Environment and Sustainability Committee

 

E&S(4)-01-12 paper 5

 

Inquiry into energy policy and planning in Wales – Evidence from The Cambrian Mountains Society

The Cambrian Mountains Society is a charitable body whose aims are :

(1)To promote, for the benefit of local communities, and of the wider public, measures which will sustain or enhance the landscape, natural beauty, biodiversity, archaeology, scientific interest, and cultural heritage of the Cambrian Mountains.

(2) To advance the education of the public in the landscape, natural beauty, biodiversity, archaeology, scientific nature, cultural heritage and geodiversity of  the Cambrian Mountains.

Introduction

1.  When it was published in its final version in 2005 the Welsh Government’s Technical Advice Note 8 (TAN8) represented a new and highly significant land use and planning policy. The document has the potential to have a highly significant impact  on the uplands of Wales..

2.  The application of TAN8 has given rise to a great deal of opposition. The intensity of that opposition is evidenced by the protest gathering at the National Assembly in Summer 2011. This was said to have had the largest  public attendance of any such meeting in the Assembly’s forecourt. Though Mid Wales was well represented on this occasion  similar events can be expected when the people in the valleys of South Wales appreciate the size of the turbine developments which threaten to dominate the rural surroundings of many an erstwhile mining community.

 

3.  It is the view of the Cambrian Mountains Society that TAN8 as a document has significant weaknesses of which some are inherent in the Welsh Governments brief to the international consultants who went on to designate the turbine development areas (the SSAs). The weakness were subsequently exacerbated by the Welsh Government treading lightly, if at all, on some important technical issues to which their attentions had been drawn before the publication of the final TAN8.

4.  The Welsh Government took no account of the large majority of responders who opposed TAN8 in whole or part in the consultation exercise on the draft.

5.  The Society offers constructive  comments on proceeding with a review of TAN8

 

The Welsh Government’s Approach to TAN8 and its targets.

6.  The sequence of events which decided the extent of the wind generating capacity to be provided by TAN8 rested on a total Wales renewable electricity generation of 4 terawatt hours. That total  was arrived at from general and political perspectives. Of that total the Welsh Government allocated a minimum 800 MW installed capacity requirement from wind generation. Onshore wind was regarded as the only commercial renewable energy technology within the market place.

7.  For the TAN8 exercise   the consultants’ brief was to identify sufficient land to provide that 800 MW minimum of wind energy capacity. Having been given this approach the consultants themselves acknowledged that their designated areas for turbine development (known as SSAs) would create what they called ‘turbine landscapes’  as a set of ‘least worse’ solutions in localities most would  regard as attractive. This one sided targeted approach is dated and out of step with the much more wholistic ‘ecosystem’ framework outlined in the Welsh Government’s draft Green Paper ‘Sustaining a Living Wales’

8.  Even at the inception of the TAN8 project  the  more normal and objective approach would have been to take account of the different kind of values which society at large may attribute to the countryside and non carbon wind energy respectively , then arriving at an optimal allocation of land to wind turbine development.. This would at least allow a more convincing  assessment of where the ‘public good’ might lie in balancing land allocation between turbine development and other land uses.  This  is in effect the economist’s ‘cost benefit’ analysis and is similar to that recommended by the UK National Ecosystem Assessment (UK NEA) which itself seems to be a means of implementing the ‘Living Wales’ procedures.

9.  The  approach taken in deriving TAN8 is dated as it has  few of the characteristics found in the Living Wales or UK NASE approach.. It leaves out important inputs, it has led  to sometimes incongruous  results, public unease and a  lack  of confidence in Welsh Government decisions..

The Lack of an Adequate Treatment of Landscape Quality in TAN8

10.               In the setting up of objectives in the early stages of TAN8 the most casual of approaches should have allowed landscape quality to be a factor for consideration even if only to meet expressed public concern. Yet outside the National Parks and the AONB’s landscape was not a consideration for designating areas (SSA’s) for turbine developments.

11.               What is surprising is the lack of involvement of the Countryside Council for Wales. They were asked for comment  only at the public consultation stage at which time the Welsh Government were not likely to reverse anything  significant. Neither did the consultants use CCW’s LANMAP as a guide. Thus they arrived at the anomalous position of  designating for  turbine development  areas that CCW , the Welsh Government’s own statutory advisors on landscape issues, have classified as of outstanding landscape quality.

12.               In the final version of TAN8 the following statement had been added to the original draft in respect of the designated turbine development areas (that is the Strategic Search Areas):


“Within (and immediately adjacent) to the SSA’s the implicit objective is to accept landscape change i.e. a significant change in landscape character from wind turbine development.”

 

This carte blanche statement does not fit well into  what purports to be a strategic document.. Taken at face value it would appear to remove even  the ability to object on landscape grounds to any  turbine development  in a SSA or close to it.

13.               The high value attached to Welsh landscapes is explicit  in other policies of the Welsh Government. The Society feels it is completely unacceptable to ignore landscape quality in designating areas for turbine development.

 

Dealing with Technical Matters in TAN8

14.               The indifferent level of planning in TAN8 has  lead to public disquiet not only on landscape. The problems which are current were foreseen at the time it was in draft.

15.                Even in the public consultation Dulas Engineering, leading consultants to developers, expressed unease about turbines being proposed ‘very close to the nationally acclaimed Pumlumon range’.  The British Wind Energy Association said ‘the assessments failed to include some key technical criteria ‘as well as expressing doubt about the Nant y moch SSA below Pumlumon. Developers stated concerns that public road access was not taken into account. National Grid Transco expressed particular concern that it had not been considered in the drafting of TAN8.

16.               TAN8 did not deal with these problems. Disquiet by the public owing to the very many long loads disrupting traffic for extensive periods over a difficult rural road network was underestimated. Though the consultants seemed to recognize possible transmission problems in Mid Wales, the Welsh Government having no powers in this respect, the TAN8 response was only to recognize the restricted transmission capacity and to support ‘in principle’ further grid lines.

17.               Other than the actual designating of areas for turbine development there does not seem to have been any integrated approach to possible turbine development. Transmission, public road access, site access over the hills being examples.

The Public Consultation

18.               The draft TAN8 went out for public consultation in July 2004. That consultation received something around 1700 responses which we believe to be the largest response to any Welsh Government consultation exercise.  The Cambrian Mountains Society has carried out a comprehensive analysis of the responses (ref(1)).  It showed only 10% of responders partly or wholly supported TAN8 and this total included the responses from developers with clear vested interest in supporting the draft.

19.                There were close to 1500 responses from individual people, couples and what appeared to be family groups. Of these 94% were against Tan 8 wholly or in part. Many of these provided careful arguments against TAN8 based on the well known problems of wind power and often on landscape quality.

20.               These responses were given short thrift. Within the 44 pages comprising the Welsh Government’s response to the TAN8 consultation it took barely two lines to dismiss some 1300 responders who for the most part questioned the use of wind power. There was no reasoned argument in response, the Government merely saying that wind is ‘is rooted in government policy’. This is difficult to equate with good government.

21.               The Welsh Government’s response to the public consultation gives no clue as to the extent of opposing views received.

22.               This approach to a declared exercise in public consultation  seems to us to be an affront to our democracy.

 

The Speed of Events

23.               The Arup consultants were appointed to their contract to draw up  the designated turbine areas  in April 2004 and the draft TAN8 was published for consultation on 13th July 2004 . Even allowing for the fact that significant work had been done previously it is an impressively speedy piece of work by Arup and a quick reaction by the Welsh Government. The timing of the consultation was criticized by some organization type responders who regarded the period of 13th-July-8th October as too short given that it was over the summer holidays.

24.               The consultants, probably realizing the significance of what they were proposing, made a recommendation that there should be a series of ‘road shows’ to inform the public of what was going on.. This recommendation was not implemented by the Welsh Government.

25.               In July 2004 the Welsh Government approved the European Directive on Environmental Assessment. This required an Environmental Assessment to be undertaken by the Welsh Government itself on new planning and land use policies. It was formally enacted by the Welsh Government on 12th July 2004 to be applied to all policies brought into being from 20th July. The draft TAN8 was published on 13th July evading by just seven days the requirement for a Strategic Environmental Assessment which the Welsh Government itself had promulgated. A call for the document to be subject to the Directive was not answered.

26.               The charge is that the Welsh Government moved with haste in order to evade the legislation it itself had enacted. At the very lest the ethics of the matter are questionable.

Conclusions on the Development of TAN8

27.               The issues raised above show that there were significant weakness in the way TAN8 was developed enough to make it a flawed document. They also  provide the case that In devising a new and highly significant planning and land use policy  the Welsh Government’s attitude was to push it through quickly taking into account only lightly, if at all, some important technical considerations. It disregarded the massively adverse public opinion expressed in the responses to its own consultation and acted with the haste required to evade its own environmental legislation.

The Need for a Review of TAN8

28.               .Since TAN8 was drafted in 2004 turbine heights have increased from around 50 metres to around 145 metres, public perceptions have developed on the wind issue and other technologies have developed too as well as the UK government’s energy policy.  Problems have arisen on transmission and other matters. The work underpinning TAN8 was undertaken by international consultants Arup who considered it would apply for 5-7 years from 2004.

29.                The Cambrian Mountains Society therefore calls for the Welsh Government to instigate a formal review of the application of Tan 8.

30.               .The overall methodology and framework of TAN8 is dated. A review should be based on the framework now being described in the green paper “Sustaining a Living Wales” and the recommendations of the UK National Ecosystem Assessment. The latter states

‘that the methods developed for conducting economic analyses of ecosystem services are capable of delivering decision relevant information to policy makers’

‘A Living Wales’ describes itself as

‘A strategy for the integrated management of land, water and living resources that promote nature conservation and sustainable use in an equitable way’
and
‘the ecosystem approach provides a framework within which the relationship of protected areas to the wider landscape and seascape can be understood and the goods and services flowing from ecosystems can be valued.’

It is these frameworks that should underpin a review of TAN8.

 

31.               The experience of the last ten years will allow the achievable renewable total generation required to be based on less arbitrary figures than the TAN8 assumptions. Similarly the allocation of generation capacities to the different renewable energy technologies can be put on a sounder footing..

32.               Within the approach there needs to be a further assessment of the comparative advantages of the ‘strategic’ approach as in TAN8 and a more criteria based approach in determining suitable turbine areas. It can be noted that neither England nor Scotland have adopted the strategic approach.

33.               Where other forms of non carbon generation come into being there needs to be  some credit taken for them in summing up Wales’ contribution to a low carbon energy policy.

34.               A rational and studied approach to the issues using the new ecosystem framework approach offers the best hope of  winning over the Society and people generally and renewing at the same time their faith in decision makers at Welsh Government level.

5th January 2012
The Cambrian Mountains Society

Ref (1) The details of the analysis of the responses to the Tan8 public consultation on the draft TAN8 can be viewed at
http://www.tan8.woodlander.eu