Environment and Sustainability Committee
Inquiry into Energy Policy and Planning in Wales

EPP 173 – Eco Cymru



 Energy policy and planning in Wales response


Thank you for your consultation letter. We did appreciate its comprehensive brevity, and open-ended questions.


Many did not see the consultation, who would like to respond to it, eg NFU Wales policy officer. 

It is not part of the open consultations on the government website. Perhaps a wider consultation could be started.


In response to Page one bullet points:


It will be difficult to impossible to fulfil our commitment to be a low carbon sustainable country without more control over major energy production.

 For example if we get more coal fired generation this will undermine all our ghg reduction achievements, and compromise our international SD image.


Re the petitions; there were no petitions for people to sign who favour wind farms for their contribution to replacing fossil fuel. This was sad as there is a strong body of opinion in favour, only it does not campaign so is not heard.


There are hundreds of people in Wales who are in favour of or not against onshore wind farms, possibly a majority.

They would like to respect the opponents of wind farms but have great difficulty seeing the problem.


In response to Page two bullet points


The role of the different consenting agencies


Experience on the ground is commonly that planning is a blunt tool to consent energy applications, causing a lot of cost, delay, pain and uncertainty. It is prone to pressure from anti-groups, which is understandable as planning is determined by an elected body without relevant training.

The Environment Agency is generally considered an appropriate tool as it is not there to stop the proposed activity but to shape it so that it does no or minimal environmental harm.

The approach of the two agencies is fundamentally different, one being modelled on the court system (yes / no guilty / innocent), the other on operating within standards, like building regulations.

In the case of hydro the EA has been criticised in some cases for its red tape and lack of permissive approach. This can be addressed for example by requiring compensatory measures for any negative impacts. The surge in interest in small scale hydro took the EA by surprise which resulted in hold ups and a precautionary rather than permissive approach.

CCW used to be associated with an undue focus on short term local rare species impacts. This leads to anomalies like stopping a cycle path because it means damaging dormice habitat. The benefits of cycling over driving to mice is not considered, nor are climate impacts.


A general problem is that the environmental lobby is associated with those protecting the view to the exclusion of all other considerations. There is also the danger that as small and innovative proposals can be blocked, whereas established ones cannot, all the anti campaigning is focussed on relatively harmless or positive proposals like renewables while fossil fuel and nuclear are beyond campaigners reach.

Those in favour or with no views do not campaign and are not heard. The issue of climate which is clearly the most important lacks campaigners because it lacks immediate local significance.


Potential and likelihood of different energy forms to deliver.

Potentially we can live within our genuine renewables. We know this because many people do already, without loss of functionality, but with behaviour changes.

We also know we will probably have to at some point.

However most people do not know how this is possible or practical. It would really help to show the many examples of people in Wales living in standard homes, partly or wholly off grid just on small scale renewables. See appendix for sample mix of renewables used in these cases.


Again, looking ahead we would be wise to ensure we can repair and replace energy equipment in Wales as the international market may become unaffordable or broken. This requires matching renewables equipment with our industrial capacity and raw materials availability.


The energy ascent path has meant rapid change. Energy descent could be even more rapid due to the bursting of debt bubbles. We will need to envisage a different energy use landscape, possibly heavily relocalised, with a demographic that sees people reconnected to the resources that sustain them.


The questions for energy descent and transfer to renewables are not whether but how, also how fast, and the answers to this are technical, financial and largely motivational.


Motivation is connected to

Seeing the goal and its value

Having a means to proceed towards it

Having some choices and some short term benefit from doing so

Seeing others who have gone ahead, to get reassurance.


UK govt. is using electricity market reform to incentivise the market. We can complement this with motivational measures.


Tell people where we need to get to: ie Energy self reliance using sources of power and equipment that we can keep using for many generations.

Give them choices of how this is going to be achieved (choices may be relevant to regions, to individual homes or to Wales)

Provide all the information necessary to make the choices


Implement change in stages, so adjustments can be made, use pilots, accept mistakes.

Show-case studies and exemplars using the media (TV)


No technology should be demonised or rejected. There is no reason why people should not choose! If they want to pay more (or use less) and choose renewables that don’t show or don’t frighten them, fine.


There can be no choice over the exit from energy sources that cause climate change and those that use up future generations’ share of the earth’s resources. Our children cannot be sacrificed any longer to present convenience. The exit can be achieved through a tariff for the use of non-renewables which is large enough to pay for their replacement by the chosen renewables. Presumably some of this will be achieved through the EMR




Potential of the different types: offshore wind, tidal, onshore wind, hydro-power, nuclear, bio-energy/waste, micro-generation, community energy projects, also solar pv and thermal.

the table below is a stab at a comparison chart, don’t expect perfect accuracy.



How renewable and eroi= energy return on energy invested

How affordable

How productive, how intermittant

Social costs and benefits

How durable, how repairable

offshore wind



Very productive and intermittent

Maybe view benefits

Difficult, high maintenance?

onshore wind

bad to very good depending size and site, bigger the better


Productive and very intermittent

According to some view costs, bigger the worse

Not easy to repair large, small easier but more maintenance


Huge potentially

In the future good to very

Very high installation and development costs

Extremely productive, moderately (predictably) intermittent

Possibly benefits to fish stocks

Very challenging to access to repair, high maintenance, affordable materials



Initial high site works, otherwise very affordable

Superb with short off time eg droughts

Locally repairable, may mean people move nearer hydro

Extremely durable and repairable


Good eroei but not long term renewable unless different feedstock developed

Dubious if clean up included, otherwise very good?

Very good, not easy to turn off but no intermittancy

social costs according to some due health effects waste and leaks high future costs potentially

Known and good for the energy output


Depending on source very good

Depending on scale, very good

Very good, can be timed to provide reserve, not instantly accessible like gas spinning reserve

Risk of massive social cost if using imports which displace food but great social benefits if from well managed woods. Excellent for animal +human manures.

Energy from other waste at risk from waste reduction.

Excellent for moderate scale and technology, more challenging for giant processors.


Depending on type good to poor

Good due connection to many small pots money but variable value for money

Variable according source

Often huge benefits, in behaviour change, empowering

Mostly good

community energy projects



Variable according to source

Potentially great, but not always easy to achieve the potential





Moderate without grants

Quite good, predictable

Quite good

Maintenance Excellent, durability good

Solar thermal



Fair and limited use (washing only)

Good to very good,behaviour ch. effects





potential role of other forms of energy production


As said, we need to exit all fossil fuel uses, and not start any more. There is no excuse at all for using up the remaining resources that should be left for our children – we have had our share!

GSP and air-source hp not mentioned in this consultation, I’m not complaining!


transport issues relating to wind

The transport implications of installation are a momentary issue and don’t seem to warrant much consideration. This is a minor part of the feasibility of the installation, soon forgotten.

Transport for feedstock such as biomass will have road impacts. To reduce these locate for sea or river transport, or have smaller installations. Haulage of biomass suits winter, complementing summer agricultural activity, avoiding tourist season. Ensure storage for wood to dry beside site of biomass generation.