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Detailed comments to TAN8 from the MLAG
| Draft
Ministerial Interim Planning Statement (MIPPS) on
Renewable Energy Draft Technical Advice Note 8 (TAN8): Renewable Energy A response by the Mynydd Llansadwrn Action Group (MLAG comments shown as bullet points under each quotation from MIPPS and TAN8) MIPPS:
12.8.1 ‘Unless such [greenhouse] emissions,
particularly carbon dioxide, are brought under control,
there will be severe and unpredictable global
impacts…’ ·
Carbon dioxide accounts for only 5% of greenhouse gases.
Most of these carbon emissions come from aircraft,
vehicle exhaust, domestic heating and industrial
processes; electricity production accounts for only
one-third of carbon emissions. The contribution of wind
turbines to the overall reduction of carbon dioxide
emissions is so small as to be irrelevant. On the other
hand, the manufacture, transport, and installation of
turbines add to the emissions problem. Wind turbines
require standby backup usually from fossil fuel power,
which again adds to the emission problem. ·
No one knows for certain what the effects of global
warming will be and whether they will be severe.
‘The projections of temperature rise to 2100 are
uncertain because they depend on model simulation and are
subject to the acknowledged limitations of these
models…The levels of these parameters in 2100 are
not only unknown but are unknowable within ranges that
are relevant for policy making’ (The European
Science and Environment Forum 2001). MIPPS:
12.8.2 ‘…review of the programme
[Climate Change] will take place in 2004.’ ·
Has this review taken place? Does this policy statement
incorporate the findings of this review? If not, will
this document be amended in light of the findings? MIPPS:
12.8.3 ‘…renewable energy targets of
4TWh per annum by 2010…’ TAN8:
5 ‘The Welsh Assembly Government has set a
target of 4TWh…’ ·
This represents 10% of the overall UK target of 40TWh.
Wales already contributes 33.2% of the wind turbines in
the UK and about 40% of the overall UK renewable energy
output, so the 2010 target seems to be a significant reduction
in Wales’ contribution to the UK renewable energy
programme. Is this a miscalculation? The MIPPS:
12.8.5 The 800MW wind energy target is based on the
assumption that ‘onshore wind power is the most
viable commercial technology available.’ ·
According to the Royal Academy of Engineering,
wind-generated electricity is one of the most expensive
forms of electricity – more than 5p per kWh –
because of the extra cost of providing backup generation. ·
‘Wind farms get around three times as much in
subsidies – a mixture of ROCs [renewable energy
certificates] and a share of fines paid by non-renewable
plants – as they do from selling electricity’ (Economist
18.03.04). ·
Without ROCs and other incentives, the payback time for a
wind farm would be 14 years. With incentives, the payback
time is 3 years. ·
Wind power is not commercially viable without
government/taxpayer/consumer subsidies in the form of
ROCs and other financial incentives. MIPPS:
12.8.6 ‘It is also of considerable importance
to do everything possible to reduce the overall demand
for energy.’ ·
There is no mention of any measures that would help to
reduce demand and no strategic plan for achieving this
goal. The bulleted points that follow this stated
commitment to demand reduction are concerned only with
the Assembly Government’s commitment to renewable
energy production. Using renewable energy will not have
the same effect as reducing demand. All forms of energy
production have environmental consequences; therefore, in
our view, a reduction in overall energy use and demand
should be the first priority. MIPPS:
12.8.7 ‘…economic and community
regeneration is also a very important part of the
rationale.’ ·
Evidence indicates that wind farms do not generate local
income. The developers and manufacturers of components
parts are usually foreign-owned companies. ·
There may be some local jobs during the construction
phase, but a typical wind farm employs only one
maintenance person. ·
Wind farms do not establish locally-based energy
supplies; the energy is sold to the national grid. ·
Tourism earns £2 billion a year for MIPPS:
12.8.8 ‘…continuously and sustainably
available…’ ·
In defining wind energy in this way, the policy statement
is ignoring the fact that wind turbines do not provide a
continuous supply of electricity. Energy production from
onshore wind turbines is, according to BWEA, 30% of their
rated capacity. According to OFGEM figures for MIPPS:
12.8.10 ‘Wind power…offers the greatest
potential for an increase in the generation of
electricity from renewable energy.’ TAN8:
15 ‘…wind power is the only clear and
realistic deliverable…’ ·
Can the Assembly Government provide documented evidence
to back up these statements? ·
There is no mention in either of these documents of the
need for backup. Wind power is intermittent and therefore
requires 100% standby backup from convention plants,
which generate pollution when not producing electricity. ·
‘In the electricity supply industry, security
considerations involve both security of energy supply and
security of power supply. For this reason an important
principle that has to be understood is that intermittent
renewable energy generators can supply energy, but they cannot
replace capacity! The installed capacity of such
intermittent plant has to be compensated by back-up
capacity of conventional plant to ensure security of power
supply, in the case of wind power as if it did not
exist’ (‘Energy Policy and Security of
Electricity Supply’ by Professor Michael
Laughton, FREng). So, while wind-generated electricity
may contribute to a renewable-energy-generation target,
it will never provide security of power supply or
contribute to a reduction in carbon dioxide emissions. MIPPS:
12.8.10 ‘Wind power is probably the most
controversial…However, the need…is established
in the short-term through environmental imperative and
international treaty…’ ·
Why is the Government pursuing a policy that is so
controversial and yet, in their view, only a short-term
solution? Wind farm infrastructure – access roads,
cables trenches, pylons, substations, borrow pits,
concrete foundations – are certainly not short term;
they will have long-term consequences for the environment
and landscape of Wales. ·
The aim of the MIPPS:
12.8.10 ‘Development of a few large scale
(25MW+) wind farms…. TAN8:
16 ‘The Assembly Government has therefore
decided that in order to meet its 4TWh target, 800MW of
additional capacity will be required to be provided by
large-scale on-shore wind by 2010.’ ·
These are supposedly consultation papers, yet the
Assembly Government has set its course of action before
the public has had a chance to respond to these
documents. ·
The stated target is an additional 800MW provided by
onshore wind farms. This would mean building not a
‘few’ but 32 wind farms of 25MW capacity by
2010 – approximately six wind farms each year for
the next five years. ·
MIPPS:
12.8.11 ‘…and other considerations… TAN8:
32 ‘…there are only a few unconstrained
areas in ·
In footnote iii of the MIPPS, other considerations that
would restrict development included major urban areas,
farms and settlements, and registered common land. TAN8
(sections 21, 26) also refers to these categories as
constraints on development. However, on the Strategic
Search Areas maps, many areas, especially E and F,
include these categories. ·
The original maps provided with these documents were of
such poor quality that it was impossible to identify
exactly the areas targeted for wind-energy development. ·
There has been no consultation with the people living in
the strategic search areas. ·
There are many proposals and planning applications
currently under consideration that are not mentioned in
the reports or shown on the maps, most notably the
Camddwr proposal for 212 turbines in the TAN8:
33 Forestry Commission woodland has ‘some
positive siting factors’. ·
Siting wind farms on forested land requires clear cutting
vast areas to build access roads, substations and grid
connections and to provide a clear footprint around each
turbine. Clear cutting not only produces carbon dioxide
because of ground disturbance and decomposition of the
vegetation left behind, it also removes an important
carbon sink. According to the Environment Agency, one
acre of coniferous trees absorbs 3.5 tonnes of carbon
dioxide from the atmosphere each year. MIPPS:
12.8.11‘…smaller, domestic or
community-based wind turbine developments…’ TAN8:
19 ‘…smaller scale domestic or
community-based turbines may be suitable…’ TAN8:
36 ‘…smaller, domestic or
community-based wind turbine developments…’ TAN8:
38 ‘…relatively small, possibly
community-based, proposals…’ ·
There are no guidelines as to the meaning of these
descriptions. Do the terms ‘smaller’,
‘small-scale’, and ‘relatively small’
refer to the size of an individual turbine or turbine
development or do they refer to the electricity output?
It is important to clarify this point because a wind
turbine or a wind-turbine development may be small in
terms of electricity output but, as structures in the
landscape, may be very large and intrusive, with
large-scale impacts on the local environment. ·
What is the definition of community-based? If electricity
is fed into the national grid, how can the turbine be
‘community-based’? MIPPS:
12.10.1 ‘Where a development is likely to
cause demonstrable harm to a designated
area…consideration should be given to refusing the
development…’ ·
What is the definition of ‘demonstrable harm’?
What degree of environmental harm would be acceptable
according to this definition? How can harm be
demonstrated before development goes ahead? ·
There is no mention of harmful effects on people’s
health and quality of life as a consideration for
refusal. TAN8:
42 ‘Residential property in the strategic
areas…would not thus provide a decisively limiting
factor.’ ·
Again, this consultation paper is disregarding the
quality-of-life and health issues for residents who will
be affected by these projects. ·
Low-frequency noise travels further than audible noise;
it is ground borne and felt through vibrations, which can
resonate with the human body resulting in a range of
symptoms. The effects of low-frequency vibrations can be
felt up to several miles from the source. In assessing
the suitability of a site, wind developers measure the
audible range of noise, but never the infrasound –
the low-frequency noise. ·
Research is currently underway into the health
implications of the low-frequency noise associated with
wind turbines, and there is a great deal of anecdotal and
medical evidence as to the detrimental effects of wind
turbines on people’s health. According to a report
by Dr Geoff Leventhall, a fellow of the MIPPS:
12.10.1 ‘…requirements for the removal
of turbines and all associated infrastructure and
remediation of the site as soon as their use
ceases.’ TAN8:
41 ‘Local planning authorities will need to
include appropriate conditions for the
decommissioning…and the restoration of their
foundations…’ ·
How would a planning authority be able to enforce any
‘requirements’ or ‘conditions’? Would
it have the power to force a wind power development
company to come back after the 25-year life span of each
turbine and remove it and its 1,000-tonne concrete
foundation from the Welsh hillsides? Wind power
developers are international companies with many
subsidiaries, who will undoubtedly no longer exist in the
same guise as they did when they signed the original
contract and, therefore, may not be around 25 years later
to fulfil the terms of their contracts. ·
Developers are required to pay a bond of £3,000 per
turbine for a 25-year period to cover decommissioning
costs if they change identity or go bankrupt, but this
amount is too small to be of any practical benefit. ·
In many instances the impacts of the construction phase
of wind farm developments will have lasting consequences
that can never be rectified. Blasting or drilling into
the bedrock to build foundations has been shown to
disrupt natural water courses. At Cefn Croes, for
example, where layers of peat are being ripped up and
aggregate is being quarried from ‘borrow pits’,
the environmental damage is such that restoration of the
site to its original condition will be impossible. TAN8:
17 ‘Proposals for reinforcement and new
network development…should be encouraged where
environmental implications are minimised.’ ·
There is no indication as to the nature of these
reinforcements and developments. Are they to be overhead
lines or underground cables? Are there plans in place for
this reinforcement and network development? ·
The grid infrastructure will be in place even after the
turbines are de-commissioned and will, therefore,
influence future energy-development patterns. ·
There is no mention of the problems of instability in the
grid caused by the unpredictable surges of wind-generated
electricity. ‘Accommodating any intermittent
electricity source into the grid distribution system
presents considerable problems. Denmark…has just
removed subsidies on three proposed 150MW offshore wind
farms, effectively cancelling them, as any more wind
power will cause serious destabilisation of their
grid’ (‘A Cloudy Energy Future’ by
Professor Ian Fells CBE FREng FRSE, 2003). ·
What is meant by ‘where environmental
implications are minimised’? It is difficult to
envisage how the landscape and environmental impacts of
high voltage connections in remote areas can be
minimised. ·
A recent government study has concluded that high-voltage
power lines have been responsible for some cases of
childhood leukaemia. TAN8:
21 ‘…turbines should be sited 500m or
more from noise-sensitive properties.’ ·
Recent research has shown that sound from wind farms can
be heard clearly up to one kilometre away (G. P. van den
Berg, TAN8:
35 ‘…whilst cumulative impact can be a
material consideration, it must be balanced against the
need to meet the national target…’ ·
TAN8:
43 ‘…active involvement of the local
community…’ ·
Experience shows that wind farm proposals split
communities. Some landowners may benefit financially, but
most local residents are opposed to the developments.
Throughout ·
Wind farms do not help the local economy. The developers
and manufactures of components parts are usually
foreign-owned companies. ·
There may be some local jobs during the construction
phase, but a typical wind farm employs only one
maintenance person. ·
Wind farms do not establish locally-based energy
supplies; the energy is sold to the national grid. ·
Wind-power profit comes from direct and indirect
government subsidies. Rather than setting up trust funds
from these so-called profits, in our view, it makes more
sense to use the subsidies to invest directly into the
community to set up ‘energy conservation and
small-scale projects in the locality’. TAN8:
72 ‘If however the electricity used to power
the heat pump is generated from fossil fuels…the use
of heat pumps will be likely to generate little, if any,
carbon saving.’ ·
This argument should also be applied to wind turbines.
They need standby backup, which is usually generated by
fossil fuels, and therefore wind turbines also ‘generate
little, if any, carbon saving.’ TAN8:
95 Environmental Impact Assessments ·
The standard practice is for wind farm developers to
commission the required EIA. Can the Assembly Government
assure us that in future all EIAs will be carried out by
impartial agencies? |
Click here to return to the TAN8 text
Home |
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