Return to Submission Contents

Evidence to the House of Lords Committee's Enquiry by CPRW

1 Introduction

1.1 The Campaign for the Protection of Rural Wales

 CPRW, which in 1998 celebrated its 70th anniversary, is Wales' foremost voluntary charitable organisation specialising in all issues relating to the conservation and enhancement of the countryside, its environment and rural communities. In a single phrase, CPRW's concern is for the living landscape.

1.2 CPRW's renewable energy policy

 CPRW's democratically produced policy on renewable energy accepts the need to reduce dependence on polluting and fossil fuel power generation, coupled with improved conservation measures and restraint in use, always provided that the benefits outweigh or do not unnecessarily involve other adverse environmental impacts.

1.3 CPRW's policy on wind energy installations 

Since 1991 CPRW has refined this position in the light of a concentrated wave of planning applications for wind power stations which it considers individually and cumulatively to have created unacceptable visual and other impacts on the Welsh landscape. CPRW believes that projects have been unduly forced on to the windiest and often most visible and beautiful sites in upland and coastal areas by the competitive bidding element of NFFO subsidy system which provides a guaranteed market for successful tenderers. In 1995 it produced a definitive policy on renewable energy installations (ref 1) with a specific sub-section relating to wind energy. This provides the basis for a presumption against large wind power stations in the open countryside and sets out a series of circumstances in which small installations might be acceptable.

1.4 CPRW's experience in relation to wind energy proposals

 In the process CPRW has gained considerable experience in analysing the impact of proposals for what it considers to be wind power stations (rather than the euphemistic 'windfarms' preferred by developers). It has evaluated many applicants' Environmental Statements, and contributed to the statutory planning process and policy formation at all levels. It retains a permanent consultant on the subject; has played a leading role within the UK voluntary sector on the issue; has developed the concept of forming profesionally represented coalitions to combine the evidence of like-minded objectors at Public Inquiries; and has established a positive working relationship on the subject with the Countryside Council for Wales, the government's statutory adviser.

1.5 Scope of this Evidence

 Because of its experience above, CPRW wishes to concentrate its evidence on wind power.

2 Effects of the government's renewable energy policy for wind power

2.1 The policy background 

In response to the EU target, the UK has adopted its own target for 10% of electricity consumption in 2010 to be met by all forms of renewable energy. A longer-term aim of 20% by 2025 is also in existence. The Department of Trade & Industry has indicated that wind power will continue to be the major component of the 10% target and that by 2010 it might contribute about 6% of electricity consumption, with roughly half of that coming from land-based installations and half from off-shore (despite the fact that no commercial off-shore installations have yet been constructed). We understand that these individual components do not constitute formal targets, although recent indications are that the off-shore proportion might be slightly higher and on a strongly rising curve by 2010. It is even possible that it could then eclipse, if not entirely replace, land-based deployment in the progress to the longer term 2025 objective.

2.2 The response of the wind energy industry 

In its 1996 Policy Statement (ref 2) the British Wind Energy Association had anticipated that wind power would supply 4% of consumption by 2010, and declared that "a long term target of 10% of the UK's electricity demand being met from the wind by 2025 is perfectly feasible". However, in more recent evidence to the House of Commons Trade and Industry Committee (ref 3), 1998, the BWEA has increased its 2010 forecast to 6%, while repeating the former CEGB's view that an intermittent supply "from non-firm sources" could increase to 20% "without changes being necessary to the grid operating system". In 1998 the pressure group Greenpeace and the power generator Border Wind published a manifesto (ref 4) claiming that offshore wind alone could produce 10% of UK electricity by 2010 and 30% or even 40% by 2030, while arguing for a specific off-shore incentive to enable it to become economically competitive. We understand this is now imminent, and will augment the replacement for the NFFO/SRO subsidy system, without which the development of wind power and other renewables would have been impossible.

2.3 The effect on the landscape to date

 Between 1991 and 1998 about 750 wind turbines were built in the UK (Table 1) of which approximately half were in Wales (Table 2), progressively increasing in installed capacity and size from 300kW (41.5m = 136ft) to 600kW (60m = 196ft). Most have been erected in coastal and upland areas, notably Anglesey and mid-Wales (where Montgomeryshire has the two largest wind power stations then built in Europe). In April 1997 CPRW compiled a populist colour brochure entitled Pla'r Twrbinau Gwynt: Ple ar ran y Tirlun [Wind Turbine Blight: A Plea for the Landscape] (ref 5) which concluded that the adverse visual and other impacts arising from wind power station policy were outweighing the benefits of stimulating a renewable source of energy. In May 1997 CPRW united with CPRE and APRS (its sister organisations in England and Scotland), the Ramblers' Association and the Council for National Parks to produce a joint statement Wind Energy and the Landscape (ref 6) calling on the newly elected government to 'green' the NFFO subsidies; to widen the menu of renewable technologies; to strengthen protection for vulnerable landscapes; and to make energy conservation an increased priority.

2.4 The Implications of the 2010 target

2.4.1 Data from the DTI's Energy Technical Support Unit (ETSU) shows that, due to the intermittency of suitable medium-strength winds, the 318MW wind generating capacity functioning during the y/e June 1998 operated at 26.7% of its nominal installed capacity (IC), producing 745,000,000 kWh (745,000 MWh or 0.745 TWh) * (Table 3). This is 0.25% of the estimated 300TWh present annual consumption in the UK and represents an average output of 85MW Allowing for minor additional output from the 8MW installed capacity of more recently constructed turbines, present wind power generation is thus still well below 0.3% of consumption, and therefore an increase in land-based capacity greater than 10-fold would be needed to reach the indicated 3% of 2010 levels. 
* 1 terawatt (TW) = 1,000 gigawatts (GW) = 1,000,000 megawatts (MW) = 1,000,000,000 kilowatts (kW) 1 kWh (kilowatt hour) = 1 'unit' of electricity

 

2.4.2 On present trends this huge increase would come from progressively higher capacity machines of 1.5MW (c95m = 312ft) and more, but due to their increased size and extended threshold of visual intrusion (Appendix 1) their impact would not be correspondingly diminished, and would be considerably intensified at closer range. Moreover, the Countryside Commission (ref 7) has indicated that the recent average annual 2.4% rise in consumption is likely to be maintained. If this was even 2%pa, annual electricity consumption in 2010 would be about 373TWh. The balance still required to reach the 3% 'target' of 11TWh/pa would therefore be 10.25TWh/pa. This would require an actual output capability of 1170MW *. On the equally generous assumption that capacity factors for land-based turbines might reach an overall average of 30% this would in turn require an installed capacity of 3900MW **. This would involve 2600 1.5MW turbines or their equivalents at other capacities. 

* 10,250,000MWh ? 8760 = 1170MW [there being 8,760 hours in a year] 
** 1170MW ? 30% = 3900MW

2.4.3 CPRW has found that such 95m = 312ft turbines could be visually intrusive at a 12km radius and readily discernible at 22km (Appendix 1). Qualitative and cumulative impact would be significantly exacerbated due to both turbine size and numbers deployed and we recommend a radius of visual impact analysis of 30km, compared with 20km for the current typical 55m turbines. We are also concerned that the technical and conceptual basis for assessing visual impact through environmental impact assessment is inadequate, especially in respect of cumulative or incremental impact, as set out in our response to ETSU's on-going research study on the Cumulative Effects of Wind Turbines (ref 8).

2.4.4 In addition, the whole of the putative 3% contribution from off-shore turbines would be required, and is likely to require some 1,800 or more 2MW turbines * (or equivalent combination). Advances in technology may allow deployment in non-sensitive areas and at non-intrusive distances from the coast (more than 10km and preferably 15km) but this still uncertain, as is the nature of the consent and support regime, both of which could make or mar the acceptability of the technology. 

* 373TWh x 3% = 11.19TWh = 11,190,000MWh ? 8760 [hrs/pa] = 1277MW output which @ 35% capacity factor [assuming better off-shore wind regime] = 3648MW IC = 1824 turbines @ 2MW IC

 

2.4.5 The 2010 target is an interim point in a longer term strategy which requires a further doubling of renewable capacity. The role of wind power is uncertain but off-shore deployment is by then likely to predominate. How environmentally acceptable and economically attractive this may be is uncertain, as is the weighting of adverse impacts in the policy decisions which yet have to be made.

Return to top of page

 

3 Implications for Wales

 

3.1 The 3% objective
The 357 turbines already installed produce about 2.4% of Wales' relatively small energy needs, thus effectively almost meeting the general land-based objective already, although it is likely that wind power may be expected to produce a disproportionately large share of the 2010 target in Wales. Whether, by how much, and with what balance between land-based and off-shore is undetermined, and at a recent Countryside Council for Wales Seminar (ref 9) it was accepted by all sides that this was a practical and political question to be addressed by the National Assembly.

 

3.2 Beyond 3%
It has been CPRW's view since 1995 (supported by other NGOs in England and Scotland) that the majority of existing sites have unacceptable visual (and in some cases other) impacts. Further substantial land-based turbine development geared to meeting an appropriate larger share of the 2010 target would jeopardise the integrity of extensive areas of high quality landscapes and their enjoyment by the public - especially in or around nationally designated areas, or in the substantial portions of Wales ostensibly protected by local designations such as Special Landscape Areas, and Heritage Coasts. CPRW has argued to Planning Authorities, at the Cemaes B Public Inquiry (ref 10), and in various submissions notably that to the House of Commons Trade & Industry Committee (ref 11) that this represents a most unfortunate major induced conflict between policies for renewable energy and protection of the countryside (for the reasons set out above) and requires urgent reconciliation at the highest level. In the meantime, the precautionary principle should be applied to ensure that there is a presumption in favour of landscape conservation rather than resource exploitation.

 

3.3 Policy issues
We can understand why the wind power industry, which had relatively little opposition in the early years of turbine development, is now bemoaning its lack of progress and has identified the planning system as the greatest obstacle to achieving its desired proportion of the renewable energy target (ref 3). Local Planning Authorities have responded to the progressive disillusionment of electorates in or near 'windfarm' areas - especially where cumulative impact and ever larger turbines have become issues - and have begun to withold consent for a growing proportion of applications. Similarly, Appeals or Call-ins have been increasingly dismissed at Public Inquiries. We regard the recent dismissal at Public Inquiry of National Wind Power's appeal against refusal of consent for the Barningham High Moor wind power station in County Durham (refs 12 and 13) - as having major implications for the future deployment of wind power policy in Wales and the whole of the UK. The appellants, who manifestly share this view, have appealed to the High Court. The Inspector concluded that the installation - considerably larger than any built in England - would have "caused demonstrable harm to the appearance of the landscape" and that "its contribution to energy needs would be insignificant and unreliable, and the pollution savings would be correspondingly small, and uncertain". While we accept that some local benefits exist, we would also argue that the average intermittent 85MW produced erratically from disparate installations throughout the UK is also insignificant and potentially unreliable in terms of both the national demand and the distributional and regulatory needs of the National Grid. We conclude, therefore, that the operation of land-based wind power policy has produced successive tranches of proposals which individually and collectively run contrary to the government's test that they should be both "economically attractive and environmentally acceptable".

 

3.4 Conclusion
Implementation of the anticipated land-based wind energy proportion of the general renewables target could thus in our view only be achieved at an unacceptable cost to the landscapes of Wales and those facets of the rural economy, such as tourism and some aspects of the housing market, which derive their viability from the unimpaired high quality of the landscape. CPRW would argue that this would not only be a betrayal of the post-war planning and landscape conservation system but would be counter-productive to the wider national interest to pursue these targets in the present manner. We would urge that a decisive policy change is required to address the underlying issue and we would in that sense regard the targets as unrealistic and unsustainable. It is therefore unsurprising to us, that despite the damage done to the landscape in the early years of the NFFO system, further planning consents have been so bitterly fought and so rarely granted in the light of the incremental impact of wind power station development.

Return to top of page