Ramblers’ Association Wales Renewable Energy Policy
Appendix A
Welsh Assembly Government has set an all-technology renewable energy target for 2010 which represents 10% of electricity generation (not, it should be noted, of consumption, which runs at half that level). This was published by its Economic Development Committee (EDC) in 2003 as 4Terra Watt hours (TWh) per annum, to be attained by an equal three-way division between onshore wind, offshore wind and other renewables. In late 2004, the Assembly’s Planning Division issued the consultative draft of a revised Technical Advice Note (TAN 8) on Renewable Energy which proposes that the 4TWh pa target be achieved primarily from onshore wind with a reduced target for offshore wind, and virtually no increase in the remaining technologies. It defines seven upland Strategic Areas outside nationally designated landscapes for accelerated onshore wind development within which the normal planning constraints such as visual and cumulative impacts would in effect be disregarded. Elsewhere, developments would not exceed 25 Mega Watt (MW) capacity - still larger than most existing installations.
This is a completely different approach than that used in Scotland and England through NPPG6 and PPS22 respectively, and is highly controversial, not only for its desertion of conventional landscape safeguards, but for the uncorroborated basis on which it has abandoned the previously published proportions of the major technologies. There is in fact authoritative evidence that the 4TWh target is on course to be substantially exceeded by major contributions from offshore technologies within the 2010 period. In the TAN 8 text it is accepted that built and consented renewable energy project already account for 1.9TWh capability, since when a further consented offshore wind project has raised this to over 2.2TWh pa. At a meeting, November 9th 2004, of the Assembly’s Sustainable Energy Group, the promoters of two major schemes presented detailed proposals to generate virtually 3TWh within the 2010 period, despite both being excluded from the Assembly’s assumptions - (Tidal Electric’s Swansea Bay lagoon – 0.33TWh pa and npower Renewables’ Gwynt-y-Mor 18km-offshore windpower project – 2.63TWh pa).
Consequently we do not accept the claimed pressing need to concentrate the vast majority of the capacity needed to satisfy the target into the one technology - onshore wind - that has the greatest ability to impact adversely upon the upland and coastal landscapes of Wales, and particularly to bring this about by the virtual abandonment of the countryside protection policies which lie at the core of the planning system. It is already apparent from the unprecedented response of 1700 submissions on TAN8, that organisations, individuals and local planning authorities are of a similar view. Accordingly we do not believe that our policy should be in any way conditioned by the emergence of the Assembly’s consultation draft, which in this respect we reject, and trust will be substantially revised to reflect the realities of the situation.
May 2005
