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Dear Mr Adcock,

Re: Consultation on

Draft Ministerial Interim Planning Policy Statement on Renewable Energy

Draft Technical Advice Note 8: Renewable Energy

I am writing on behalf of the Mynydd Llansadwrn Action Group. The group – membership approximately 200 – was formed in 2003 in response to a proposal in this area for a wind turbine development. Our first reaction was to oppose a potential threat to the local landscape and our quality of life. As we became more informed on the subject of wind energy and other forms of renewable energy, we came to the conclusion that large-scale wind power installations can never provide a reliable source of electricity or contribute to a reduction in carbon dioxide emissions. In our view, the damage to the environment during construction and the subsequent harmful effects on wildlife, the problems of low-frequency noise and light flicker, far outweigh any benefits that are offered as justification for this type of industrial development in the Welsh countryside.

We support the Assembly Government’s policy of developing renewable energy; however, we do not agree that large-scale wind farms are the best way forward and we question the underlying assumptions and the conclusions of the MIPPS and TAN 8 documents.

Our detailed response to these consultation documents is attached, but in summary our objections are as follows:

There are no justifications and no documented evidence for the reports’ assertions that wind power is the best available form of renewable energy. We would like to see the evidence that supports these assumptions and conclusions; we also want to know who wrote these reports and if the Assembly Government is satisfied with the impartiality of these documents.

TAN 8 figures for electricity output from onshore wind turbines are based on a load factor of 30%. This is incorrect. According to OFGEM figures for Wales for 2003, the load factor is 23%

Nowhere in the MIPPS or TAN 8 is there any mention of the need for backup electricity supplies. Because wind energy is intermittent and unreliable, it requires 100% backup from other sources, usually fossil fuel. Therefore, wind farms can never provide security of power supply or any significant reduction in carbon dioxide emissions.

Although the MIPPS and TAN 8 make general statements about improved energy efficiency, there are no concrete or innovative policies for achieving this. This seems a lost opportunity. Reducing energy demand is a more practical and environmentally sensitive solution to the problem of global warming than embarking on a massive building programme that itself will contribute to carbon dioxide emissions.

In describing onshore wind power as ‘the most viable commercial technology available’, these reports are ignoring the financial incentives and subsidies that wind power developers receive and that are paid for by the taxpayers and electricity consumers. There is evidence from other countries, especially Denmark, that when subsidies are withdrawn, wind power is not longer a viable option.

There is no attempt to compare the cost and/or effectiveness of wind power with that of other renewable energy technologies.

Although the public is invited to respond to these consultation documents, there has been no publicity campaign. The documents have not been readily available and the accompanying maps are of such poor quality that it is difficult to see which areas are being targeted for development. The maps do not show any of the current wind farm proposals and planning applications, most notably the Camddwr proposal for 212 turbines on Forestry Commission land.

In our view, these are serious faults and omissions, making an informed public response impossible. As consultation documents, the MIPPS and TAN 8 fail in their purpose. We, therefore, request that the Assembly Government re-write these reports taking into account the issues raised in this letter and in our attached detailed response.

Yours sincerely, Joanne Jessop

on behalf of the Mynydd Llansadwrn Action Group

Cc: All Welsh Assembly Members; MPs and MEPs for Wales; Carmarthenshire County Councillors; Michael Howard MP; Charles Kennedy MP; Bishop of Liverpool, Right Reverend John James;
HRH Charles Prince of Wales; The National Trust; Open Space Society; RSPB; Ramblers Association Wales; County Landowners Association; Bat Conservation Trust; Cambria Archaeology, Countryside Council for Wales; Forestry Commission.

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