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