Slaying the Golden Goose with a Rotor Blade.

How Kyffin Williams might have been forced to
paint Ynys Môn in two or three years time.

The Welsh Government is committed to delivering a three percent annual reduction in CO2 from 2011 onwards. Part of the way it hopes to achieve this is through promoting the development of renewable energy in Wales such that it will deliver 4TWh of electricity per annum from renewable energy to 2010 and 7TWh to 2020. (For comparison purposes, in 2010 UK’s total electricity generation stood at around 26TWh.)

In 2004 the Welsh Government identified that there was an installed renewables capacity of only around 380MW (equating to around 1TWh; for comparison purposes Wylfa A has a capacity of 900MW and Wylfa B will generate 3300MW) in Wales and therefore reviewed the various forms of renewable energy technology which would allow it to reach its 4TWh target:

"Offshore wind is an emerging technology and cannot compete commercially with onshore wind at present without grant support as demonstrated by Round 1 offshore windfarm projects. All substantial hydroelectric power in Wales has already been developed and there remains little scope for further development. Utilising Biomass to produce electricity at competitive prices remains a challenge and Wave and Tidal Technologies are still emerging technologies in the developmental phase and are a considerable distance from commercial applications. Photovoltaics are interesting at the small scale, but not currently commercially viable outside of building systems."

Accordingly it concluded (somewhat prematurely perhaps) that onshore wind was basically the only "commercial renewable energy technology" which would allow Wales to reach its targets. As onshore wind has very obvious land planning implications — they require large amounts of open land on which to site turbines, sub-stations, and pylons to provide a grid connection, in addition to visual impact issues of, in some instances, 140m tall wind turbines — the Welsh Government in 2005 rushed through Technical Advice Note 8 (TAN8) as the main planning instrument to enable the development of onshore wind farms in Wales.

The seven "Strategic Search Areas" defined in TAN8 to be 'sacrificed' to large-scale
wind farm development shown in red above.
The closest to Ynys Môn is Clocaenog Forest on the Conwy and Denbighshire border.

TAN 8 basically defines seven opaquely named "Strategic Search Areas" (SSAs) within rural sections of Wales which, subject to empirical evidence gathering and scrutiny before they were identified, the Welsh Government decided could be 'sacrificed' to the development of large scale (over 25MW) wind farms. Clustering large scale wind farms in geographically defined areas was supposed to minimise the visual and environmental impact and also provide for efficiency in connecting them to the national grid. Also, given that such areas would be changed out of all recognition, this strategy also helps the Welsh Government restrict and contain the public discontent that was sure to follow the plans to a few relatively sparsely populated areas. 

As you can see from the above map, there are no SSAs on Ynys Môn — the nearest one being in Clocaenog Forest on the Conwy and Denbighshire border. Ynys Môn was not identified as being suitable for large-scale wind farm development, no doubt due to it being encircled by the largest Area of Outstanding Natural Beauty (AONB) in Wales amongst other reasons.

TAN 8 clearly states that the Welsh Government wants to protect such landscapes. It states: 

"Large areas of Wales were excluded from consideration as SSAs by features that militate against larger wind power developments. In particular large wind power proposals within a National Park or designated Area of Outstanding Natural Beauty would be contrary to well established planning policy and thus SSAs have not been considered for these areas".  [Section 2.7]

Unfortunately however, TAN 8 does not rule out the development of wind farms outside of SSAs. Although it explicitly states that "most areas outside SSAs should remain free of large wind power schemes", it encourages Local Authorities to consider the development of wind farms up to 25MW on urban or brownfield sites in addition to "smaller community based wind farms schemes (generally less than 5 MW)". However, crucially for Ynys Môn Council, its says that each Local Authority must do so through:

"a set of local criteria that would determine the acceptability of such schemes and define in more detail what is meant by 'smaller' and 'community based'. Local planning authorities should give careful consideration to these issues and provide criteria that are appropriate to local circumstances." [Section 2.12]

By 'community based', the Welsh Government clearly means that smaller schemes should be managed both with the consent of and for the advantage of communities. Ynys Môn has not yet prepared any such local criteria, nor has it defined how it proposes to define the meanings of 'smaller' and 'community based'. 

Furthermore, according to TAN 8, Local Authorities should:

"consider the cumulative impact of small schemes ... and establish suitable criteria for separation distances from each other and from the perimeter of existing wind power schemes or the SSAs. In these areas, there is a balance to be struck between the desirability of renewable energy and landscape protection. Whilst that balance should not result in severe restriction on the development of wind power capacity, there is a case for avoiding a situation where wind turbines are spread across the whole of a county." [Section 2.13]

Ynys Môn Council is not considering the cumulative impact of the 50 plus applications for wind turbines which have been made on the Island as it says it plans to deal with them on an individual and ad-hoc basis; criteria for separation distances have not been established; and, as the below map of wind turbine locations clearly shows, they are already spreading across the whole of the county — a situation with TAN 8 explicitly warns Local Authorities to avoid.

Wind Turbine applications: spread across the whole of Ynys Môn, despite TAN 8
instructing Local Authorities to avoid this.
Furthermore, despite all these applications being dealt with individually,
are they not in effect turning Ynys Môn into a de-facto Wind Farm?

© OpenStreetMap contributors, CC-BY-SA

TAN 8 was introduced by the Welsh Government six years ago in 2005. Ynys Môn's 'Energy Island' strategy was officially launched two years ago in 2010. Yet Anglesey Council did not issue for consultation its Supplementary Planning Guidance (SPG) for onshore windfarms — i.e. a local policy on how to deal with wind turbines — until just last month. The document itself sets out in great detail the planning process for applicants, but crucially is entirely devoid of any strategic consideration of how to deal with wind turbines on Ynys Môn:

• It does not address the issue of avoiding wind turbines spreading across the whole Island as TAN 8 says it should
• It allows for wind turbines to be erected in the AONB — what therefore is the point of having an AONB?
• It does not establish any criteria for separation distances from residential properties, again despite TAN 8 saying that it should
• It considers cumulative impact only from a visual impact standpoint — rather than recognising the need to consider all applications in the round. The current situation means that Ynys Môn in its entirety is being turned into a large-scale wind farm by default, yet each application is being considered individually. This what TAN 8 meant when it stipulated that regard should be had to the potential cumulative effect of smaller proposals.
• It contains no consideration of "smaller community based schemes" whatsoever. 

In contrast, the joint SPG on onshore wind issued by Conwy and Denbighshire councils (issued in 2006 - take note Ynys Môn planners!) is a model of clear and strategic thought:

• It strategically sets out policies on how to deal with large (over 25MW), medium (5-25MW) and small wind farms (<5MW)
• It strategically limits all large-scale wind farms to the TAN 8 SSA of the Clocaenog Wind Farm Zone. 
• Medium wind farms can only be developed within the Clocaenog Wind Farm Zone or on urban or brownfield sites
• Both large and medium size wind farms must be a minium of 500m from the nearest residential property
• Small wind farms are defined as being either 'Community' schemes or 'Domestic' schemes. In the case of domestic schemes, only one turbine no more than 15m in height is allowed. Community schemes must be owned by a community group, be composed of no more than three turbines no more than 70m tall, and must be a minimum of 500m from the nearest residential property. 
• No windturbines are allowed in an AONB.
• The number of small developments will be limited and consideration given to the cumulative impact of them.

Quite frankly, Ynys Môn's draft SPG is so lacking in any strategic thought it would be better if they quietly binned it and adopted Conwy and Denbighshire's grown-up one instead. 

This is what  Jonathan Jones CBE, the head of Visit Wales had to say about wind turbines recently:

"There is a growing recognition of the grave threat that wind turbines represent for the natural environment of Wales — the basis of our tourist economy. All our research consistently shows that the main reason for coming to Wales on holiday is the beautiful, natural and unspoilt environment. If we kill that then we kill an industry." 

Unless Anglesey Council changes direction rapidly we are in danger of turning Ynys Môn into a large floating wind farm — one which will destroy a tourism industry which, even according to the council's own estimates, brings in £215 million of income to the Island every year. In light of figures like this, those who criticise the campaign group Anglesey Against Wind Turbines as being anti-jobs are extremely wide of mark.

There is still time to stop the worse happening. Please respond to the consultation on Anglesey's SPG for onshore windfarm before 10th February (click here). Furthermore, please join the Anglesey Against Wind Turbines protests outside the Council's Llangefni offices at 11.30am on the 1st February — the date of the next Planning Committee meeting.