separate but adjacent) Areas of Least Constraint
at Knowesgate and Harwood there was potential capacity to accommodate
100MW of wind energy generation. The report suggests a fairly
even split of this potential total between the two ALC's ie. approx
50MW each.[29]
11. Sadly the slow response and belated
intervention by the Regional Assembly and its constituent partners
meant that by the time the landscape capacity report was commissioned
there were already three separate planning applications on the
table for the Knowesgate ALC alone; Steadings (21 turbines, H
J Banks) Green Rigg (18 turbines, Wind Prospect) and Ray Fell
(now 16 turbines, AMEC). These windfarms, totalling 55 turbines
with a combined output of approximately 150MW, are currently the
subject of a joint local Public Inquiry which commenced in January
2008 and is likely to continue until at least October if not beyond.
Unfortunately it appears that the fact that there is currently
an ongoing public inquiry into three existing applications has
done little to deter other developers and there are now three
further applications in the same vicinity at scoping/pre-application
stage which together could total a further 28 turbines. Indeed
at the time of writing this submission we have just been notified
through the post of NPower's intention to formally submit a planning
application for an eight turbine development at Kirkharle.[30]
Details of the current Public Inquiry and its associated documentation
can be accessed at http://www.persona.uk.com/tynedale/Tynedale.htm
12. There have been objections to all three
current applications from both County and District councils as
well as from the Northumberland National Park Authority, the Ministry
of Defence, Newcastle International Airport, NATS En Route Ltd
and English Heritage to name but a few.
13. CREDIT is playing a major role in the
PI and believes that evidence submitted to the Inquiry on the
basis of compliance with national and local planning policy, land
use, heritage, culture, ecology and, perhaps most fundamentally,
aviation concerns means that there are serious doubts about whether
any of these developments will be consented. Nevertheless, publicly
funded agencies have been compelled to participate in the PI at
great expense and, given the applications in the pipeline, may
well be forced to do so again in future. It is therefore unarguable
that the high levels of subsidy on offer make it worthwhile for
developers to engage in purely speculative applications on the
off chance that they might just be able to convince the powers
that be that the need for onshore windfarms as an alternative
source of energy outweighs all other considerations.
14. CREDIT do not believe that such blatant
free for alls were ever the intent of Government policy and we
understand that more enlightened Ministers and their advisers
are rightly concerned that there is now an over emphasis on onshore
wind energy almost to the exclusion of all other technologies,
many of which are far more efficient and far less intermittent
than wind turbines. The fact that the planning system is log jammed
from end to end with windfarm applications is not, as the British
Wind Energy Association would have us believe, due to intransigent
local authorities persisting in refusing permission for windfarms
in their area, but is rather a product of Government planning
and subsidy regimes which have been interpreted by the developers
as carte blanche to build as many onshore windfarms as they possibly
can irrespective of the impact on local landscapes and communities—and
all apparently in the name of national policy.
15. However it is worth noting that it is
often the case that many of the issues which PPS22 advises should
be resolved by the developers before planning applications are
submitted are left unresolved in the stampede to get applications
on the table. This is especially true of aviation matters where
the onus is firmly on the scheme promoters to prove that their
proposals will not affect aviation interests and/or safety. The
fact that three aviation bodies (MOD, NATS en Route and Newcastle
Airport) have all objected to each and all of the schemes under
scrutiny at the current (Knowesgate) Public Inquiry demonstrates
the difficulties which statutory and other interested organisations
have in convincing the developers that when they say no they mean
no.
16. The planning regime is therefore in
part responsible for encouraging this headlong rush for onshore
wind which, if left unchecked, will lead to an over -reliance
on a technology which is unreliable, intermittent and, on current
evidence thus far, has failed spectacularly to live up to the
claims made for it by its supporters in terms of both energy production
and reductions in CO2 emissions.
17. We have no doubt that other contributors
to this Inquiry will provide the Committee with convincing and
well-founded arguments regarding the real cost of on-shore wind
energy and we are not minded to repeat such arguments here. We
simply make the point that the cost to the public purse of processing
speculative and ill-conceived applications is rising exponentially
as more and more local authorities find their decisions being
challenged by large, well-resourced developers willing to ride
roughshod over local authorities and local communities.
18. We are aware that in terms of the present
Inquiry, Tynedale Council has set aside £250,000 to pay for
legal advocacy and expert opinion. A leading Councillor has indicated
to us off the record that the Council is expecting that it will
get no change from £1 million when everything has been paid
for. For a small rural district council this is a substantial
amount of money and it needs to be viewed alongside those costs
which will be similarly incurred by Northumberland County Council,
the MOD, Northumberland National Park and English Heritage in
providing evidence to the Public Inquiry. Given that this is not
the only windfarm Public Inquiry in which such agencies have participated
it is self evident that considerable sums of money are involved.
If such sums were multiplied throughout England the bill must
surely run into tens of millions of pounds already, with the likelihood
of more to come as applications continue to pile up in the planning
system. To the best of our knowledge this is a price which has
never been factored in to any previous discussions on the cost
of renewable energy.
19. CREDIT believes that the present situation
is inherently unfair and indeed many in our group speculate as
to whether this kind of "carpet bomb" approach by the
developers is a deliberate tactic designed to either intimidate
local authorities and local communities or bleed them dry of the
resources and political will to contest the applications. The
cost to local people participating in the process is prohibitive;
as CREDIT has already pointed out in their evidence to the Public
Inquiry[31]
for us to raise funds to contest one application would be onerous
enough, to contest three is quite simply beyond our means.
20. CREDIT would be delighted to provide
further information to the Select Committee should they require
it and would be most happy to appear in front of the Committee
if this was felt appropriate. In any event we trust you will find
this statement worthy of your consideration and helpful to your
deliberations.
9 June 2008
27 North East Regional Spatial Strategy Original Draft
2005 Policy 42 Onshore Wind http://www.northeastassembly.gov.uk/document.asp?id=614 Back
28
North East Regional Spatial Strategy with Sec of States Further
Proposed Changes Feb 2008 http://www.gos.gov.uk/nestore/docs/planning/rss_fpc/a_maps.pdf
(Page 225) Back
29
Ove Arup (for the North East Assembly) Windfarm Development and
Landscape Capacity Studies; Knowesgate and Harwood Forest June
2006 http://www.northeastassembly.gov.uk/document.asp?id=390 Back
30
Tynedale District Council Submission to Knowesgate Windfarm Public
Inquiry showing current windfarm proposals at planning and pre-planning
stage http://www.persona.uk.com/tynedale/PROOFS_STATEMENTS/Tynedale/Add_Docs/TDC-0-02.pdf Back
31
CREDIT Proof of Evidence Submission to Knowesgate Wind farms Public
Inquiry Dec 2007 http://www.persona.uk.com/tynedale/PROOFS_STATEMENTS/CREDIT/Proofs/CREDIT-1-1.pdf Back
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