Nant y Moch consultation #2 responses

The Cambrian Mountains Society’s own response is shown below.

Other responses:

Nigel Brown
Brian Davis
Digital Landscape Company (illustrated report)

Comments on behalf of the Cambrian Mountains Society on the Further Consultation on the draft ES and Non Technical Summary for the Nant y Moch proposal

(Drafted by Environment Information Services)

The Further Consultation Exercise

The exercise is publicised in Issue 5: June 2011 of the SSE Newsletter. At the foot of page 1 is a green Panel headed ‘Supporting Nant y Moch wind farm’. This ends by specifically canvassing [only] a support response to the consultation. This is highly inappropriate and fails to elicit responses in a neutral manner.

The Non Technical Summary
[comments that apply equally to the main ES are not repeated there]

As observed by CCW in its Annex 2, the NTS is of critical importance in describing the proposal and its environmental impacts to the general public. Para 7 of the Preface states that a full copy of the ES is on display at the offices of the two County Councils. Yet the Deposit Information in the present consultation is said also to be available in five further locations. I would suggest that the final ES should similarly be available, and perhaps at more local venues in addition. The limited downloads mentioned are doubtless constrained by the sheer electronic size of visual material: it is normal in such circumstances to see provision for a CD Rom at modest price.

The bright clean style adopted for the front cover of the NTS conveys an impression of clarity and neutrality. Unfortunately, it contains an element of promotional text, even reading at times as a brochure for the development as in para 84 and as noted by CCW in its reference at Annex 2, 2.6 to NTS 80.

Figure 1 (Site Location) should have an emphasised boundary of the two County authorities and the Snowdonia National Park.

Figure 2 (Final Site Layout with Tan [sic] 8 Boundaries) shows in a rather complex fashion the SSA D boundary under TAN8 (it is better to use capitals) but this is not mentioned until NTS para 20. It also shows the ARUP Refined Boundary, but confusingly for readers there is no other reference to the Arup exercise in the NTS. This could be resolved by simplifying Figure 2 and inserting a further map relating to the two sets of boundaries and explanatory text at Section 3 which currently fails to explain the role of the Arup exercise and boundary.

Assessment Methodology and Significance Criteria

Para 40 fails to distinguish between the meaning and relevance of the term ‘significance’ for EIA Regulations purposes (where the threshold determines screening) and that for planning purposes at determination stage (where effects should be considered in terms of their spectrum).

Project description

There is no information to set the size of the proposed 146.5m turbines [or as CCW notes at 4.29, potentially 151.5m] in the context of those currently visible in the landscape. For example, the Cefn Croes turbines are under 100m and those nearby at Mynydd Gorddu and Ystumtuen are 55.5m and 46.5m overall height, respectively.

Planning Policy Context

There is no reference to the role and status of the Arup material in TAN8 either nationally or locally, for example at para 70.

Landscape and Visual

74: The complexity of wind power development is acknowledged, but the claim that there are few locations where the proposed turbines would be seen in isolation is misleading. This is only true in a technical sense, as most views of the proposed project will be dominated by it, with other turbines peripheral or dwarfed in size or extent. The focus on cumulative effects leads to a structure of the ES which is focussed primarily on complexity and interplay and takes the onus of assessment away from the proposal itself. In particular it leads to excessive complication in terms of the visual material in the main ES, making it difficult for readers and viewers to gain a clear impression of the proposal’s own effects.

75. The ZTV or ‘viewshed’ is skewed by the visual containment of Pumlumon [nowadays the accepted spelling in English language documents] but in view of extensive visibility elsewhere the claim – repeated at paras 84 & 85 – that the influence is ‘limited in comparison with other similar development in the UK’ is refuted by its northward and southward visibility shown in Figure 7.

76. I welcome the acceptance that effects at viewpoints are considered in terms of both visual amenity and character. I share the reservations about coverage and positioning expressed by CCW in Annex 4 para 4.39. Further more detailed comments will be made when the final selection of viewpoints is published in the ES for the accepted application.

87. The example photomontages shown from the summit of Pumlumon in View Point 7 are strangely without explanatory text and should also indicate the Mynydd Gorddu turbines seen in the central distance on Figure 8 (i).

Land Use, Amenity and Rights of Way

159. Amid references to linear Rights of Way and various promoted routes there is no mention of Open Access Land or the availability of FCW land to the public.


173. This section is essentially promotional and contains no reference to the baseline of enterprises currently dependent on the recreational, scenic and ecological interest of the area, or any specific .assessment of possible negative impacts upon them.

174. While there is reference to the Core Area of the Dyfi Biosphere the text does not acknowledge that much of the proposal site lies in its Transition Zone. There is no reference to the Pumlumon Geo Parc or to the fact that the area is part of the once designated Cambrian Mountains National Park.

The Environmental Statement –

Layout and structure

Contents listings, and in particular Appendices, would benefit from a page index.

Chapter 6 Landscape and Visual Assessment

In addition to issues which are mentioned in comments on the NTS, the following aspects should be reviewed.

The placement and emphasis of text on cumulative effects as intervening sections throughout the Chapter makes it difficult to appreciate the specific impacts of the proposal. It even appears to deflect attention away from the most acute impacts by flooding the document with exhaustive and far-flung analysis. A primary text, followed by a separate similarly structured cumulative text would remedy this. The problem is particularly acute when the viewpoint photographs and montages are considered (see below).

Throughout the text, paragraph numbering is cumbersome and makes it difficult to locate text on various topics. Other wind farms in the area

Understandably this will require updating. The Mynydd y Gwynt proposal recorded at as at Scoping has now been submitted to the IPC. This is the closest proposal to the site. It is understood that the Dyfnant Forest proposal is also in course of preparation for an IPC application.

6.4.3 Landscape Character

There is a danger of information overload driving attention away from significant effects when listing attributes of a large number of sometimes distant Landscape Character Areas. Visibility from Key Roads / Cumulative variant Visibility from Leisure & Recreational Routes / Cumulative

In addition to the texts, graphic sequential analysis would be beneficial. Visibility from Settlements / Cumulative

Inadequate selection of local settlements and rather superficial text.

6.5.4 Viewpoint Analysis

The comments by CCW in Annex 4 para 4.39 concerning viewpoint re-arrangement and additions are supported.

It is also of concern that there are no viewpoints in the northern sector of the relatively close-by area from Bwlch y Garreg at the head of Cwm Ceulan to the Anglers’ Retreat, Hafodwnog, Banc Llechwedd Mawr, Drosgol and above Llyn Craig y Pistyll. This is the area where primary, as opposed to cumulative, impacts are of the greatest concern.

This is a key part of the ES, yet the analytical text is set out in a continuous and ill-demarcated stream without a clear beginning or end. There is no clear summary tabulation of the effects at viewpoints within the text, yet Table 6-30A tabulating Cumulative Effect on Landscape Character Areas takes up pages 127 – 162.

Landscape Figures

Detailed systematic comments will be made on the finally submitted ES.

However, VP1 (which itself is unimportant) provides an immediate and acute example of bad practice in photo-composition. The cumulative view at figure 6.21a (page 96) is filled with distracting and cluttering obstacles to view that are untypical, needless and unacceptable. Oncoming traffic; a car across the view in a roadside entrance; a foreground sign; two close electricity poles and a stay: all these jump into the frame while the wireframe reveals that the skyline single CAT turbine for which the position has been selected as a cumulative view is obscured by an end-on small house and a row of conifers.

The procedure of circling the compass points with potentially cumulative views also makes the depiction of primary views of the proposal into a search in itself. Most readers of the ES will turn first to the NTS and then the viewpoints. They are likely to find this a confusing rather than an enlightening experience.


Response of Nigel Brown

I am against the proposed Nant y Moch wind farm in general terms, because:-

a) Pumlumon occupies a unique position in the Mid Wales landscape, because it is the only true mountain in the vast area between Snowdonia in the north and the Brecon Beacons in the south.

b) because of that uniqueness it contributes enormously to the area in terms of environment, recreation and the economy

c) the Nant y Moch side of the mountain is particularly important in sustaining the value of the Pumlumon area

d) as well as long term damage to the Pumlumon area resulting from the proposals, in the short term, over an extended period, there will be a high and wide level of disruption to the Aberytwyth area, seriously affecting both residents and the local economy.

As regards the latest proposals, I have the following particular objections:-

1) the siting of wind turbines (no’s T59-T64) on Bryn Gwyn is particularily insensitive, dominating the reservoir and the dam area to the detriment of the many and varied visitors who visit it, and intruding on the upper Rheidol valley above Ponterwyd as well. Wind turbines T32-T34 (north Nant y Moch) and T46-T49 (Cwm Ceulan) are also highly undesirable.

2) the northern end of the Nant yr Arian access route has taken the cheap option of terminating on the shores of the reservoir, meaning the road along the side will carry considerable traffic, whereas a route heading further north on the line of the existing track to Esgair Ffosfudr would keep the traffic away from the reservoir, and those who enjoy relaxing on its banks.

3) the proposal to use the existing mountain road from Ponterwyd to the dam will be severely disruptive to all who wish to continue to access the Pumlumon and Nant y Moch areas while construction is in progress. All construction traffic should be prohibited from using this road, and constrained to use the access from Nant yr Arian instead.

4) the proposals mention the need to close unspecified rights of way while construction is in progress. The closures envisaged should be detailed in the proposals, together with the duration required. Many of the rights of way in the area are used by walkers, mountain bikers and others, whose rights should recognised and disruption to which needs to be fully justified and kept to the minimum.

5) the proposed revised development boundary still includes large areas in which no turbines seem to be planned, but no reason for the inclusion of these areas has been given. This includes the north of the development area, and the east of the area around Banc Llechwedd Mawr.

Reply, from SSE’s Project Officer

Many thanks for this, your comments have been noted. You can feed in your opinion in a number of ways. Either directly through us as the developer, by letter or email or alternatively you can feed in your comments to the Infrastructure Planning Commission (IPC) details on how to do this is available on their website.

From the outset and as important context I should point out to you that SSE Renewables is proposing to develop this site because it is a prescribed wind farm zone (SSA D) under Welsh Assembly policy (TAN8), which itself is a crucial component in Wales’ efforts to combat the effects of climate change and ensure the security of the UK’s energy supplies. If SSE Renewables was not proposing to develop the site then another developer would be and as such it is inevitable that there will be wind farm development at Nant y Moch in one form or another. SSE Renewables has taken on the development of the site because it believes it can build the wind farm sustainably, with minimum impact and with maximum benefits to the affected communities around the scheme.

To come back on the points you make:

The final turbine layout has been achieved after considerable work including detailed landscape and visual assessments and other survey work which is detailed in the Environmental Statement (the current draft available on CD on request)

Likewise, considerable work has been undertaken on the proposed transport and access to the site if the wind farm gains consent. The current proposal is in SSE’s opinion the best option, which has been achieved after a considerable amount of work, which has considered the traffic impacts on all 3 proposed routes, the best way of bringing in abnormal loads carrying the large turbine components and the importance of Nant yr Arian as a visitor centre within the area.

We are currently assessing the potential impact to the rights of way network within the wind farm site boundary and developing a plan for mitigation, both during the potential construction period and in the longer term, after the wind farm is in place. Every attempt will be made to keep impacts to a minimum, however, for public safety some closures are envisaged during the construction period. Further details on this along with the mitigation and possible enhancement measures being proposed by SSE will be available in due course.


Final comments by Nigel Brown

Thank you for your reply. With respect to the points you make:-

(a) My understanding of TAN 8 is that it prescribes areas in which wind farm development MAY take place, without making assumptions about what form that development will take, or indeed if any development at all will be found to be acceptable. While I understand that it was inevitable that proposals would emerge, and I understand SSE Renewables aiming to be the developer, I don’t regard such development as inevitable.

(b) Re the landscape/visual assessments which have taken place, these seem to be concerned mainly with impact on communities and the principal transport arteries, and not the impact within the Nant y Moch area itself. Thus no consideration has been given to the fact that the turbines sited on Bryn Gwyn (T59-T64) will dominate the dam area (the centrepiece of the area) and both arms of the reservoir, in a way the other turbines do not, and will also impact severely on the upper Rheidol valley. Also, the impact of the whole development on the outstanding scenic views experienced by those who walk up Pumlumon, particularily from west, have been largely ignored.

(c) As someone who uses the Nant y Moch mountain road from Ponterwyd somewhere in the region of 2 – 3 times a week, averaged over the year, I would dispute the assumption that this road is “little used”. I almost always encounter other traffic, such that I keep to around 20 mph because of the chance of meeting something. The low level increase in traffic currently being experienced due to timber traffic creates problems. The proposed increase in traffic would make driving this road a misery, or even dangerous, for regulars and for contractors alike, even if improvements are made, which is why I believe construction traffic should, as far as possible, be confined to other routes.


Response of Brian Davis

I have noted your company’s Consultation publicity for its proposed wind power station in the Nant y Moch area and wish to respond as set out below. I will of course wish to consider the proposal in greater detail when you submit your application to the IPC and I am then able to look at your Environmental Statement. However I wish to raise concerns that the cost of a copy of the Draft Environmental Statement is prohibitively expensive and precludes detailed analysis by a lay concerned individual. Cynically one can only conclude that this is deliberate.

I would welcome information and reassurance that there has been a full environmental and ecological impact report on

1. The siting of the individual turbines within the proposed area and the potential carbon damage resulting from the disturbance of an ancient peat rich landscape.

2. The proposed access road and infrastructure to deliver and install the turbines and the potential disturbance to an ancient peat rich landscape.

3. The necessary infrastructure and mechanisms necessary for the distribution and export of the electrical energy generated. The over-ground transportation of the electrical energy generated has the potential to visually destroy a very wide area of landscape, whilst the underground alternative will disturb a vast area of peat rich landscape.

I would also welcome information on the long term impact the project may have on

1.  The scenic route between Ponterwyd and Talybont and its exceptional value as a tourist resource.

2. The effect on the tranquillity and enjoyment of the area both visually and in terms of audible noise pollution.

3. Effect on quiet recreation in the area in particular hill walking, wild camping and fishing.

4. The preservation and maintenance of the area’s historical, cultural and especially archaeological importance for future generations.

Having only recently returned from a visit to the mid Wales area it was a matter of concern that of the many wind farm observed during a period of four days when the average wind speed ranged between Force 2 and 4, that only one of the existing installed farms had turbines which were active and generating.

Reply, from SSE’s Project Officer

Many thanks for your letter, your comments have been noted.  You can feed in your opinion in a number of ways. Either directly through us as the developer, by letter or email or alternatively you can feed in your comments to the Infrastructure Planning Commission (IPC) details on how to do this is available on their website.

From the outset and as important context I should point out to you that SSE Renewables is proposing to develop this site because it is a prescribed wind farm zone (SSA D) under Welsh Assembly policy (TAN8), which itself is a crucial component in Wales’ efforts to combat the effects of climate change and ensure the security of the UK’s energy supplies. If SSE Renewables was not proposing to develop the site then another developer would be and as such it is inevitable that there will be wind farm development at Nant y Moch in one form or another.  SSE Renewables has taken on the development of the site because it believes it can build the wind farm sustainably, with minimum impact and with maximum benefits to the affected communities around the scheme.

To get back to you on the points you made, the Environmental Statement is a huge piece of work which is made up of a number of volumes of over 500 sheets of A3 paper.  Copies of the draft Environmental Statement are available to be inspected free of charge at local libraries and I can also arrange for a cd copy to be sent out to you free of charge if you would like one.  Please send me your postal address should you like to receive a copy.

I would like to reassure you that a considerable amount of time has been spent by SSE and by Dulas, the consultants who have managed the Environmental Impact Assessment work for the Environmental Statement.  The Environmental Statement covers the issues you have raised, such as ecology, archaeology and culture, hydrology and many others in detail.  Shorter versions are available on line on the project website including summary sheets for the topics I mention above and also a Non Technical Summary for the Environmental Statement.

Please get back in touch if there is anything further I can help you with or if you would like a copy of the draft ES on CD.

Click here for an article by Brian Davis about the proposal