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Environmental Impact Assessment Electro-Magnetic Interference (EMI) Landscape and Visual Assessment
Background
& Context
Ceiriog
Valley Action Group (CVAG) stresses, at the outset, that it is not opposed, in
principle, to the generation of electricity by wind power.
Indeed, it is strongly in favour of environmentally friendly energy
sources. The
opposition to the proposal to site these three 300ft high turbines in the
Valley, is that we believe it will have a seriously negative impact on both
residents and tourists alike. The
site lies within an area of Outstanding Natural Value and outside defined
settlement boundaries, where there is a strong presumption against development,
which will affect its open character. To
allow this proposal would prejudice the character of the surrounding landscape
and detrimentally impact on the privacy and amenities of adjoining properties,
hamlets and villages by virtue of increased vehicular movements and noise
disturbance. It
will also have a negative effect upon the visual amenity of almost the entire
Ceiriog Valley, as the 300ft turbines will ensure that they can be viewed from
many places along the Valley, as well as being intrusive to the local area of
the proposed site. In
1994 an application was received, by the former Clwyd County Council, for the
erection of 16 wind turbines. This
application is, in part, the same application (ie: the same location for 3 of
the originally proposed turbines). A massive groundswell of opinion, throughout the Ceiriog
Valley and beyond, resulted in that application being withdrawn. An
intensive doorstep survey was conducted and 628 people were interviewed, 69% of
whom were opposed to the development (18% were undecided and 12% were in
support). Subsequently, almost 1000
letters of objection were received by the Planning Department, including
approximately 100 letters from visitors to the Valley.
These objections have not gone away. Why Wales?
The
developers report states that Government
targets for “additional” wind energy installations require Wales (although
there are no regional targets within Wales) to install an additional 3000 GWh of
generating capacity but the rest of the UK (including Scotland) only to install
an additional capacity of 1570 MW. A vast discrepancy and clearly one which shows that such wind
turbine clusters are not wanted in England. Claimed benefits
The
proposal claims that, in addition to the financial benefit to the landowner, the
wind turbines would annually generate an electricity output equivalent to the
average domestic consumption of ‘about’ 2700 homes. NOT TRUE. The turbines
operate only at wind speeds above 25mph but below 56mph. The optimum output (the only figures quoted by Dulas
Engineering Ltd) is therefore only achieved approximately 30% of the time.
One third of maximum potential ! top^
Environmental Impact Assessment
Wrexham
County Borough Council has not yet conducted an Environmental Impact Assessment
(EIA), in contradiction of planning guidelines. The only environmental report to
be produced has been an abbreviated one by the contractor and is, in our view,
grossly inaccurate and lacking in detail. We have called upon Wrexham County
Borough Council Planning Department to conduct an independent EIA and await
their response. Dulas Engineering Ltd has prepared a shortened Environmental report, which
is full of biased, irrelevant and plainly wrong information.
The report states that according to Town & Planning Environmental
Impact Assessment (EIA) Regulations 1999, an environmental report is not
required for wind turbine clusters of 5 or less.
Presumably, this is why much of the report is general in nature, and not
specifically related to the development in question.
Much of their report has been regurgitated from their 1994 report. Construction
Damage
The route (proposed by Dulas Engineering Ltd) that the construction
traffic would use goes through the village of Selattyn (from Oswestry, on the
B4579). This road is virtually
single track at Selattyn, because residents park cars outside their houses, and
passes a Primary School on a blind junction.
To allow the amount of traffic necessary for the construction of the wind
turbine clusters (which Dulas Engineering Ltd estimates as being over 4000 car
and lorry movements) is unthinkable and positively dangerous, to the village
residents generally and to the Primary School in particular. It defies logic to understand how Dulas Engineering Ltd intends to take
over 300 lorry loads of concrete and road stone past the Primary School, round a
sharp left-hand corner and up a very steep hill. In winter, the regular weather conditions of rain, snow,
frost and ice will make large vehicle movements up this hill impossible.
Even in good weather conditions, cars parked on the roadside will block
HGV movements and cause chaos. One
has to question whether the residents of Selattyn are aware of what has been
proposed and whether they have been given sufficient time within which to
object. Finally, Dulas Engineering Ltd proposes a 31-metre trailer to deliver the
turbine blades and use of a crane, weighing 128 tonnes (with 9 axels) neither of
which, they believe, will require any sort of police escort.
It is clearly ridiculous to consider allowing these monster vehicles
access to the Cefn Coed site, even if it were somehow possible. Electro-Magnetic
Interference (EMI)
National Transcommunications have said that TV interference is likely, should the proposed development go
ahead near Hendre Mountain. The
broadcasting line between Pontfadog and Glyn Ceiriog is at risk.
Furthermore, most of the communities at the bottom of the Valley already
suffer from a weak signal. Some
hamlets (and Pandy in particular) already have serious problems with receiving
an adequate signal, which has resulted in the residents financing and installing
Receiving and Amplifying Transmitting aerials, at their own, not inconsiderable,
expense. Dulas Engineering Ltd states that wind turbines DO cause EMI to
both telecommunication systems, such as TV and radio transmissions, and to
microwave links. This could
seriously impact upon contact with, and between, Emergency Service personnel
called to the Valley; a potentially disastrous consequence for such a rural
community. Dulas Engineering Ltd did contact some Transmission Operators but
“several failed to respond”. This
failure to respond has been taken by Dulas to mean that no problems would be
experienced. If problems are
experienced, Dulas states that such problems would be remedied at their expense
but does not state what will happen if such problems are insurmountable, or how
long residents would have to wait for remedial action to be taken.
Any problems encountered could therefore remain unresolved for years.
Would Dulas Engineering Ltd be legally liable to remedy these problems
and does their offer of funding constitute a legally-binding, open-ended
commitment, regardless of the costs involved ? Noise
Assessment
“At present there is no
established method for predicting wind turbine noise”.
This statement comes from the first page of “The Proceedings of the
Institute of Acoustic” Volume 16 (1994).
The map showing the predicted noise levels by contours, in the Dulas
Statement, makes no allowance for the local topography of the landscape or the
nature of the ground. The
surrounding area of Hendre Mountain has many rock faces, which reflect sound and
can increase noise levels by at least a further 12 dB.
Such an anomaly has been recorded before and was reported upon by the
Institute of Acoustics. “At Coal
Clough (wind farm) predictions were 11dBa lower than those which actually
occurred”. No measurements were taken
in the village of Pandy, the nearest village to the proposed turbines
(approximately 650 metres). The vague predictions of noise, from untested turbines, must cast doubt on
the thoroughness and accuracy of the Survey. The software programme, developed in conjunction with Dulas
Engineering Ltd to predict noise levels, must be regarded with caution, since
theirs is a vested interest and almost certainly bound to understate true
levels. Noise levels from wind farms have, in general, exceeded those which were
predicted, prior to previous wind farms developments being approved.
In the light of this, it would seem that the concern of the residents,
both from the immediate surrounding area and the village of Pandy (surrounded as
it is by substantial rock faces), is justified. Ecological Assessment
The survey, commissioned by Dulas Engineering Ltd but undertaken by ADAS
was, yet again (as it was in 1994) conducted in the winter month of February
2002 “in adverse weather conditions”. It
is not stated how many days the survey was conducted over, and whether or not
the personnel carrying out the survey were appropriately qualified. February is the least appropriate time for a survey of this type to be
conducted. Upland birds move to
lower ground and estuary habitats, to avoid food shortage caused by the high
ground adverse weather conditions of the winter period. A true and proper comprehensive survey can only be carried
out on an ‘all seasons’ basis and concentrating on the breeding season (ie:
April through to August). The bird life in this, and the surrounding area, has been studied on a
regular and intensive basis by the British Trust for Ornithology (BTO) and
licensed ringing of birds has been carried out by the Merseyside branch of the
BTO for many years. Despite the
degree and amount of information readily available, ADAS consulted only with the
RSPB, who have no specific knowledge of this area. Various species of bird were observed when the survey was conducted but
several species, which are known to be present, were not recorded.
These include Red Kite (seen but not nesting), Goshawk, Hen Harrier,
Merlin, Peregrine Falcon, all 5 species of Owl, Field Fare, Redwing, Crossbill
and Brambling. In spring, the area is alive with at least a further 17 species of
Summer-visiting birds. Breeding
records exist for Swift, Swallow, House Martin, Redstart, Winchat, Wheatear,
Grasshopper Warbler, Whitethroat, Blackcap, Chiffchaff, Spotted & Pied
Flycatchers and Cuckoo. To date,
over 100 species of bird have been recorded in and around the proposed
development area, by the BTO. The ADAS report states that there are now
recorded cases of bird strike on wind turbines. A single case of bird strike could mean the end of Peregrines
in the Ceiriog Valley. Even if bird
strike is discounted, it is a matter of record that birds will desert a wind
turbine area. Recent excursions to
wind farms in Powys and Montgomeryshire reveal virtually NO bird
life in or around the area. ADAS reported on badger foraging in one corner of the survey area. The badgers presumably will desert their nearby sets, once the disturbance of the Construction Phase starts. A reptile and amphibian survey during the freezing month of February is
totally meaningless, as any Naturalist (or common sense) will confirm.
However, it is known locally that the proposed development area is
inhabited by adders. The report stated that many species of plant were difficult to locate and
identify. This is easy to
understand, as the Survey was conducted in February and quite possibly the area
was covered in snow ! Water Course
In the proposed development
area, several properties rely on springs, as their sole supply of household
water and water for livestock. The
driving of foundations and trenches for the proposed turbine site, will cut
across the supply of at least 5 dwellings (the possible effect on others is of
concern but difficult to quantify). If
the supply of spring water is affected or polluted in any way, by the
development, then mains water from Glyn Ceiriog will have to be connected at
considerable cost. Who will bear
these costs ? Dwr Cymru (Welsh
Water) categorically refuse to contemplate financial assistance.
Will Dulas Engineering Ltd bear these costs, or will the matter have to
be litigated ? Experience at the Ovenden
Moor Wind Turbine Site (Yorkshire) provides alarming information.
Hydrologists and Engineers have reported that the erection of large
turbines on upland moorland has cracked the bedrock and diverted the natural
water course. Around the turbines
and along the cable trenches, the thin layers of peat are drying out so rapidly
that, what was once moorland is now turning to dust and blowing away.
The tracks to the turbines caused a different problem.
Deep pools of ‘peat soup’ (fetid surface water) have formed, which
remain stagnant. Permanent and
irreversible damage has already been caused to Ovenden Moor.
Not only have the spring water supplies been drastically affected, but it
has become a disaster area for the animals, birds and insects, so dependent upon
a fragile ecology for their survival. Property
Values
If permission is granted,
for the erection of 3 giant wind turbines at Cefn Coed, this will not be the end
of the matter. It is known that at
least three other Landowners along the valley are awaiting the outcome of this
proposal, so that they can submit their own applications. Whilst, in 1994, an
application was received for 16 turbines (which was later withdrawn, due to
local opposition), the gates could well and truly open this time.
Within two or three years we could have scores of giant turbines along
the Valley. Common sense dictates that
house prices will, at the least, freeze and more likely fall.
That is, if houses can be sold at all. After all, if all the
predictions on noise, intrusion on the landscape, Electro Magnetic Interference
and the like are correct, would YOU buy a house in the Ceiriog Valley ? Landscape & Visual Assessment
Dulas Engineering Ltd conducted a viewpoint analysis from 15 different
viewpoints, yet originally reported on only 6.
Were the non-selected other 9 so detrimental to
their cause that they decided to hide the results ?
Production of the additional 10 ‘Wire Frames’, at the request of
Wrexham Council, show that the turbines are clearly visible from all viewpoints
and, of the 6 viewpoints originally selected, the 4 which concerned residents,
all show an unwanted line-of-sight view of the turbines. The viewpoint pictures are all computer generated images and represent a
masterpiece of digital photography manipulation, understating, as they do, the
turbines’ visual impact upon the surrounding landscape.
By any assessment, the huge 90 metre turbines are neither attractive nor
unobtrusive. The statement goes on to state that in many cases the presence of a
tree-line-cluster would hide or obscure the turbines. These “tree-line-clusters” are, in fact, fir trees which
do not match the height of the turbines and which will be felled in due course,
further exposing the turbines. Finally, the report states that several hamlets within the Study Area will
only have sight of turbine tips. However,
no mention and therefore presumably no study, has been made of PANDY, the
nearest hamlet to the proposed site. Pandy is only 1000 metres from the site of
the proposed development and will, indeed, have the turbines in line of sight.
Every resident of Pandy has stated their complete opposition to the
proposed wind farm and has written to the County Borough Council Planning
department formally, to register their objections. Ceiriog Valley Action Group (CVAG) has commissioned a photographer to take
photographs from several relevant locations and to superimpose the giant turbines onto
them, to give a realistic idea of the skyline, after they have been erected.
These photographs can be viewed on this website. Conclusion
The overriding and fundamental objection to this application remains the
wholly unacceptable intrusion into, imposition upon and degrading alteration to
the peaceful and unspoilt landscape of the Ceiriog Valley. No single generation, let alone a single Developer or an avaricious
Landowner, can be allowed to ruin this ancient and collectively loved landscape,
for the sake of short-term financial gain and a miniscule return in overall
energy reward. To allow this proposal would make a mockery of the Local Authority’s
efforts to promote the scenic beauty of the Valley and its uplands to the
thousands of visitors who return, year after year, to recharge their hearts and
souls. The Ceiriog Valley is indeed
the Jewel in the County Borough’s Crown, but for how much longer ?
Information provider: Phil Spratley Tel: 01691 718494 email: msc@globalnet.co.uk
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Last modified: July 02, 2002 |