The Cambrian Mountains Society’s own response is shown below.
Proposed Amendments to the Nant y Moch scheme June 2012:
Comments from the Cambrian Mountains Society
(Drafted by Environment Information Services, July 2012)
In June 2012 the applicants SSE Renewables issued two Documents setting out proposed amendments to the Nant y Moch scheme. Responses were required by July 28th prior to the changes being incorporated into the ES – forecast to accompany the application to the National Infrastructure Directorate (NID) within the Planning Inspectorate in autumn of this year. The main document is the PEI or Preliminary Environmental Information, which is accompanied by a separate Summary.
The purpose of these Comments is not to anticipate the final production of the completed application or to formulate an Objection at this stage, but to respond to mistakes and mispresentations in the draft material put out for consultation. The intention is, as far as possible, to ensure that the final ES is free from omissions, errors and imbalance so that the CMS and others may eventually respond with a minimum of critical analysis of its content. While the CMS welcomes this chance to register concerns about the revised material, it is not intended (or expected) that the remaining ES text or its methodology will be rendered free from further critical comment. To repeat, the CMS recognises that this consultation is not a specific forum for objections, but an opportunity for critical and constructive comment.
The text below focuses on the first three of the items of modification and makes no comment on those affecting the topics of ‘Additional borrow pits’ and ‘Common Land replacement’. It also critically reviews the current draft version of the Non-technical Summary of the Environmental Statement, both in the light of the previous edition, and the comments made on that text by the CMS in 2010.
1 Changes to the Access Point (and the subsequent route)
1.1 The Preliminary Environmental Information (PEI)
1.1.1 Abandoning the original Bwlch Nant yr Arian access is to be welcomed because of the avoidance of localised impacts to the Visitor Centre surroundings, and to paths and westward views overlooking the cwm. Unfortunately, the detailed Site Entrance Plan Figure 4, as referred to at 2.3.4, is missing from the PEI (though it is included in the parallel Summary document). This should be rectified.
1.1.2 It is claimed (2.3.1 & 2) that this is now a single access point rather the other two options via the FCW Haul route from near Furnace or the local road from Ponterwyd. My reading of the text is that all traffic, including the full range from abnormal loads right down to light vehicles throughout the life of the scheme will now use this entrance alone and will not make use of other routes. This should be explicitly clarified.
1.1.3 The new route is inadequately shown at too small a scale for easy identification on the accompanying Figure 3, which includes all the various proposed modifications over the whole site, or on Figure 5, where it is still impossible to distinguish the route in relation to the OS base map and local features. The exact route can only be appreciated by transposing the information manually onto a 1:25,000 scale OS map. These Figures should be supplemented by a more detailed local plan for the new section of the access route from the junction with the A44 to the point at which it joins the rest of the previous route.
1.1.4 The descriptive text for the proposed new route is inaccurate and muddled, and needs to be completely re-written. As explained in detail below, the text from line 4 at PEI 2.3.5 bears no relation to the brown route shown in Figure 3, or to the various sections in Figure 5.
1.1.5 Figure 3 shows the new route as a ‘Track Layout’ shown by a brown single line starting from the A44 and curving within the red ‘Order Limits’ boundary, and snaking back right-handed, after which it proceeds north to join the previous and unchanged blue route. There is also a short dead-end branch running westwards. Figure 5 provides more detail, by colour-coding explained in the Legend, showing the first curve in red as an upgrade to an existing track, the westward dead-end in orange as a ‘minor upgrade’ extension, and the ‘snake-back’ in brown as a ‘New Track’. The remainder of the new route continues in red northwards as an upgrade to good existing track.
1.1.6 Figures 3 & 5 use a reduced and pale monochrome version of the OS 1:25,000 map as the base for the specific information. When the routes are plotted onto the full-size map – which also has contour and forestry information in colour – the line, location and topography of the route can be appreciated more clearly.
1.1.7 The PEI text at 2.3.5 contains errors in the sections underlined below:
[PEI] The general routing of the upgraded proposed site access track will be via the existing Coed Nant yr Arian site entrance and then following two large loops to the foot of Pen y Graig–ddu for a distance of approximately 1.2km. It then follows a course eastwards for approximately 1km before redirecting northwards up the existing forestry track to the public road south east of Llyn Pendam.
Correction – to describe the route as shown on Figures 3 & 5:
From the A44 the new access route follows an existing forestry track in a single curve or loop above the farm of Nantyrarian for 1km climbing across the south side of Esgair Nantyrarian to approximately SN 714 817. From this point a subsidiary branch runs westwards for c800m along the contour on an existing forestry track, ending in a terminus. The route then continues as a New Track through forestry, climbing obliquely NW to the crest of Esgair Nantyrarian and then snaking back right-handed and downhill NE above the deep valley of the Afon Melindwr to join an existing forestry track running northwards to join the public road c1.5km further N.
Comment – the purpose or status of this dead-end route is not explained, if indeed it is intended to be shown. The so-called ‘second loop’ does not exist, and the proposed route does not extend anywhere near to ‘the foot of Pen y Graig-ddu’, which is a prominent crest over 1km NW on the opposite side of the deep valley followed by the Afon Melindwr. The track ends at the public road ( and rejoins the existing route) adjacent to and SE of Llyn Blaen Melindwr – not Llyn Pendam, as stated, which lies almost 1km further W. These errors of description are difficult to fathom, unless they are perhaps the careless text relicts of part of a previously abandoned alternative route.
1.1.8 At PEI 2.37 there is again reference to the ‘the site access road from ‘Llyn Pendam’ which similarly should be Llyn Blaen Melindwr.
1.1.9 No reference is made [as, for example in the case of impacts on private water supplies at 2.3.22] to the presentation of photographs of the proposed route, or of montages to show the likely impacts, especially bearing in mind that the 6m wide route will transect steep and conspicuous slopes. It is to be presumed that this is an oversight.
1.2 The Summary of Changes
1.2.1 In its text on ‘Change to the access point to the wind farm’ the [un-numbered] fourth paragraph repeats the errors described at 2.1.7 above. This should be re-written to correspond to the route shown in Figures 3 & 5 (re-issued with the Summary).
1.2.2 The fifth paragraph makes erroneous reference to Llyn Pendam comparable to that in the PEI described at 2.1.8 above. This should also be corrected.
2 Changes to the Rights of Way and promoted trails
2.1 The Preliminary Environmental Information (PEI)
2.1.1 The deletion of the alternative access from the A487 is to be welcomed.
2.1.2 PEI 2.4.6 states that ‘provision would be provided during operation for alternative routes that avoid proximity to turbines, for users such as horse riders’. This should be specified, and the rationale, in terms of impacts and distances, should be provided in the ES.
2.1.3 References to the ‘Nant yr Arian Visitor Centre ‘ [sic] should be changed to its full title of Bwlch Nant yr Arian Visitor Centre. The additional new ‘family cycle route’ to be created from the Centre is described at PEI 2.4.8 and elsewhere as a balancing contribution to offset other impacts. The new route should be described in detail in the ES, and be made subject to an explicit and binding commitment, with suitable text in the PEI and Summary.
2.1.4 PEI 2.4.13 refers to ‘Open Access Land over most of the site’. This is an important consideration, but Open Access Land was inadequately shown in the Figures or described in the text within the draft ES – this should be remedied.
2.1.5 The green ‘Alternative routes on new PROWS’ in Figures 5 & 6 should be shown in more detail on a new Figure and described (accurately) in a specific text section of the PEI ahead of the ES.
2.2 The Summary of Changes
2.2.1 No further comments
3 Reduction in numbers of turbines
3.1 The Preliminary Environmental Information (PEI)
3.1.1 The two deleted turbines should be shown clearly on a more-detailed map or inset. They are marked in orange and difficult to see on the small-scale map in Figure 3. Notably, there is no reasoning for their removal, unlike that provided for the re-routing of the access route away from the Bwlch Nant yr Arian Centre. This should be remedied.
3.2 The Summary of Changes
3.2.1 No further comments
4 The draft Non-technical Summary (NTS)
4.1 General comments
4.1.1 The draft NTS incorporates the above amendments to the scheme, but also reduces the coverage and informative basis of the original draft NTS – on which CMS commented in 2011. We then quoted CCW’s comments that ‘the NTS is of critical importance in describing the proposal and its environmental impacts to the general public’. This seems to be recognised by the text that it is ‘a stand-alone document’ but unless indicated elsewhere there is now no reference as to where the NTS (and ES) will be displayed, or how copies might be obtained. Last year CMS complained that the NTS text indicated that the ES as a whole could only be inspected at the offices of the two County Councils. Availability should be expanded and made more explicit.
4.1.2 The style is more readable, and some of the complexity of the earlier version has been addressed. This is to some extent welcome, but this 2012 draft is not just a smarter up-date: it has become more non-technical and more summarised. Worse still, in later pages it degenerates at some length into a developer’s brochure, an impression aided by the insertion of three stylised quite large turbines on some kind of arty grey horizon at the foot of every page. They should be expunged. The NTS should be a formal and neutral statutory document with a precise role in the EIA process. Without losing its improved layout, its appearance and tone should be sobered-up to serve rather than exploit the process.
4.2 Illustrative material
4.2.1 The following table summarises the changes since the previous draft, some of which follow suggestions made by CMS and are improvements – others are not, as indicated.
|NTS 2012||Comments (relating where necessary to 2010 NTS)|
|As we suggested, replaces over-complex A3 map. Reduced to A4; simplified as suggested but now over-simplified. Base map is too small scale, and too crude with unhelpful large relict lettering: should instead name Ceredigion and Powys. Enlarged extract from OS 1:250,000 has more informative base data.|
|p6 Illustration of typical wind turbine||It’s a diagram [!] but suitable in-text replacement for original A3 from which dimensions of the actual turbine should be inserted.|
|More suitable replacement for over-complex original Figure 2. New Site Entrance should be better marked by a thicker arrow|
|Deletion of original Figs 4, 5 & 6||Map of Felling and restocking, diagrams of foundations and substation are not necessary and their removal is supported|
|Deletion of Fig 7 showing ZTV and View Point sites||A retrograde step. The original was too small-scale and fussy; this is essential material and not too complex for general readers. Should be larger scale with a lesser radius of c15-20km but retaining ZTV colour bands and View Point locations.|
|p12 SSA key-map||Adequate; should be TAN 8 [not Tan 8] as we originally suggested and as in text, for example on page 4|
|Figure 3 Pumlumon View Point||Simplified to 2 x A3 pages rather than the original over-complex version covering 8 pages. Aberdyfi VP omitted, perhaps justified|
|p15 Photo of ‘typical Wind Farm’||Should be deleted. Much smaller SSE turbines in Scotland with towers 30m smaller and tip only 11m above the proposed hub in regimented plantation not ‘typical’ or representative of Nant y Moch. Unhelpful, even misleading. There are no 145m GB upland turbines yet built (the largest is 135m at Arecleoch in Ayrshire). The attached spreadsheet provides current details. .|
|p17 Photo of noise measuring equipment||Irrelevant to the purpose of the NTS. Should be deleted|
|p18 Photo of Red Kite||Photogenic but irrelevant to the purpose of the NTS.Should be deleted|
|p19 Photo of a pile of logs||Extraordinarily pointless. Should be deleted|
|p20 Photo of Afon Ceulan||Misleading view from SN 711 898 at entrance to Blaen Ceulan sheltering under the hillsides ahead thus showing only tips of 6-10 turbines [ZTV Fig 6-44] – VP24 is still hardly a suitable site character view but lower and 1km west shows 18 turbines = 9 full sweeps + 3 upper blades + 6 tips. There is a need for a representative view of site character including turbines but there is no suitable ES VP. Should be deleted and a substitute found, by inserting a new VP in the ES – such as Drosgol.|
|p21 Mining photos||Irrelevant to the purpose of the NTS. Should be deleted|
|p22 photo of Drosgol cairn||Irrelevant to the purpose of the NTS, because it is looking away from the development area. Should be deleted|
|p23 Photo of Stone Circle||Irrelevant to the purpose of the NTS. Should be deleted|
|p26 Photo of lorry carrying blade||Marginally relevant to the NTS. Should be deleted unless length of blade is given [if Cefn Croes, is 35m max compared to 46.5m]|
|p28 Photo of Footpath sign||Astonishingly irrelevant to the purpose of the NTS.Should be deleted|
|Fig 4 Transport Route||Should incorporate the detailed highway modifications as in Figure 10 of the 2010 NTS|
4.2.2 Two important maps in the ES should be incorporated, and linked to relevant text, thus plugging information gaps in the NTS. ES Figure 6-2 shows the extensive landscape designations and other key factors covering the site and its surroundings and in addition serves as a key map for the viewpoint locations. Radius could be reduced to 15 – 20km for A4 portrait format. A similar treatment should be given to ES Figure 6-3 which sets out the Visual and Sensory Areas in LANDMAP, which for all the non-forested part of the large site are ranked ‘Outstanding’. Omission of these existing important figures would prevent the NTS from fulfilling its summary role.
4.3 The Text
4.3.1 Introduction and Brief Overview
The text should explain that within the Planning Inspectorate the application will be processed by the National Infrastructure Directorate.
4.3.2 Brief Description of the Application Site
The text should say that the site is mostly in Ceredigion, but also partly in Powys. The area described as ‘upland rotational forestry’ is part of the national forest estate administered and managed by Forestry Commission Wales with a wide multi-purpose remit. The term ‘agricultural grazing upland’ is pejorative and superficial, ignoring its role as semi-natural vegetation and open access land. Other text should link to the inclusion of ES Figures 6-2 and 6-3 as indicated above. The geographic description must include reference to the proximity of the site to Pumlumon as the most important and iconic mountain in mid Wales. Reference to Mynydd Gorddu should state the size of the much smaller turbines (55.5m to tip). These omissions together fail to convey the character, attraction and use of the area. They should be remedied.
4.3.3 Proposed Development
The text should explain that 59 turbines are in Ceredigion, and 3 in Powys. It should also state the hub and blade dimensions individually, and indicate that they turbines are larger than any yet built in Wales or the UK in a large upland development. It should be made clear that the potential benefits are based on estimates and that the household consumption figures of 4.7MWh/annum are on a GB basis, while those for Ceredigion are 5.2MWh/annum.
4.3.4 Planning Policy Context
In the National Policy section, para 2 mistakenly refers to the former IPC.
4.3.5 Landscape and Visual
The observation that ‘there would be few locations from where the proposed turbines would be seen in isolation’ [from others] is misleading and only applies to the relatively distant viewpoints. Most of the local and characteristic Nant y Moch landscape between Pumlumon and the edge of the escarpment would contain views only of the proposed turbines, as shown clearly in the cumulative ZTV maps. This zone is unacceptably ill-served with viewpoints, thus contributing to the assertion above. As a result the assessment process has been overwhelmed and distorted by cumulative assessment, effectively displacing the essential assessment of the primary impact of the proposal.
4.3.6 Land Use, Amenity and Rights of Way
The spectacular Scenic Route from Ponterwyd to Tal-y-bont and links to the coast via the various lakes are not mentioned, while the extensive use by walkers, mountain bike riders, horse-riders and recreational motorists is inadequately described.
The seventh paragraph asserts that ‘the proposed wind farm would be unlikely to deter the overwhelming majority of visitors’. This strange and rather cautious phrase still leaves open the possibility of significant adverse effects.
4.3.8 What happens next?
It is accepted that it is not the primary responsibility of the applicants or of the NTS to explain this process, but again there is no reference to the National Infrastructure Directorate within PINS, with little explanation as to how it will examine the application after the ‘preliminary meeting’.
The Cambrian Mountains Society makes these comments without prejudice to its response to the Environmental Statement for the proposal in whatever form it is finally issued for comment by the public.
Response of Dr. H.K. Little, on behalf of the Cefn Croes Action Group
[Page numbers below refer to Draft Non Technical Summary of the Environmental Statement May 2012]
To: Eluned Lewis, Community Liaison Officer, SSE Renewables
July 24th 2012
Please find below my response to the Additional Consultation on the Nant-y-Moch Windfarm proposals. Having attended the public exhibition in Tal-y-Bont Community Hall, and read the Non-Technical Summary, I address the issues raised in the order in which they are referred to in the document:
|p. 4||sect 2||It would be interesting to see “SSE Renewables’ … site development criteria”. Can you please send a copy? TAN8, the Welsh Government’s guidelines for Renewable Energy was formulated during 2004, published in 2005, and is now widely regarded as flawed and out-of-date. In light of new information about wind ‘farms’ and evolving energy policies, many AMs are campaigning for a review of TAN8, and feel that this is overdue. To base your application on TAN8 is unwise.|
|sect 3||“Site is located on an area of upland rotational forestry”. This fails to make clear that this is part of the National Forest Estate i.e. public land, administered and managed by Forestry Commission Wales. Its remit is to “maintain and expand the forestry resources of Wales”, comply with the Forestry and Countryside and Wildlife Acts and manage the forestry estate “on behalf of the nation”. Disposal of forestry land for industrial purposes rather than growing timber is illegal.|
|p. 5||Area of proposed development: the figures given are confusing. It would be helpful to give a conversion factor for hectares » acres. The figures provided perpetuate the illusion that wind ‘farms’ have a small footprint in terms of land-take. It would be more honest to give the total land-area within the boundary.|
|p. 6||Proposed Development: “External transformer housings for each turbine” – this is surely a retrograde development. Even on Cefn Croes the transformers are houses within the turbine tower bases.|
|“Upgrading existing on-site access tracks” sounds like an improvement, but in reality involves extensive widening and thousands of tonnes of road-stone, giving a new road network. This is a major engineering project.|
|“One concrete batching plant” – the reality is a concrete-making factory with large bays containing various grades of sand and aggregates, cement in giant hoppers, concrete-mixer lorries, site office, conveyor belts and facilities to clean the lorries. The Cefn Croes developers were so keen to keep this hidden that they built it behind a barrier of the few remaining conifers!|
|“11 borrow pits” – again a misnomer. Stone from these rock-faces is excavated and crushed, and used for road surfaces, and hard standings. It is not borrowed, because it is not returned. These are quarries, and should receive individual planning permissions under the minerals and aggregates rules.|
|p. 7||“Minor modifications to the existing A road network” – All roadworks and street furniture alterations have potential for noise, inconvenience, and traffic delays on our congested roads.|
|para 3||“A wind turbine of rated capacity 2 – 2.5 MW would be used” – I presume that this would be imported? Therefore having no economic benefit to the UK. There are no details as to manufacturer or design.|
|para 4||Nearly 3 years of construction amounts to huge disruption, not only on-site, but on the surrounding road networks.|
|p. 9||30% capacity factor claimed – but OFGEM’s monitoring of large land-based turbines shows outputs far less than originally claimed. All anemometery data should be publicly available, and not deemed “commercial in confidence”.|
Environmental Impact Assessment
|p.11||“Mitigation – which will avoid, minimise or offset any negative effects” – this is one of the developers most dishonest ‘weasel-words’. Nothing can “mitigate” the impact of 62 man-made vertical machines, with moving parts, >400 feet high, standing on ridges and summits in the heart of the Cambrian Mountains. To pretend that “negative effects” resulting from an industrial development of these proportions in a Special Landscape Area can be “mitigated” is an insult to our intelligence.|
|p. 12||“The Welsh Government set an indicative target of 212 MW installed wind capacity for SSA D in 2011” – It is now 2012 and the planning application has not even been submitted. If the scheme was a good one and publicly acceptable, presumably it should already be up and running?|
|p. 13||“Award of rights to develop Forestry Commission Wales land at Nant-y-Moch” – This was given by the Welsh Government, but as already made clear it is in contravention of the Forestry Act. It is highly significant that a 3 year battle to obtain, under the Freedom of Information Act, the legal advice given to WG Ministers prior to FC Wales land disposal for industrial purposes failed. What were they wanting to hide?|
|para 4||“appropriate site selection and the iterative design process” has not avoided potential effects, nor have the “embedded design features reduced environmental effects” The statements are untrue.|
Planning policy context
|p. 14||para 1||It is totally unrealistic to expect that “64% of the UK electricity supply will come from renewables by 2020” “A further 6,000 wind turbines will need to be installed on-shore by 2020 and 4,000 off-shore”. 10,000 more turbines between 2013 and 2020 – 7 years approximates to 1,430 turbines per annum or 4 daily. IMPOSSIBLE!|
Landscape and visual
|p. 14||para 1||There is recognition here that there is already huge cumulative impact from pre-existing wind turbines in mid Wales with wide zones of visual influence, but surely this in not a rationale for inflicting further landscape degradation?|
|p. 18||“Habitat Management Plans” for large wind developments are rarely worth the paper they are written on, notwithstanding ecological reports from clever consultants. Go and view the continuing peat devastation, habitat damage and dreadful attempts at replanting Cefn Croes. (I offer you a guided tour).|
|p. 19||Forestry – “a keyhole approach” – to felling is another Forestry Commission lie. You cannot hide wind turbines in mature forestry. Extensive clear-felling has already taken place during the last three years to “accommodate” wind turbines.|
Hydrology, hydrogeology and geology
|p. 20||para 2||It is worrying that the developers are so sanguine about “some changes to peat hydrology”. Is there no understanding as to the importance of peat as a carbon-sink and rare habitat?|
|para 3||The potential for downstream flooding from the rivers Leri, Ceulan, and Rheidol has not been referred to. Yet villages and towns around the coast and Tal-y-Bont have recently suffered catastrophic floods. Reducing the absorptive capacity of the wet catchment areas by “concreting over the countryside” and other impervious materials can only increase future risks.|
|p. 24||Peat is sacrosanct. Don’t go anywhere near it. Have no lessons been learned from Cefn Croes?|
|para 7||Anticipated pay-back of 0.8 years is challenged and evidence refuting this will be given in the submission once planning permission is applied for.|
Traffic and Access
|p. 25||It is worrying that despite many requests for a Draft Traffic Management Plan over the last 2 years, none is yet available. The Welsh Government, and officials from Ceredigion County Council and the Trunk Roads Agency all monitored the trial runs for the Abnormal Indivisible Loads (AILs). Where are their reports? It is not reassuring that street furniture at ‘pinch-points’ may be “demountable”. In particular, everyone wants to know what will happen at Llanbadarn Fawr roundabout.|
|p. 31||Why is this not yet settled? It is madness to consider the details of a power generating station without first working out how that power will be transported to where it is needed. The long corridors of pylons and overhead cables to a substation will have their own deleterious environmental impacts.|
|p. 30||para 2||“During the operational life of the Development, it is predicted that 20 full time jobs could be supported in the local area annually”. The weasel-word here is “could”. We were told that Cefn Croes would support 7 permanent local full-time jobs, then it became 4. The reality is NO local workers.|
|p. 30||Where in the UK has a wind ‘farm’ been decommissioned, and what is the experience of that procedure?|
|It is very hard to prove that wind ‘farms’ are damaging to tourism revenue. Much evidence is anecdotal, and public opinion surveys are frequently flawed in their methodology, or commissioned by groups with vested interests. VisitWales reports a reduction in visitor numbers.|
|p. 31||The “community benefit package” is a bribe to the local community to make the developer appear more acceptable. If it was widely acceptable, there would be no need for it. The Development should stand or fall on its own merits.|
I represent the Cefn Croes Action Group, which continues to photograph, monitor and record the wind ‘farm’ on the Cefn Croes plateau, a mere 5 miles away from the new proposals. When the application is finally submitted to the Planning Inspectorate, we wish to register our interest and we shall then present a detailed objection. This is merely an interim response, but questions are posed, and further information is requested.