comments of ceredigion county council to the responses to ...... · comments of ceredigion county...

Comments of Ceredigion County Council to the responses to the Second round of questions from the ExA Question Number.

Response to the question and by whom. Ceredigion County Council’s comments.

1.3

The applicant. a) It is not known whether the proposed boundaries were settled at this point, or whether they would have been subject to further review and amendment. Had the order been confirmed in this form, all of Mid Wales over 300m would have been in a National Park. (See Appendix 2 attached). In that theoretical scenario the Cefn Croes, Rheidol and Bryn Titli wind farms would all have been within this designated area. In addition TAN8 SSAD (Nant y Moch), would have been in this context, together with the proposed Mynydd y Gwynt and Bryn Blaen wind farms. b) The intrinsic value of the landscape is not solely dependent on or related to any designations. Although designation might be a factor to take into account with regard to the value ascribed by the public, intrinsic value stems from a number of other factors including landscape quality, rarity, and perceptual aspects. Therefore, by not being designated it doesn’t diminish the intrinsic value of the landscape, or the value attached to it by the Applicant.

It is self-evident that, had National park Status been confirmed, Cefn Croes, Rheidol, Mynydd Gorddu, Bryn Titli, and possibly Llangwyryfon would not exist. SSA D would not have been identified because of the absolute constraint of National Park status and Mynydd y Gwynt and Bryn Blaen would have been considered non-starters therefore it is difficult to see what point the applicant is trying to make here. Agreed.

On the basis of the applicant’s landscape assessment, however, the value of this landscape cannot be regarded as being of the level of National Parks and Areas of Outstanding Natural Beauty because the landscape is not intrinsically sufficiently attractive to draw in visitors in the way in which National Parks and Areas of Outstanding Natural Beauty do. It is also pertinent to record the change that the maturing and felling cycles of the broad-scale forestry in the northern parts of the Cambrian Mountains area have had on the intrinsic value of the area over the last 40 years in particular, in the time since national designation was considered. This means that the landscape of the northern part of the Cambrian Mountains would be unlikely to meet the criteria expected for AONB or NP status by virtue of the impact this forestry has had on the areas of natural beauty.

The Countryside Commission would not have prepared an Order for confirmation if they had not considered the landscape to have been of National Park quality. The Order was not confirmed because the landscape was not considered to be of National Park quality but for other reasons. The evidence presented by CCC, PCC, NRW and the Cambrian Mountains Society rebuts the applicant’s view that the landscape is not intrinsically attractive to visitors and the fact that large numbers are not attracted to the area does not devalue the quality of the landscape as suggested by the applicant. 36,400 ha, some 17% of the ground area of the Snowdonia National Park, is covered by woodland ranging from broad leaved, coniferous and mixed woodlands some of which are owned and managed by the National Park Authority. Coed y Brenin is the Forestry Commissions exemplar visitor centre and off road biking centre situated within the National Park and forestry is promoted along with the other attractions of the Park. To suggest that the existence of forestry would prevent AONB or NP status is not founded.

1.5

To be clear, the Applicant does not rely on the potential for the site to have been included in the SSA. The letter from Defence Estates of 22 July 2004 (MYG-AD-5-APP1)

The County Council would wish to refer the ExA to:

was written in response to the fact that the application site had originally been subject to Defence Estates’ objection – as the letter records. The proposers (who then consisted of the landowners and local businessman, assisted by Mr Martin Alder, a wind energy consultant) were unwilling to accept this blanket sterilization of the site and so Mr Alder secured a meeting with Defence Estates. That meeting revealed that the Defence Estates requirement was not for a blanket tactical training area but for a low flying zone, for which unimpeded access for low flying in the valleys was principally required, The resolution of this misunderstanding enabled the Defence Estates to clarify the position in its letter referred to above, and for the application area freed for wind farm development. As a result the original team then sought to have the area included in the TAN8 SSA D designation. Unfortunately, most written records have been disposed of, but discussions took place in 2005 and continued in 2006 to try and overcome the issue. During the course of these, Mr William Little, then Senior Environmental Consultant with ADAS (UK) Ltd, discussed the site with Simon Power of Ove Arup & Partners (“Arup”), the consultant leading the TAN8 SSA study (“Arup Study”). Mynydd y Gwynt had approached Arup to prepare a comparison of the Mynydd y Gwynt site with the Arup Study for SSAD, applying the same criteria. Although Arup was initially willing to carry out this exercise they ultimately determined not to do so. however, during the course of

Spatial extent of strategic search areas. Facilitating Planning for Renewable Energy in Wales: Meeting the Target – ARUP Review of Final Report of June 2005 which can be found at Appendix 1.

At the time of the publication of the draft of TAN 8 various consultees queried whether the proposed SSAs should be increased/decreased in size. A review of the spatial extent of SSAs with respect to the following constraint themes was, therefore, carried out in response to consultation comments:

• Ministry of Defence Mid Wales Tactical Training Area (TTA)

• Common land • Sites of Special Scientific Interest • Wind Speed distribution using NOABL • National Air Traffic Service (NATS) constraints • Isolated properties and the noise generated by

wind turbines. Within the Draft TAN 8 mapping, the boundaries of SSA B (Carno) and C (Llandinam East) were drawn slightly inside the MOD TTA, as it was anticipated that the MoD would be flexible regarding possible extensions to the existing groups of wind turbines at Carno and P&L (Llandinam East). Including part of the TTA within the SSAs was an attempt to deal with uncertainty at the time regarding the degree to which the TTA should be viewed as an absolute constraint.

http://wales.gov.uk/docs/desh/research/050601planningarupjune2005en.pdf



the conversations Mr Little had with Mr Power, Mr Power stated that without the objection from the MoD the site would have been their preferred Area D. Further, Mr Little attended a meeting in Aberystwyth with Mr Brian Barrows, then head of the Welsh Development Agency’s Energy Office. The intention of the discussion was to seek the assistance of the WDA in persuading its colleague bodies to revise the Area D designation. Mr Barrows also said that but for the objection from the MoD the site would have been included in Area D. Unfortunately, and no doubt due to the sensitivity of the information, neither Mr Power nor Mr Barrows were prepared to confirm this in writing. Mr Little will however be prepared to provide a statutory declaration confirming these discussions if required. The then development team also provided evidence to the Welsh Affairs Select Committee in 2005, a copy of which has been printed from the UK Parliament Website and is appended at Appendix 3. Whilst it is appreciated that this is a document produced by Mynydd y Gwynt, it is contemporaneous with the events set out above and in parts 3 and 4 sets out the MoD issue.

The Welsh Government and the Ministry of Defence reached a memorandum of understanding whereby the SSAs as published in the Draft TAN 8 were not considered to be in conflict with the TTA. In three other cases (Areas C, E and G) the review exercise identified small areas of unconstrained resource immediately adjacent to the SSA boundaries which LPAs might wish to examine in further detail at the local level. A number of reductions to the SSAs were suggested, comprising land with no discernible potential for wind turbine development due to a combination of topography, the presence of residential properties and marginal wind speeds. The technical basis behind the onshore wind energy aspects of the Draft TAN 8 were extensively reviewed over a 5 month period. The range of consultation responses combined with the specific consultations undertaken as part of the study, provided a robust examination of all the issues associated with the strategic planning of wind turbines in Wales. In was concluded that: the decision to develop SSAs, and the method used to identify them, remained valid;

• excluding landscape and visual issues (to a degree) in the initial identification of the SSAs was the correct approach;

• the identified boundaries of the SSAs should

remain largely unchanged, but assessment suggested modification, as indicated, to better reflect the areas of potentially developable resource;

• there were no new SSAs required, and that none of

the existing SSAs (as published in the Draft TAN 8) require removal.

Having taken all the reviewed factors and suggested boundary modifications into account it was predicted that:

• the SSAs remain capable of delivering the government target (800MW) for renewable energy in Wales; and

• the target capacity for allocation in LPA plans and

policies will fall somewhere between the government target (800MW) and the maximum capacity identified in the Garrad Hassan study (1666MW) – to take account of site specific factors limiting availability and LPA consideration of landscape and visibility matters.

The following actions were recommended:

• the strategic approach to the planning of wind turbines in Wales, involving the identification of several strategic search areas, should continue;

• the modified SSAs (and appropriate capacities)

should be re-published as part of the Final TAN 8;

• local planning authorities which encompass SSAs should be encouraged to undertake further assessment work to refine the SSAs to take account of local factors.

Arup would have been aware of the Y Foel proposal. The report demonstrates that representations regarding the draft TAN were taken into account and the findings of the report may explain why ARUP declined to carry out a comparison of the Mynydd y Gwynt site with the Arup Study for SSAD, applying the same criteria. In Research: Search Areas (SSA) Reassessment and Validation. A Research Report to the Welsh Assembly Government (July 2010) it was concluded in table 5.4 on SSA area D that: “Plynlimon and areas of LANDMAP visual and sensory outstanding evaluation may further reduce capacity”. This recognised the importance of Pumlumon and its surroundings in landscape quality terms and as an absolute constraint. The document is attached at Appendix 2. The evidence presented by the applicant is unsubstantiated evidence and cannot alter the fact that

the Mynydd y Gwynt land is not within or well related to SSA D.

1.7

The applicant.

1) The Ministerial Statement of 17th June 2011 is a statement that sets out WG’s policy towards sustainable renewable energy with particular emphasis to on-shore wind, making reference to:

- A Low Carbon Revolution - PPW - TAN8 The contention by CCC that such Statements carry ‘little or no weight’ is not accepted by the Applicant. 2) The Ministerial Statement (17th June 2011) and the First Minister’s letter of July 2011 do not change the policy approach of the Welsh Government towards large scale windfarm development. The Ministerial Statement and Ministerial Letter re-state the strategy to focus such development to the SSAs and restrict a proliferation of large scale windfarms across of the whole of Wales. The Ministerial Statement and Ministerial Letter should be read alongside TAN8, and be attributed weight in the same context as TAN8, namely an important planning policy consideration to which the decision-maker is required to have regard to, but not the primary policy

To be clear, the decision maker has to adopt the following hierarchy in the decision making process:

• The duties conferred under Section 104 0f the Planning Act 2008 (as amended by the Localism Act 2011);

• National Policy Statements for Energy; • Planning Policy Wales (July 2014); • Technical Advice Note 8: Renewable Energy; • Policy Clarification Letters; • The duty conferred by Section 38(6) of the

Planning and Compulsory Purchase Act 2004; • The Development Plan; • Any other matter determined as material to the

consideration of the application which may include open letters from Ministers.

Where open letters or statements cite policy it is the policy that carries weight. Where statements are at odds with policy the letters or statements cannot re-write the primary policy. It can be seen from the hierarchy that open letters or personal statements from Ministers cannot be attributed great weight in the overall balance where they are odds with stated policy.

basis for the determination of this application. As made clear at paragraph 4.1.5 of NPS EN-1 the preparation of the energy NPSs ‘have taken account of Technical Advice Notes (TANs) in Wales where appropriate’. The applicants’ position regarding the hierarchy and relationship of policy is fully set out in its Deadline II written representation at part 2, and in its Deadline III submission document, again at part 2.

PPW, paragraph 1.1.4, clearly states that PPW, the TANS, circulars and policy clarification letters comprise national planning policy. TAN 8 therefore comprises primary Welsh policy and is not, as suggested at paragraph 2.16 1 of the evidence presented by Peter Frampton in response to the ExA’s first round of questions, guidance only. TAN 8 not only deals with the spatial aspects of onshore wind but also the scale, hence onshore wind is assessed in terms of schemes over 25MW (Large scale), those between 5MW and 25MW, and those under 5MW. Paragraph 2.2 of TAN 8 talks about large scale onshore wind developments being concentrated into particular areas defined as SSAs paragraphs 2.11 – 2.13 deal with onshore wind in other areas (outside SSAs). In what the County Council interpret as reference to paragraph 2.4, paragraph 2.13 indicates that most areas outside SSAs should remain free from large wind power schemes, so it is conceded that wind farm schemes may take place outside SSAs but only if there is robust evidence that land outside (but close to) the SSA is suitably unconstrained. The evidence presented above in relation to: Search Areas (SSA) Reassessment and Validation. A Research Report to the Welsh Assembly Government (July 2010) suggests that land to the east of SSAD would not be suitably unconstrained for the reasons give.

Para 2.13 goes on to say that the Assembly Government would support local planning authorities in introducing local policies in their development plans that restrict almost all wind energy developments, larger than 5MW, to within SSAs and urban/industrial brownfield sites. It is acceptable in such circumstances that planning permission for developments over 5MW outside SSAs and urban/industrial brownfield sites may be refused. This can only be interpreted as a statement of support to confine wind turbine development over 5MW to SSAs without prejudicing the ability of local planning authorities, through their development plans, to have a degree of flexibility on schemes between 5 and 25MW. From that statement it is clear that the Welsh Government considered TAN 8 to be a statement of confinement and not concentration. The applicant’s interpretation of TAN 8 as guidance only is not accepted nor is the applicant’s spin on TAN 8 being guidance on concentration rather than of confinement, however, the test in every case for any wind turbine developments outside the SSAs is whether “the implicit objective (in Annex D paragraph 8.4 of TAN 8) to maintain the landscape character i.e no significant change to landscape character” has been met. This is confirmed in the conclusion of the Inspector at paragraph 11 of the decision letter into the proposal to erect 10 wind turbines at Rhos Garn Whilgarn appeal reference: APP/D6820/A/07/1200875 and referred to in

the EVALUATION OF CUMULATIVE LANDSCAPE AND VISUAL IMPACT ASSESSMENT UPDATE: Final Report for Natural resources Wales by White Consultants February 2015 Appendix SWUA. It is interesting to note that the Department for Communities and Local Government are seeking to encourage local councils in England to set out, in their Local Plans, where renewable energy development should, and should not take place, in line with the National Policy Framework. This would appear to be an attempt at confinement not containment in line with Welsh Government policy. See: http://www.parliament.uk/documents/commons-committees/energy-and-climate-change/150306-SoS-onshire-wind.pdf

2.2

The applicant. The significant cumulative effects on the whole of the study area were consistently reported; including the western and south-western parts of the study area. In its deadline III responses CCC cross-refers to Paragraphs 4.36-38 of its LIR. Reading paragraphs 4.36-38 of CCC LIR it appears that the concerns of CCC are concentrated on the north-

Whilst the County Council accept that the ES recognises that the impacts are assessed in summary in the ES LVIA the point the Council make is that CRDGNVS313 and CRDGNVS508 are outstanding in the LANDMAP Visual and Sensory Character Evaluation, outstanding in the Visual and Sensory Scenic Quality, and CRDGCL508 is of high value in the Cultural landscape group evaluation and the Cultural Landscape Rarity Evaluation. This

http://www.parliament.uk/documents/commons-committees/energy-and-climate-change/150306-SoS-onshire-wind.pdf



eastern part of the Cambrian Mountains (South) (CRDGNVS313) aspect area that lie 8km from the nearest turbine at the closest point (See Figure 8.2i of the ES). Any views from this area north would be in the context of Cefn Croes in the near-distance between the viewer and Mynydd y Gwynt. Whilst there would be some distant views of Mynydd y Gwynt, and the potential for cumulative effects, the main effect would be that of the views of the Cefn Croes turbines in the near-distance of the views. This is clearly described and reported in paragraphs 8.456-458 of the ES.

compares to anywhere else in the ZTV other than perhaps Pumlumon yet their importance seems to be reduced in the assessment process because of the scale of the aspect areas, particularly CRDGNVS313. Table 8.5 of the landscape assessment in the ES assesses where an actual view of the turbines would be experienced and where the views are considered negligible. CRDGNVS313 and CRDGNVS508 both qualify as negligible and accordingly no further assessment was undertaken for these aspect areas. In table 8.6 of the landscape section of the ES CRDGNVS313 and CRDGNVS508 are identified as having Medium to High sensitivity to the type of development proposed whilst table 8.7 assesses the magnitude of effect as Slight to Moderate/ Moderate for CRDGNVS313 and Moderate to Substantial for CRDGNVS508. In the summary of effects on landscape character both are considered to have changes in view of a low magnitude or above with significant effects being identified for CRDGNVS508. The County Council, however, consider that the effects of the proposed development on the north eastern part of CRDGNVS313 would be significant despite the LVIAs assessment for the whole aspect area being considerably less. This aspect area is located between 8km to 20km to the south and south-west, of the Mynydd y Gwynt site, covering the most extensive area of land in the region and

it is axiomatic that an assessment for an aspect area stretching so far from the site, because of the reduction of effect with distance, is likely to register significantly lower than one closer to the site, however, the landscape value of the north eastern part of CRDGNVS313 is high and the Council consider that it has not been accorded the importance that it should have. In terms of cumulative assessment, the updated CLVIA indicates that there would be some open views from the land south of Cefn Croes, at a distance of about 7km from Mynydd y Gwynt. However, these would all be in the context of the Cefn Croes turbines in the near distance (1-3km), with the Cefn Croes turbines spreading over an arc of view for these viewers of over 60-degrees. The Bryn Blaen turbines would be seen for this area at a greater distance of about 12km and to the north-east of the viewer, east of both the Mynydd y Gwynt and Cefn Croes turbines. The updated CVLIA concludes for CRDGNVS313 that no significant cumulative landscape effects would be brought about as a result of the Bryn Blaen development and this is no different to the original conclusion in the ES, however, once again, this diminishes the actual effects on the north eastern corner of CRDGNVS313.

The justification for excluding Nant Y Moch from the updated CVLIA is based on the fact that after ten years there has been no application in SSA D. The County Council would refer the ExA to the fact that Mynydd Y Gwynt itself has taken ten years from its first manifestation as Y Foel to the current application. Nant Y Moch remains registered with PINS. In the County Council’s experience it is not uncommon for wind farm development proposals to take a long time to get from initial inception to application. Figure 4.1 – Wind Farm development time line – set out in Search Areas (SSA) Reassessment and Validation. A Research Report to the Welsh Assembly Government (July 2010) at Appendix 2 demonstrates that throughout Wales, but particularly in SSAs BCD and G, there would be an increase in deployment from 2015 on. For SSAs BC and D the timeline did not take into account the delay that would result from the conjoined planning Inquiry and grid connection issues as recognised in the accompanying text. At paragraph 3.26 of the County Council’s representations the County Council say: “Given the uncertainty and delay generated by the conjoined planning Inquiry in Powys and the delay in the NGT grid programme SSE are in no hurry to progress Nant Y Moch any further at present and it is easy to see the advantage to SSE of allowing the Mynydd y Gwynt

application to test the veracity of Welsh Government spatial policy as represented in TAN8”. This would apply to any successor in title to the site. Whilst preliminary environmental information was in the public domain for the section 42 responses from Powys and Ceredigion in fact the scheme has significantly progressed well beyond that as evidenced by White Consultants at the open floor hearing on landscape issues. That information is not in the public domain but provides the County Council with sufficient justification to reiterate its disappointment that Nant y Moch has not been included in the updated CVLIA. As a result the County Council take the view that the cumulative effects on the whole of the study area have not been consistently reported.

2.6

The applicant. The summary description drawn from LANDMAP of the Plynlimon VSAA is correct in stating that there is limited public access and that it consists of a couple of footpaths. The OS plan only shows two footpaths to the cairns at the summit and nothing along the ridge. The un-waymarked Cambrian Way crosses the area, and the route of this is described in detail in t Figure 8.9 of the ES. The majority of the area is afforded Open Access, (see Figure 8.10a&b of the ES) and therefore in theory anyone can walk anywhere. In reality to get onto the paths or open access

NRW has already confirmed that the summary description from LANDMAP of the Pumlumon VSAA is an error. Enclosed at Appendix 3 and 4 are maps showing the public rights of way in Ceredigion in the area of the VSSA and the common land which is shown red, blue or green. The colours for the common land merely delineate different types of landownership. The whole of the VSAA CRDGNVS151 is CROW access land.

24th March 2015.

land a walker needs to either walk a considerable distance or park at one of a restricted range of locations: at the Hafren Forest Car Park, the private land on the south side of the A44 adjacent to the entrance to the Sweet Lamb Rally Complex, in one of the few lay-bys on the A44, in one of the lay-bys on the single-track road heading up through the Nant-y-Moch valley, or at the pay car park at Eisteddfa Gurig.

There are three well known routes within Ceredigion to the summit of Pumlumon. The two referred to by the applicant being the single track road beside Nant Y Moch Reservoir and Eisteddfa Gurig, however the third is from the car park at Dyffryn Castell which joins the route from Eisteddfa Gurig by Dyll Faen. The contention, by the applicant, that there is limited public access to Pumlumon is not founded.

Welsh Assembly Government

Facilitating Planning For Renewable Energy in Wales: Meeting the

Target

Review of Final Report - Research Contracts

105/2002 and 269/2003

Welsh Assembly Government

Facilitating Planning For Renewable Energy in Wales: Meeting the Target

Review of Final Report - Research Contracts 105/2002 and 269/2003

June 2005

This report takes into account the particular instructions and requirements of our client. It is not intended for and should not be relied upon by any

third party and no responsibility is undertaken to any third party.

Ove Arup & Partners Ltd 4 Pierhead Street, Capital Waterside, Cardiff CF1 O 4QP Tel +44 (0)2920473727 Fax +44 (0)2920472277

www.arup.com

Job number 115399-01

ARUP Document Verification Page 1 of 1

Job title Facilitating Planning For Renewable Energy in Wales: Job number

Meeting the Target 115399-01

Document title Review of Final Report - Research Contracts 105/2002 and File reference

269/2003 4-50 05/6662 Document ref

Revision Date Filename 0005TAN 8 REPORT.doc Draft 1 20/05/05 Description First draft

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Issue for 06/06/05 Filename 0010Arup addendum TAN 8 report. doc Final Description Version issued for final Planning Division/OCTO review. Review


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Ove Arup & Partners Ltd Issue 28 June 2005

Welsh Assembly Government Facilitating Planning For Renewable Energy in Wales: Meeting the Target Review of Final Report - Research Contracts 105/2002 and 269/2003

CONTENTS

Page

1. INTRODUCTION 1 1.1 Report structure 2

2. CONTEXT 3 2.1 Main issues raised by the TAN 8 Consultation 3 2.2 Energy/Capacity Assessment of TAN 8 Wind Energy Strategic Search Areas: 3 2.3 Brief for additional work 4 2.4 Approach to the Arup work 5

3. REVIEW OF THE TREATMENT OF LANDSCAPE AND VISUAL ISSUES/CUMULATIVE IMPACT 6

3.1 Overview 6 3.2 Protection of National Landscape Designations 6 3.3 Use of landscape character data, including LANDMAP 7 3.4 Cumulative landscape and visual impact 9 3.5 Summary 11

4. REVIEW OF THE DEFINITION, SPATIAL EXTENT AND CAPACITY OF SSAS 12 4.1 Overview 12 4.2 Definition of strategic search areas 12 4.3 Spatial extent of strategic search areas 13 4.4 Conclusions: spatial extent of strategic search areas 20 4.5 Capacities of the strategic search areas 20

5. CONCLUSIONS AND RECOMMENDATIONS 23 5.1 Conclusions 23 5.2 Recommendations 23

APPENDICES

APPENDIX A Advice to Local Planning Authorities

APPENDIXB Updated Strategic Search Areas

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1. INTRODUCTION The Welsh Assembly Government is committed to delivering renewable energy targets published in the Governments Energy White Paper (2003) through the development of an energy programme which contributes to the carbon emission targets. This includes specific renewable energy targets of 4 Terrawatthour (TWh) per annum by 2010 as part of the wider UK national target of generating 10% of electricity consumption from renewable sources, and 7 TWh per annum by 2020. The Welsh Assembly Government has announced the need to plan for between 800 -1000 Megawatts (MW) of installed capacity of onshore wind (some 400-600 additional turbines approximately) by 2010 if there is to be a realistic chance of achieving the 4TWh target.

Original research (Research Contracts 105/2002 and 269/2003 ') was commissioned by the Welsh Assembly Government to assist with the redrafting and implementation of Technical Advice Note 8 (Renewable Energy), published in 1996. Arup and its sub-consultants were appointed in September 2002 to undertake the research.

The brief was to provide a map for Wales identifying 'strategic search areas' capable of delivering the Welsh Assembly Government's Renewable energy target of 4 TWh by 2010. The fundamental objective was to ascertain: the most appropriate areas of Wales in which to locate the 800MW of onshore wind turbines minimising direct land take. The area needed to accommodate this scale of development, allowing a margin for local siting, is approximately 140km2 or 0.68% of the land area of Wales.

The research employed a land-use sieve approach applicable at an all-Wales level to identify relatively unconstrained areas according to nominated criteria. This data was then combined with information on the capacity of the existing and proposed grid network to produce a plan indicating broad strategic search areas for major wind energy developments, together with a strategic assessment of their potential wind energy capacity to 2010. The result of the analysis was the derivation of seven strategic areas for large-scale onshore wind energy development in Wales.

The Draft revised Technical Advice Note (TAN) 8 on Renewable Energy (hereafter referred to as Draft TAN 8) issued on 13 July 2004 contains these seven strategic areas. The TAN (when finalised, hereafter referred to as Final TAN 8) is aimed primarily at local planning authorities but is also of interest to developers, government agencies, environmental groups and members of the public. It is intended to provide guidance on national planning policy for renewable energy in support of Planning Policy Wales (PPW), as amended by the draft Ministerial Interim Planning Policy Statement (MIPPS), which was issued for consultation at the same time as the T AN2. .

The Welsh Assembly Government is continuing to develop its approach to the strategic planning for renewable energy in Wales and, following a period of consultation which closed on the 5th November 2004, has revised and updated TAN 8 in response to issues raised by statutory consultees and other respondents. This report details the further technical assessment/research undertaken by Arup to support this work between December 2004 and the issue of the Final TAN 8 in summer 2005.

, Facilitating Planning for Renewable Energy in Wales: Meeting the Target (2004 ), Arup for Welsh Assembly Government, as available on www.wales.gov.uk 2 The role of PPW/MIPPS is to set down land use policy for local planning authorities/others to take on board when developing Local Development Plans or submitting/taking decision on applications. Role of TAN is to elaborate on how the policy should be implemented.

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1.1 Report structure This report is structured as follows:

• Section 2, Context, contains a review of the issues raised in the consultation on the Draft TAN 8, as far as they pertain to the original Arup work undertaken to inform the T AN. This is followed by the brieffor the additional work undertaken by Arup between December 2004 and the issue of a Final TAN 8 in summer 2005 and the project methodology.

• Section 2, Review of landscape, visual and cumulative impact issues. In this chapter, the key issues of landscape and visual impact are re-examined again in the light of responses to the Draft TAN 8. This establishes the context for Appendix A: Advice to Local Planning Authorities. This provides further information on the means by which local planning authorities, either singularly or in combination, can take the initiative in planning the strategic search areas incorporating landscape and visual issues and considering cumulative impact.

• Section 3, Review and Implications: spatial extent and capacity, contains a description of the work undertaken by Arup in order to respond to the issues raised in the consultation. It deals with each issue in tum and outlines the implications for the work undertaken to date.

• Section 4, Conclusions and Recommendations, outlines the implications for the Final TAN 8.

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2. CONTEXT

2.1 Main issues raised by the TAN 8 Consultation Approximately 1700 consultation responses were received by the Welsh Assembly Government (WAG) relating to the Draft TAN 8 and the MIPPS. A full analysis of these is contained in a separate report prepared by WAG and this is expected to be published in summer 2005.

Consultation responses were made by a wide range of individuals and organisations, including the public, governmental and non-governmental organisations, and developers of wind turbines. Most sections of the Draft TAN 8 were commented on in some detail and many representations related to issues of Welsh energy policy, which sits largely outside the scope of the TAN and accompanying Arup research. The Draft T AN8 contained a detailed description of the purpose and derivation of the Strategic Search Areas. Many consultees, therefore, commented in some detail on the methodology adopted by Arup and the choice of constraints used in the all-Wales mapping exercise. In particular the following issues were raised:

the treatment of landscape and visual issues/cumulative impact (in particular the perceived neglect of these); and

the definition, spatial extent and capacities of Strategic Search Areas (with specific reference to the Geographic Information System (GIS))established for the research and the weight given to certain factors (e.g. coniferous forestry).

Of particular concern to some industry representatives was whether the areas identified were sufficient in extent and/or had sufficient capacity to allow achievement of the 800MW of onshore wind by 2010. Shortly after the end of the consultation period, therefore, another consultant was appointed to undertake a validation of the technical capacities of the SSAs; their findings are discussed below.

2.2 Energy/Capacity Assessment of TAN 8 Wind Energy Strategic Search Areas: In winter 2004, Garrad Hassan and Partners Ltd (GH) were commissioned by the Welsh Development Agency to carry out a technical feasibility study' of the seven proposed wind energy SSAs. This was to provide a 2nd opinion on the installed capacity in MW of the areas, as approximated by Arup. The premise behind the GH study approach was to first establish a "Base Case" to reflect the (potential) capacity of the SSAs in the absence of any constraints. Suitable "Constraint Cases" were established reflecting planning constraints and rational design criteria, namely:

(1) Noise levels from very large wind turbines;

(2) National Air Traffic Service ("NA TS") concerns; and

(3) The effect of mature trees on energy production

By quantifying the impact of each of the three constraints in terms of MW capacity these figures could then be subtracted from the original "Base Case" to provide output capacities reflecting the different constraint scenarios (1 to 3).

3 Energy Assessment of TAN 8 wind energy strategic search areas ( 2005 ) - unpublished report. Garrad Hassan and Partners Ltd, for Welsh Development Agency

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Data generated by GH (and displayed in Table 1 below) represent the "Base Case" with noise as the only constraining factor. The two remaining constraints were not used to inform the final assessment because of ambiguities surrounding their validity as absolute constraints (see discussion of these issues in Chapter 4, section 4.5).

Table L Energy Yields ( GH estimates)

Strategic Search Rated Capacity Output Rated Capacity Output A Area (MW) (MW)

Draft TAN 8 Garrad Hassan Report A 200 212 B 200 430 C 100 98 D 100 212 E 100 152 F 350 430 G 150 132

Total 1200 1666 Source: Garrad Hassan Study (2005)

A Base case + Noise: the Garrad Hassan noise constraint cases introduced an appropriate maximum noise buffer of700m

Results of the feasibility study (see data in Table 1) confirm the Arup initial assessment that the SSAs have the potential to meet or exceed the Assembly's target of800MW used to underpin the revised TAN 8, although there are some variations in the capacity output figures when compared to the Arup data.

2.3 Brief for additional work The Welsh Assembly government re-appointed Arup in December 2004 in accordance with the following brief'-

• "Further to assist on issues raised during consultation on the Draft TAN 8 and the draft Strategic Search Areas (SSAs) -To explore [technical} concerns raised by the consultation with respect to the Draft TAN 8 and the SSAs and to include support to Assembly Government (AG) in meetings with various organisations and local authorities affected by SSAs (principally in South Wales).

• To assist AG with any technical queries that were raised by respondents to the TAN 8 consultation - To include ad-hoc meetings with Assembly officers and others as appropriate as required to provide an explanation of the methodology used etc.

• To develop options for (and modify as required) the current TAN 8 SSAs to reflect points raised by the consultation and other emerging work. - To propose solutions to specific issues in relation to the SSAs as established in summer 2004

• To provide modified TAN 8 SSAs to Garrad Hassan and Partners Ltd to aid in a capacity verification exercise - The Welsh Development Agency has commissioned a capacity study of the SSAs (undertaken by Garrad Hassan and Partners Ltd). This work reported in April 05. Arup are to liaise with the consultants concerned/review other developer representations and consider modifications to the SSAs/capacity estimates accordingly. In conjunction with Garrad Hassan a common approach to the absolute and variable constraints should be developed taking account ofGarrad Hassan's work.

• Output -Recommendations are to be made to Assembly Government with respect to

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» whether the SSA boundaries should be altered,

» and/or whether extensions to the SSAs or new SSAs are justified. These should be considered in the context of whether the TAN 8 consultation responses cause the use of particular criteria to be reviewed.

» an appropriate minimum size of SSA

» the weight that LANDMAP should be given in the detailed planning of the SSAs by local planning authorities.

In association with client, provide a new 'road-atlas' style TAN 8 map of the SSAs for incorporation within the Final TAN 8. A brief report will be needed setting out the reasoned justification for any changes.

2.4 Approach to the Arup work The review stage was an iterative process, given that a number of the research streams engaged with during earlier phases of the study were revisited. To update existing knowledge involved:

• Consultations with stakeholders, principally Welsh Assembly Government and the Forestry Commission.

• Field visits: - to check/validate, mainly in South Wales

• Further GIS analysis - to assemble and analyse additional data gathered from field visits

The next two chapters of this report review each of the major issues raised in the TAN 8 consultation by others, as far as they relate to the Arup technical assessment work that underpinned the Draft TAN 8 issued on 13 July 2004. Taking each issue in tum, the concerns/queries raised are discussed, any work undertaken to review these concerns/queries is explained and the implications for the original Arup work and final TAN 8 considered.

The issues are considered under two themes:

• The treatment oflandscape and visual issues/cumulative impact

• Definition, spatial extent and capacities of strategic search areas

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Welsh Assembly Government Facilitating Planning For Renewable Energy in Wales: Meeting the Target Review of Final Report - Research Contracts 105/2002 and 26912003

3. REVIEW OF THE TREATMENT OF LANDSCAPE AND VISUAL ISSUES/CUMULATIVE IMPACT

3.1 Overview During the development of the SSAs, the Welsh Assembly Government consultancy brief indicated:

"This study (Research Contract 269/20034) wil! exclude non-statutory environmental constraints/factors such as landscape capacity and sensitivity, historic landscapes, National Trails, consideration of landscape quality and character using LANDMAP in the initial identification of 'strategic search areas '.

In accordance with the brief, the SSAs were therefore defined by the absence of agreed National and International designations, combined with other technical and practical factors.

It was however recommended as an output of Research Contract 269/2003 that

"the Welsh Assembly Government further develops the draft strategic areas ... .[ and] they are also reviewed in relation to the local landscape and visual issues, particularly LANDMAP data and/or other county-level landscape data and assessments".

In response to the consultation on the Draft TAN 8, the treatment oflandscape and visual issues has been reviewed. This chapter considers the main points of that review:

• The case for buffers around national landscape designations

• The use of landscape character data, principally LANDMAP

• Cumulative visual and landscape impact.

3.2 Protection of National Landscape Designations

3.2.1 Use of buffer sub-areas

The Draft TAN 8 contains the following statement in criteria used to determine the location and extent of the draft strategic areas:

The edge of the area is greater than 4km from the boundary of a National Park.

This has been queried/challenged by various consultees.

The original Arup research considered a distance of between 30 and 35km when evaluating whether wind turbines in any of the proposed strategic areas are likely to be visible from the National Parks, Areas of Outstanding Natural Beauty (AONBs) and National Trails. Only broad comments were made, however, on the likely visibility of the various SSAs from the nationally designated areas. The SSAs were not modified to take account of these comments. The report indicated:

"With regard to at what distance (and hence, magnitude of impact) the [landscape and visual ] effects become significant, there is a complete lack of statutory guidance. Until such time as robust consensus on significance based on detailed research, can be claimed with confidence, best practice requires that the bases for al! judgements made are clear and explicit on a case-

4 Facilitating Planning for Renewable Energy in Wales: Meeting the Target ( 2004 ), Arup for Welsh Assembly Government, as available on www.wales.gov.uk 5 Facilitating Planning for Renewable Energy in Wales: Meeting the Target (2004 ), Arup for Welsh Assembly Government, as available on www.wales.gov.uk

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by-case basis. For this reason no specific distances have been identified as minimum separation buffers between National Parks, AGNBs, National Trails and potential strategic areas."

No further research or guidance is available on legitimate buffers, and so this view still holds. It is not appropriate to set standard distance buffers for the Welsh National Parks/AONBs at the national level. Local terrain factors mean that any such buffers would have to be variable and site-specific, and thus defined following considerable study at the local level. For example, in Northern Snowdonia, the land within the park is elevated and separated from the nearest SSA by intervening valleys (suggesting any buffer would have to be considerable to be effective), yet in Southern Snowdonia the land within the Park and the SSA is formed by a ridge (where a smaller buffer is more likely to be sufficient). It is suggested that the reference to 4km, and separation buffers, is removed from the Final TAN 8.

A consideration of the landscape and visual effects upon National Parks/AONBs is best undertaken at a regional/county level where the assessment can be informed by suitable field studies of an SSA and its environs. An outline methodology for this is contained in Appendix A: Guidance for Local Planning Authorities.

3.2.2 Size I scale of wind turbines inside sensitive national landscape designations

The consultation Draft TAN 8 currently indicates

"The Welsh Assembly Government does not consider that the siting of large scale (25MW+) wind turbines is appropriate in National Parks and AGNBs, recognising their designation as areas of value as a result of the landscape they protect, although smaller scale domestic or community-based turbines may be suitable, subject to local planning considerations. "

The definition of large scale as being greater than 25MW was in the Arup brief from the Office of the Chief Technology Officer of the Welsh Assembly Government for Arup Stage 2 work. Published Arup reporting repeats this definition without further clarification; it contains no environmental threshold for the size of developments within National Parks/ AONBs.

The use of the 25MW+ criterion has been reviewed, and it is concluded that developments of such a scale would cause landscape and visual impacts (upon the nationally designated landscape areas) that are likely to conflict with their policy protection and reasons for designation.

Small scale wind developments may be appropriate within National Parks and AONBs. No guidance is offered on the scale of such developments, since this falls outside the remit of identifying strategic search areas. LP As will consider such proposals on their merits and subject to an appropriate level of assessment.

3.3 Use of landscape character data, including LANDMAP One of the major issues raised in response to the Draft TAN 8 consultation related to the lack of consideration of landscape character issues in the derivation of the seven SSAs.

There were two reasons for this and these are covered separately below.

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3.3.1 Geographic coverage of datasets

Firstly there are currently no complete national datasets for Wales that can easily and accurately define the landscape resource. LANDMAP6 is the landscape assessment tool, devised by the Countryside Council for Wales to enable information about landscape to be gathered, organised and evaluated into a nationally consistent data set. LANDMAP information is collected in a structured and rigorous way that aims to be as objective as possible. Its database contains both relatively objective information - such as rock type and historical information - and more subjective information, such as sensory responses and cultural interpretation. LANDMAP information can also be combined with contextual socio economic information. There are 5 Evaluated Aspects of LAND MAP (Geological Landscape, Landscape Habitats, Visual and Sensory, Historic Landscape and Cultural Landscape). The majority of Wales is now covered by some form of LAND MAP assessment commissioned by the appropriate local planning authorities, however some authorities are still without data or have the data in a preliminary form. It is recognised that in time an all-Wales LAND MAP dataset may be available, but the issues outlined below should apply to its use.

3.3.2 Accepted thresholds of change

The second reason for the omission of landscape character data was as indicated in the original Arup research 7 namely "there are no currently accepted thresholds of acceptable/ unacceptable change in landscape character in the UK, particularly in relation to wind energy developments."

This is still understood to be the situation. The case has been made in the consultation responses, however, for the use of LAND MAP data (where available and quality assured) to assist in the strategic planning of wind turbines. It is first necessary to revisit the definitions and concepts of landscape sensitivity and capacity and how they might affect the planning of wind turbines these are set out below.

"i] Overall landscape sensitivity: This term should be used to refer primarily to the inherent sensitivity of the landscape itself, irrespective of the type of change that may be under consideration. It is likely to be most relevant in work at the strategic level ....

. . Relating it to the definitions used in Landscape and Visual Impact Assessment, landscape sensitivity can be defined as embracing a combination of

• the sensitivity of the landscape resource (in terms of both its character as a whole and the individual elements contributing to character);

• the visual sensitivity of the landscape, assessed in terms of a combination of factors such as views, visibility, the number and nature of people perceiving the landscape and the scope to mitigate visual impact.

ii) Landscape sensitivity to a specific type of change: This term should be used where it is necessary to assess the sensitivity of the landscape to a particular type of change or development. It should be defined in terms of the interactions between the landscape itself, the way that it is perceived and the particular nature of the type of change or development in question.

iii) Landscape capacity: This term should be used to describe the ability of a landscape to accommodate different amounts of change or development of a specific type. This should reflect:

6 Countryside Council for Wales (June 2003) The LAND MAP information manual 7 Facilitating Planning for Renewable Energy in Wales: Meeting the Target ( 2004 ), Arup for Welsh Assembly Government, as available on www.wales.gov.uk

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• the inherent sensitivity of the landscape itself, but more specifically its sensitivity to the particular type of development in question, as in (i) and (ii). This means that capacity will reflect both the sensitivity of the landscape resource and its visual sensitivity;

• the value attached to the landscape or to specific elements in it. ,,8

It is considered that LANDMAP can assist with:

• the division of parts of Wales into character areas, although the typical spatial units for a LAND MAP are quite small when compared to the SSAs

• The determination of overall landscape sensitivity, via the use of some of the evaluated aspects, such as the visual and sensory layer.

It is considered most appropriate to address landscape sensitivity at a local level where the assessment can be informed by site-specific studies of an SSA (based on LAND MAP data) and its environs involving an appropriate level of fieldwork and assessment. An outline methodology for this is contained in Appendix A: Guidance for Local Planning Authorities.

It is not considered currently possible to use LAND MAP on its own (whether at a national or local level) to assist in the determination of landscape capacity with respect to wind turbines for the following reasons:

" .. capacity studies must be specific to a particular type of change or development. At a strategic level, for example in work relating to regional and sub-regional spatial strategies, this means that it might be appropriate to produce a single map of general landscape sensitivity. Maps of landscape capacity, however, need to be specific so that, for example, a map showing an assessment of wind turbine capacity could be produced but would almost certainly be different from a map showing capacity for housing development or for new woodland and forestry planting. Some capacity studies are very specific in their purpose, seekingfor example to assess capacity to accommodate a 1000 home settlement at a particular density of development."

"This is why capacity is such a complex issue and why most capacity studies need to be accompanied by guidelines about the ways in which certain types of change or development can best be accommodated without unacceptable adverse effects." 9

It is important to note, therefore, that high or outstanding value in a LANDMAP aspect does not necessarily mean that an area has a lower capacity for the development of wind turbines.

It is considered most appropriate to address landscape capacity at a regional/local level where the assessment can be informed by site-specific studies of an SSA and its environs. An outline methodology for this is contained in Appendix A: Guidance for Local Planning Authorities.

3.4 Cumulative landscape and visual impact One of the other major issues raised in response to the Draft TAN 8 consultation related to the lack of consideration of cumulative landscape and visual aspects in the derivation of the seven SSAs. Such cumulative impacts have been defined as:

"35 those which occur, or may occur, as a result of more than one wind farm project being constructed. The degree of cumulative impact is a product of the number of and

8 Scottish Natural Heritage and the Countryside Agency - Landscape Character Assessment: Guidance for England and Scotland: Topic Paper 6: Techniques and Criteria for judging Capacity and Sensitivity. 9 Scottish Natural Heritage and the Countryside Agency - Landscape Character Assessment: Guidance for England and Scotland: Topic Paper 6: Techniques and Criteria for judging Capacity and Sensitivity.




distance between individual windfarms, the inter-relationship between their Sub-areas of Visual Influence (ZVI), the overall character of the landscape and its sensitivity to windfarms, and the siting and design of the windfarms themselves. It is important to recognise that cumulative effects consist of both those upon visual amenity as well as effects on the landscape "IO

The degree of cumulative impact also gives rise to the notion of thresholds, beyond which impacts may not be acceptable. The Scottish Guidelines, quoted above, refer to an objective led approach:

"54 In order to justify a threshold based on natural heritage factors, there needs to be clarity over natural heritage objectives. Without such clarity, there is little value in seeking a cumulative impact assessment in the first place. Thus, for example, in relation to cumulative landscape impacts, one needs to be clear whether the landscape objective in the area is

• to maintain the integrity and quality of the landscape (as may be appropriate within a designated landscape);

• to maintain the landscape character; or

• to accept landscape change?'

There was an implicit objective in Draft TAN 8 to maintain the integrity and quality of the landscape within the National Parks/AONBs of Wales i.e. no change in landscape character from wind turbine development.

In the rest of Wales outside the SSAs, the implicit objective was to maintain the landscape character i.e. no significant change in landscape character from wind turbine development.

Within, (and immediately adjacent) to the SSAs, the implicit objective was to accept landscape change i.e. a significant change in landscape character from wind turbine development.

The Draft TAN 8 (and the work on which it is based), therefore, considered cumulative landscape and visual impacts at the all-Wales level. The strategy adopted is a means of concentrating the impact of wind turbines in a relatively small proportion of the country in areas that are, on balance, technically, practically and environmentally better able to accommodate such impacts than other parts of Wales.

At the local level, accepted thresholds of change, having regard to nationally developed energy capacity targets, can be established by more detailed assessments (see Appendix A: Guidance for Local Planning Authorities).

3.4.1 Size/Scale of developments. outside the SSAs

The current Arup reporting'" makes no recommendations as to what planning controls/policies should be adopted outside the seven defined SSAs. For the wider area beyond the SSAs, not comprising urban/industrial sites13, no research has been undertaken on the suitability of different scales of development.

If sites other than urbanlindustriallocations outside SSAs are to accommodate wind turbines, these developments should be subject to environmental impact assessment in the normal way.

IO Guidance on the cumulative effect of windfarms ( 2005 ), Scottish Natural Heritage II Guidance on the cumulative effect of windfarms ( 2005 ), Scottish Natural Heritage 12 Facilitating Planning for Renewable Energy in Wales: Meeting the Target (2004 ), Arup for Welsh Assembly Government, as available on www.wales.gov.uk 13 Powys Energy Agency - The Potential for Wind Power in urban, industrial and commercial sites in Wales - May 2003

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Local Planning authorities could be encouraged to set criteria based upon the appropriate physical size and number of turbines in each development.

3.5 Summary The result of the review of how landscape, visual and cumulative issues were treated in the Draft TAN 8 suggests that the approach adopted by Welsh Assembly Government, in conjunction with Arup, remains robust i.e. that the issues cannot be addressed satisfactorily at the all-Wales level below statutory designations with current data availability, resources and assessment tools. It is considered that to undertake an-all Wales landscape capacity study (building upon LANDMAP data) with respect to wind turbines would be a poor use of resources, given the range of other technical, practical and environmental factors that limit the location of SSAs. As indicated, these issues are best addressed at the local/regionallevel where knowledge and understanding of the areas can be brought to bear.

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4. REVIEW OF THE DEFINITION, SPATIAL EXTENT AND CAPACITY OF SSAs

4.1 Overview This chapter considers the definition, spatial extent .and capacities of strategic search areas and presents the results of the review work.

4.2 Definition of strategic search areas

Previous Arup reporting." and the Draft TAN contains little or no description of the nature, scope and meaning of what a Strategic Search Area (SSA) is. The SSAs were primarily defined on the absence of various national technical and environmental constraints. It is, therefore, important to identify what constitutes an SSA in terms of its positive characteristics.

In previous Arup reporting the SSAs arose from the areas which came through the national constraints sieve, using judgement and local knowledge of the following factors for refinement:

• Size of area • Land use, settlement density • Landform • Presence or absence of open moor/coniferous forestry.

The process is set out in the Figure below. Extract from previous Arup Reporting, Figure 5.6, Refinement of strategic areas for onshore wind in Wales.

Resuls from Grid """ conseeees - wth ~1CMJtNI threshold to grid areas

14 Facilitating Planning for Renewable Energy in Wales: Meeting the Target (2004 ), Arup for Welsh Assembly Government, as available on www.wales.gov.uk



Welsh Assembly Government Facilitating Planning For Renewable Energy in Wales: Meeting the Target Review of Final Report - Research Contracts 105/2002 ancl269/2003

An SSA is characterised by:

• a good wind resource (typically >7ms-l) • predominantly upland (typically over 300m above ordnance datum) • a dominant landform that is of plateau rather than a series of well-defined ridges (in

order to allow any proposed developments to be sited well back from ridge edges to minimise their visual influence and to allow accommodation of proposals of the scale proposed)

• being generally sparsely populated, or having populated areas at its margins or in discrete concentrations (to minimise affects upon visual and aural amenity)

• land use that reflects low biodiversity/agricultural value, typically degraded to some extent ( and usually with few landowners ), which is most able to offer the scope for land use improvements (e.g. dominated by conifer plantation and/or improved/impoverished moorland)

• a general absence of nature conservation or historic landscape designations (as far as can be determined at the National level based on existing digital data)

• being largely unaffected by broadcast transmission, MOD and aviation radar constraints

The area should be extensive areas (>2Skm2) to allow a minimum of between SO-lOOMW capacity.

These criteria are the inverse of the constraint criteria used in the development of the strategic search areas, but were not specified in the previous reporting. The SSAs are considered to be consistent with these criteria.

Implications for SSA boundaries

4.3 Spatial extent of strategic search areas Various consultees queried whether the existing SSAs should be increased/decreased in size. A review of the spatial extent of SSAs with respect to the following constraint themes was, therefore, carried out in response to consultation comments:


• Common land

• Sites of Special Scientific Interest

• Wind Speed distribution using NOABL

• National Air Traffic Service (NATS) constraints

• Isolated properties and the noise generated by wind turbines

A summary of the review findings is presented at the end of this section.

4.3.1 Ministry of Defence (MoD) Mid Wales Tactical Training Area (TTA)

Within the Draft TAN 8 mapping, the boundaries ofSSA B (Camo) and C (Llandinam East) were drawn slightly inside the TT A, as it was anticipated that the MoD would be flexible regarding possible extensions to the existing groups of wind turbines at Camo and P&L (Llandinam East). Including part of the TTA within the SSAs was an attempt to deal with

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uncertainty at the time regarding the degree to which the TT A should be viewed as an absolute constraint.

The Welsh Assembly Government and the Ministry of Defence have now reached a memorandum of understanding whereby the SSAs as published in the Draft TAN 8 are not considered to be in conflict with the TT A.


None, SSA boundaries can remain as published.

·4.3.2 Common land

Consul tees have responded that the use of Common Land as a constraint was inconsistent. In particular the "variable constraint' status of Common Land in the original Arup work meant that some SSAs had areas of common land within them. The issue was compounded by the availability of an incomplete dataset of Common Land for Wales which excluded Powys (SSAs B and C).

The issue of common land was considered in the original Arup work a landownership/legal (rather than environmental) matter. In view of the responses to the Draft TAN 8 it is considered that this no longer needs to be the case; developers have been successful in obtaining planning permission to site wind turbines on Common Land in Wales.

Common land areas tend, if appropriately managed, to have some landscape/biodiversity/amenity value, but these issues are covered as constraints elsewhere in the Arup derivation of SSAs. The value of common land and its influence over wind turbines is one that would be dealt with more suitably if it entered the planning debate at the local level where appropriate management benefits could be sought.


None, since common land did not ultimately inform SSA definition. The SSAs were defined on the basis of an absence of other environmental, technical and practical constraints. Common land can remain a local level factor to consider within SSAs.

4.3.3 Sites of Special Scientific Interest

Consultees have queried the 'variable constraint' status applied to Sites of Special Scientific Status (SSSI) within the Draft TAN and the associated Arup reporting.

The extent of SSSIs within and adjacent to the SSAs has been reviewed. It is concluded that in almost all cases the SSAs as developed did in fact exclude SSSIs in any event as they tend to co-exist with other absolute constraints. Development within SSSIs is not considered essential to achieve the Welsh Assembly policy aims on renewable energy.

It is therefore suggested that the SSAs can be exclusive of SSSIs and that the Welsh Assembly Government should ensure that the sites are protected from damage and deterioration in accordance with Planning Policy Wales. It is recognised, however, that it may, in exceptional circumstances, be considered appropriate to consider development within SSSIs at a regional/local level where the assessment can be informed by fieldwork.

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This should only be considered where it can be demonstrated locally that the SSA would otherwise be unable to deliver the capacities proposed in TAN 8.

None.


4.3.4 Wind Speed distribution using NOABL

Consul tees have queried the use of the NOABL wind model and the wind speed thresholds adopted to eliminate parts of Wales.

In the original Arup research, the premise behind the exercise was to (qualitatively) eliminate 'void' areas where development proposals are unlikely to be submitted, reflecting inadequate wind resource. To this end all areas of Wales with a wind speed less than 6ms-l (based on the NOABL database IS) were considered as being 'absolutely constrained.'

However, wind energy developers will only pursue development opportunities in locations with a proven wind resource. Practically, an annual mean wind speed figure of7rn1s is regarded as an economic threshold, defining the situation where wind energy development presently becomes commercially feasible. Evidence suggests that frequently.wind speeds in excess of 7ms-l (on the basis of the NOABL model) are required to realise potential developments.

The re-examination of the extent of SSAs with respect to wind speed is discussed below. This takes two forms:

• A review of the distribution of wind speed 7m/s and upwards within the SSA. This tends in all cases to reduce the potentially developable area as would be expected given the threshold used to define the SSAs originally

• A review of whether there are areas of wind speed 7m/s and upwards adjacent to the Draft TAN 8 SSA boundaries, which should have been included in the original research but were omitted accidentally or which now should be included following a re-examination of the status of various constraints (such as common land).

IS NOABL -UK Wind Speed Database -Background Information -The data is the result of an air flow model that estimates the effect of topography on wind speed. There is no allowance for the effect of local thermally driven winds such as sea breezes or mountain/valley breezes. The model has a lkm square resolution and takes no account of topography on a small scale or local surface roughness (such as tall crops, stone walls, or trees), both of which may have a considerable effect on the wind speed. The data can only be used as a guide and should be followed by on-site measurements for a proper assessment. Each value stored in the database is the estimated average for a I km square at either 10m, 25m or 45m above ground level (agl). Available via www.britishwindenergy.co.uk)

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Strategic Search Area A: the existing SSA boundary fails to take full advantage of the potential wind resource on offer in the locale around Denbigh Moors. By redrafting the boundary to incorporate two tranches ofland between the A543 and the A458 near Llanrwst and a small 'leg' of land to the south of the existing SSA boundary could have a substantive impact on the feasible maximum capacity within this SSA.

Reason not suggested - SSSI (Hiraethog)

Strategic Search Area B: the implications for the dimensions of this SSA are (potentially) the most radical of all the SSAs. If the SSA boundary was refined to reflect observed mean wind speeds (in the absence of other constraints) then the revised margins would extend south-west as far as SSA D in Ceredigion. This could effectively double the achievable capacity output. .

Reason not suggested - MOD TTA.

Strategic Search Area C: extending both the eastern and western margins of this SSA . would accord with high values of mean annual wind speed recorded in and around the area published in the Draft TAN 8. Such an enlargement would increase the (potential) maximum capacity output for the SSA.

Suggest minor adjustments could be made at the local level to accommodate these areas.

Strategic Search Area D: the SSA could form part of an extension to SSA B, as detailed above.

Reason not suggested - MOD TT A and SSSI (Plynlimon)

Strategic Search Area E: the SSA could be compressed to concentrate development in areas with the highest wind potential, thus eliminating the southern section of this SSA where topography and the existence of settlement and properties coincide with lower wind resource.

Suggest - reduce size ofSSA.

Strategic Search Area F: The SSA could be extended eastwards to include many of the eastern valleys and in particular a large area with high wind resource extending north-south from Brynmawr, via Pontypool to Cwmbran (Coity Mountain and Mynydd Maen). This possible revision was subject to specific field review given its potential.

Reason not suggested - Eastern extension areas do not meet the criteria for SSA

Strategic Search Area G: extending the SSA north-eastwards (to the A482), south of the B4310 and west (to the A484) would accord with high values of mean annual wind speed recorded in and around the area published in the Draft TAN 8. Such an enlargement would increase the (potential) maximum capacity output for the SSA.

Reason not suggested -MOD TTA and isolated properties. However minor adjustments could be made at the local level to accommodate these areas.

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4.3.5 National Air Traffic Service (NATS) constraints

Consul tees have raised the issue of National Air Traffic Service (NATS) constraints and pointed out that the data was not considered as part of the Draft TAN 8 and original Amp reporting.

Maps produced by NATS (issued in June 2004) provide developers with information about areas where wind turbine developments may be of concern. On the maps, blue notation shows those areas where wind turbines developments are likely to interfere with the operational infrastructure ofNATS. Yellow notates areas where there is a potential to interfere with this infrastructure (see www.bwea.com)

A review of the maps indicates that SSAs A, Band G, as published in the Draft Tan 8, coincide with Primary and Secondary Radar Areas identified by NATS. As part of the analysis of consultation responses to the Draft TAN 8, therefore, Welsh Assembly Government (via the Office of the Chief Technology Officer) consulted NATS on the degree of constraint posed by the Primary and Secondary Radar Areas.

In response; National Air Traffic Services (Services Ltd) (NSL) has clearly stated that the boundaries of the Strategic Search Areas (SSAs) do not need to be modified from the standpoint of air traffic control. With regards to specific windfarm developments within the SSAs located in the south east region, NSL have stated that some could proceed (subject to a height restriction of 130 metres) albeit dependent on NATS En-Route Ltd's general requirements for development within ten kilometres of radar sites and other navigational aids. It is only in a limited area outside of the aforementioned restrictions that NSL would wish to consider windfarm applications on a case by case basis.


None, but NATS position should be conveyed to Local Planning Authorities to assist in the planning of SSAs at the locallregionallevel.

4.3.6 Isolated properties and the noise generated by wind turbines

Noise from wind turbines can be more or less distinguished depending on the difference between noise from the wind turbine and the background noise. The background noise, for example traffic noise, noise from industries and the whistling in bushes and trees, vary from site to site, but also day from night. The local physical circumstances, such as the placing of houses, may shelter the site from wind on the ground, lowering the background noise so that noise from the turbine will be more easily heard.

The majority of wind farm noise assessments are undertaken using the methodology 'developed for the DTII6. This document states the procedure to make sure that sites are chosen appropriately, and that noise levels are considered in the overall planning process. This is regarded as the relevant guidance by the planning authorities in the UK and indicates that noise from wind farms should be limited to 5dBA above background noise for both day and night-time.

Developers are obliged to carry out noise predictions to evaluate the likely perception of noise from wind turbines on local residents and those working in the vicinity. They compare the predicted noise levels of turbines with the existing background level. The assessment should

16 The Working Group on noise from wind turbines (1996) assessment and rating of noise from wind farms' (ETSU R-97

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be able to demonstrate compliance with national noise regulations. Developers generally present their noise predictions as contour maps, with contours joining locations of equal noise level. The site-specific nature of noise assessments makes drawing out "rule ofthumb"criteria suitable for a National GIS sieve analysis difficult.

The Draft TAN 8 currently indicates "It is generally accepted that commercial scale wind turbines should be sited 500m or more from noise-sensitive properties. The sieve mapping exercise therefore excluded land within 500m of cities, towns and villages. However, there are some sites within urban areas (remote from noise sensitive properties) that are appropriate for wind power proposals, these have been the subject of separate examination".

Consultees to the TAN have made three main points in relation to this paragraph:

a) The statement was been interpreted as establishing a policy buffer around properties, rather that simply an explanation of the technical methodology used to eliminate land from the national sieve exercise in the Arup research, as should have been the case.

b) It was interpreted that isolated properties and/or any clusters of properties below "village" status, were not considered as part of the Arup research.

c) The technical basis for the 500m buffer is not clear and may not be sufficient.

The treatment of the presence or absence of noise sensitive properties was two-fold in the Arup research:

a) Using the GIS and available Ordnance Survey digital datasets'", land within a 500m buffer of the majority of cities, towns, farms and other settlements was treated as an absolute constraint in the identification of SSAs. Urban areas appeared in the Draft TAN 8 SSAs (e.g. some of the towns in the South Wales valleys) because of the need to draw together various topographic features into larger planning units. It was not intended that all of the land area within SSAs was to be developed with wind turbines; in fact the figure was less than 50%.

b) In subsequently defining the capacities of SSAs, all residential properties within the SSAs (identifiable at 1 :50000 scale on OS Landranger mapping) were buffered by hand to approximately 500m and these areas excluded from the identification of potential turbine sites.

Item b) was not made explicit in the previous Arup reporting.

The 500m buffer was based upon an understanding of technical best practice at the time. Desk-based research has subsequently been undertaken to investigate the noise impact from wind turbines on sensitive receptors (humans) and, in particular, to identify whether a minimum standard for separation distances between residential dwellings and wind turbines is being adhered to in practice. Although wind industry professionals generally accept 500m as a suitable separation distance, in the absence of a legislative standard, reported separation distances vary on a project-by-project basis, ranging between 200 metres and 1000+ metres, see Table 2 below. In practice this will depend on topography and orientation, which can best be judged locally.

17 OS Strategic at 1 :250000 scale and OS place name national gazetteer at 1 :50000 scale.

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Table 2. Previously recommended separation distances between wind farms and occupied homes

Source of information Recommended separation distance (metres)

DTIl~ 200-300 De Montfort University" 250 World Energy Council?' 300-400

Planning Policy Guidance 22 - 350-400 Guidance Note

National Wind Power21 400-600 Hoare LEA Acoustics 350 ~ 700

Consultants Scottish Parliament22 1000+

The suite of separation distances presented in Table 2 above illustrates the variability of guidance currently available within the public domain. Based upon an analysis of these, a 500m separation distance would still seem to a sensible compromise as a "rule of thumb" for a strategic or regional planning exercise, as long as the results are viewed flexibly. 500m is, therefore, suggested for use at a local level where the assessment can be informed by site specific studies of an SSA and its environs (see Appendix A: Guidance for Local Planning Authorities).

Implications for SSA boundaries The SSAs, as originally derived (strategic in definition and purpose), included a range of noise sensitive properties both within the SSAs and on their margins. Since these properties effectively prevent the development of wind turbines, it may be said that the present boundaries give a false impression of the spatial extent of likely development within the SSAs.

Having reviewed the extent of the SSAs in the light of the presence or absence of noise sensitive properties, changes in the boundaries of the SSAs are suggested. These changes involve the exclusion of areas, that are not developable for wind turbines due to the presence of noise sensitive properties, where they are contiguous with the SSA boundary. These changes are included within the maps presented in Appendix B - Updated Strategic Search Areas.

The effect of the constraint on potential output capacity posed by noise sensitive properties within the SSAs is considered in section 4.5 below.

18 The Department of Trade and Industry (2005) "Planning: onshore wind" [www] www.dti.gov.uk!renewables/renew_3.5.l.3.htm 19 De Montfort University (1996) Wind Energy Training Centre: Power from the wind [www] http://www.iesd.dmu.ac.uk!wind_energy/sustainable_dev/wcwind.html 20 World Energy Council (2001) Survey of Energy Resources: Wind Energy [www] http://www.worldenergy.org/wec-geis/publications/reports/ser/windlwind.asp 21 National Wind Power (2005) Environmental Studies [ www] http://www.natwindpower.co.uk!search/index.htm 22 Scottish Parliament (2005) Enterprise and Culture Committee: Evidence Received for Renewable Energy in Scotland inquiry [www] http://www.scottish.parliament.uklbusiness/committees/enterprise/inquiries/rei/ec04-reis-craig.david.htm

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4.4 Conclusions: spatial extent of strategic search areas A review of the extent of SSAs has been carried out in response to consultation comments on:


• Common land

• Sites of Special Scientific Interest

• Wind Speed distribution using NOABL

• National Air Traffic Service (NATS) constraints


The net results are included within Appendix B: Updated Strategic Search Areas. In three cases (Areas C, E and G) the review exercise has identified small areas of unconstrained resource immediately adjacent to the SSA boundaries which LP As may wish to examine in further detail at the local leveL A number of reductions to the SSAs are suggested, comprising land with no discernable potential for wind turbine development due to a combination of topography, the presence of residential properties and marginal wind speeds.

4.5 Capacities of the strategic search areas As well as consultation responses relating to the spatial extent of the SSAs, consultees (particularly the wind energy industry), have made representations regarding the capacity of the various Strategic Search Areas to deliver the electrical outputs indicated in the Draft TAN 8.

The specific issues raised were


• Presence of coniferous Forestry

• Ground conditions (presence of peat)

The result of the re-examination of the capacities is presented at the end of this section.

4.5.1 Isolated properties and the noise generated by wind turbines

This issue is discussed extensively above, regarding impact on the spatial extent of the SSAs. However, it also has an effect upon development potential within an SSA. This was considered during SSA capacity estimation for the Draft TAN 8 but only on the basis of Ordnance Survey mapping. Garrad Hassan has subsequently undertaken more detailed noise modelling of the SSAs, using specialist software and hypothetical wind turbine locations. The results of this detailed modelling are considered in Section 4.6: Assignment of Capacities in Final TAN 8.

4.5.2 Presence of Coniferous Forestry

Consultees have queried the assumptions made regarding the degree of felling associated with development of the coniferous forest areas within the SSAs. In particular, since the Forestry Commission (and hence the Welsh Assembly Government) has a duty to have regard to the national interest in maintaining and expanding the forestry resources ofWales23 extensive deforestation could be in breach of its legal duties.

23 under Section SA of the Forestry Act 1967

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In the development of the capacity estimates for the Draft TAN 8, no specific assumptions were made in the Arup research. It was stated "It is possible to locate major wind energy developments in and around coniferous plantations, either on gaps between forestry blocks, on recently felled or planted land or even within mature plantations if the turbines are large enough (typically lOa-130m to blade tip) although examples where the latter has been successfully achieved are presently few. Most areas have access roads that wil! be suitable for the delivery of wind turbines with only minor modification". In reality wind turbines were placed in coniferous forestry for the purposes of estimating the potential capacities of the SSAs, but turbine density was kept low (typically occupying only a third to a half of the forestry area concerned) reflecting a precautionary approach.

Subsequently, two desk-based studies were undertaken to provide commentary on the current state of knowledge vis-a-vis the feasibility of siting wind turbines in areas of forestry. The research was carried out in two phases. The scope for the first piece of research was to evaluate the impact trees have on turbine performance (energy generation). It concluded that the influence of wind shear generated by trees acting as obstacles to wind flow can hinder turbine performance, although raising turbine hub height can sufficiently offset any adverse effect on energy generation.

The objective for the second phase of research was to ascertain the potential for siting turbines within areas of forestry. Particular attention was paid to the physical limitations attributable to the natural fabric (density and structure) afforested areas and how such knowledge could be used to inform developers and (local) planning officials on siting issues. Contact has been made with the Land Agent in Scotland responsible for the overall management of wind turbines developments on Forestry Commission land. At present, the Forestry Commission are dealing with a number of proposed wind turbines throughout Scotland and the solutions to tree felling have their own unique features in each case. These can be:

o No or limited felling, due to turbines being located solely on exposed ridges where planting has not taken place.

o Limited felling because the forest is at a stage where the current crop is young and the developers are prepared to delay felling and address the issue when and if the problem becomes an issue.

o "Key - hole" felling where only a small amount of felling takes place around each turbine.

o Restricted top height management, where the developer agrees that trees will be felled at a defined top height, with compensation being paid at that time.

o More extensive felling, perhaps where the current crop has less commercial value and felling allows a more sustainable and environmentally sensitive management regime to be put in place over the area (typically however still in accordance with any Forestry Design Plan prepared by Forestry Commission).

Further refinement of the above may be required to establish the best strategy at local level. This will require integrated working between developers, local planning authorities and Forestry Commission Wales, with further input potentially required by other stakeholders.

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Implications for SSA capacities

Some 50-60% of the parts of SSAs (that are identified as capable of supporting wind turbines) are within areas of coniferous forestry. The installation of wind turbines within forestry however does bring with it a technical and commercial risk. Based upon recent experience of developers in Scotland this risk is considered low. If satisfactory solutions are not developed in Wales to allow developments to proceed in these areas then the Welsh Assembly Target for renewable energy for 2010 will not be met; there are insufficient non-forested areas identified in the strategic sieve exercise.

The presence of forestry has been considered in detail by Garrad Hassan in its validation review of the capacities of the SSAs.

4.5.3 Ground conditions (presence of peat)

Site selection criteria for wind turbines developments must assign adequate attention to the receiving ground conditions and soil stability levels. Some consultees have raised the possibility of poor ground conditions affecting the ability to develop in the SSAs. In particular a recent case for a 60 MW wind farm at Derrybrien; Ireland, granted full planning permission in July 2003 has been cited. In this, a combination of physical contributory factors in the area resulted in a landslide started along a sub-area of weak peat and a natural drainage channel, instigated by activity associated with the construction of the wind turbines.

No extensive areas of peat bog occur in the SSAs, or indeed in other parts of Wales to the same extent as in Ireland and thus this is not seen as an issue warranting further consideration at the strategic level. This was not however made explicit in the original Arup research.

At the local level, it is anticipated that as part of good practice, developers would obtain professional advice from geotechnical consultants to evaluate ground conditions prior to the submission of a planning application. If planning approval is granted monitoring procedures should be enforced and upheld during various stages of construction.

None.

Implications for SSA capacities

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5. CONCLUSIONS AND RECOMMENDATIONS

5.1 Conclusions The technical basis behind the onshore wind energy aspects of the Draft TAN 8 have been extensively reviewed over a 5 month period. The range of consultation responses, combined with the specific consultations undertaken as part of this study, has provided a robust examination of all the issues associated with the strategic planning of wind turbines in Wales. In can be concluded that:

• the decision to develop SSAs, and the method used to identify them, remains valid.

• excluding landscape and visual issues (to a degree) in the initial identification of the SSAs was the correct approach

• the boundaries of the current SSAs should remain largely unchanged, but assessment suggests modification, as indicated, to better reflect the areas of potentially developable resource

• there are no new SSAs required, and that none of the existing SSAs (as published in the Draft TAN 8) require removal

Having taken all the reviewed factors and suggested boundary modifications into account it is predicted that:

• the SSAs remain capable of delivering the government target (800MW) for renewable energy in Wales; and

• the target capacity for allocation in LP A plans and policies will fall somewhere between the government target (800MW) and the maximum capacity identified in the Garrad Hassan study (1666MW) - to take account of site specific factors limiting availability and LP A consideration of landscape and visibility matters.

5.2 Recommendations The following actions are recommended:

• the strategic approach to the planning of wind turbines in Wales, involving the identification of several strategic search areas, should continue

• the modified SSAs (and appropriate capacities) should be re-published as part of the Final TAN 8

• local planning authorities which encompass SSAs should be encouraged to undertake further assessment work to refine the SSAs to take account of local factors.

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APPENDIX A Advice to Local Planning Authorities


A1. ADVICE TO LOCAL PLANNING AUTHORITIES

A1.1 Introduction A typical approach for undertaking a local authority-led study of any of the Strategic Search Areas is set out in the flow chart below and is described in the sections which follow.

Technical Assessment of Strategic Desk -based Initial Meeting Objectives Search Area ( SSA ) with respect to Landscape

Meeting t--------+ developable areas, plus environmental - assessment of ~ constraint review and identify potential SSA and

Wind Farm si tes surrounding area (up to 30 km)

Categorise SSA(s) into 2 - 6 'sub- areas' - based on landform and similar characteristics

Generate sub-areas of visual influence each SSA sub-area

, Determine effect of the developed SSA (by sub-area) on the immediate surrounds and also wider area (as appropriate)

Develop criteria for spatial decision making between the sub-areas within the SSAs ( and between the SSAs ), then prepare decision- support matrix indicating the relative environmental, technical and

landscape performance of the various parts of the SSA(s)

"

Develop policy conclusions and recommendations

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The purpose of the local planning exercise is to achieve a finer grain of development allocation within the SSA, taking into account landscape, visual and cumulative impacts. It is not intended for use in the negotiation of the SSA capacities indicated in the Final TAN 8; since this would risk the achievement of renewable energy target delivery.

It is anticipated, however, that the Final TAN 8 will allow the local planning authorities to make minor adjustments to the SSA boundaries when translated into their local planning documents. This will facilitate the inclusion of development on the margins of SSAs where local conditions recommend.

A1.2 Study Area Visual/landscape and cumulative issues

An overall study area of some 40km radius, from the centre of each SSA is recommended, to allow consideration of cumulative landscape and visual issues associated with development in the SSA and existing or proposed wind turbines in the wider area.

Technically feasible areas

An overall study area of some 5km radius from the margins of each SSA is recommended to allow consideration of technically feasible areas for possible wind turbines.

A1.3 Identify "technically feasible areas" The following factors should typically be reviewed for the study in order to identify "technically feasible areas" for the development of onshore wind energy schemes, broadly in the order outlined below.

Wind speed / topography

Using the NOABL 24 dataset, the distribution of existing wind speeds across the area should be determined. Areas with wind speeds greater or equal to 7ms-l at 35m above ground level should be considered suitable for taking forward for further analysis. It should be noted however that whilst the distribution of such wind speeds is typically the starting point for developers, some flexibility should be allowed as detailed wind resource modelling would be undertaken of the SSAs by most developers which inevitably will show slightly different results to the NOABL data.

A digital terrain model should be used to identify those areas with slopes steeper than 15 degrees; these should be also eliminated.

Proximity to residential dwellings

Using a Geographic information system established for the project, Ordnance Survey Address -point data should be loaded and displayed for the Strategic Area. Address-point allows the display of any dwelling that currently has a postcode. The data should be buffered by 500 (i.e. a 500 m radius drawn). 500m is currently considered a typical separation distance between a wind turbine and residential property to avoid unacceptable noise impacts, however when applied in a rigid manner it can lead to conservative results and so some flexibility is again advised.

24 NOABL -UK Wind Speed Database -Background Information -The data is the result of an air flow model that estimates the effect of topography on wind speed. There is no allowance for the effect of local thermally driven winds such as sea breezes or mountain/valley breezes. The model has a I km square resolution and takes no account of topography on a small scale or local surface roughness (such as tall crops, stone walls, or trees), both of which may have a considerable effect on the wind speed. The data can only be used as a guide and should be followed by on-site measurements for a proper assessment. Each value stored in the database is the estimated average for a I km square at either 10m, 25m or 45m above ground level (agl). Available via www.britishwindenergy.co.uk)

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Cultural Heritage

Digital data representing the locations of scheduled ancient monuments (SAM) should be used. SAMs are represented by point features in the available dataset from Cadw; consultation should therefore be undertaken with the local Archaeological trust if any archaeological features appear to present a particular constraint to anyone site.

Land ownership/Forestry

The extent of land in the holdings of the Forestry Commission (FC) or other landowners should be determined via Ordnance survey data or via consultation. A copy of the Design Management plan for the FC estates in the area could be obtained and opportunities explored for the phasing and development of wind turbines in and around forestry clearance operations. If other information is not available the study should assume only 25-50% at maximum of the afforested areas would be available for wind energy development over the next 5 years due to operation and environmental constraints

Existing wind turbines and consented developments

The locations of existing wind turbines/wind turbines within the study area should be mapped, together with locations of consented developments and those proposals currently within the planning system.

A1.4 Review of environmental and landscape constraints/factors The TAN 8 research and strategic sieve process should have ensured that the SSA is free of a range ofIntemational and National environmental constraints. This next exercise should consider a range of environmental data not considered/considered in detail as part of the TAN 8 research, namely local and ecological factors.

Nature conservation

In liaison with the County Wildlife officer, all statutory and non-statutory nature conservation sites should be mapped (and lor digitised for the area if required). Consultation should be undertaken with Countryside Council for Wales and the RSPB and relevant factors noted.

Landscape character and value

The landscape value of an area is an important criterion in judging its suitability for wind turbines development. It is a factor that applies to a particular area rather than a generic landscape type.

Existing information available on the landscape value within the SSA and its surroundings should be collated and mapped. Consultation should be undertaken with the county landscape officers and any existing LANDMAP information obtained and reviewed. Ifpossible, GIS data for the LANDMAP aspect layers should be mapped. Historic Landscape data from the CADW Registers of Landscapes of Special/Outstanding Interest in Wales should also be obtained and mapped

For each existing LANDMAP aspect or character area the criteria of the influence and presence of other conservation interests such special cultural associations, perceptual landscape characteristics such as tranquillity, wildness, sense of remoteness, scenic beauty and the existence of a consensus about importance, either nationally or locally should be applied. These judgements should be kept separate from the more objective criteria of landscape and visual sensitivity (considered below) to present a more transparent assessment.

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A1.5 Classify areas within the SSA The SSAs should be reviewed for major areas with similar landform characteristics and sub aread accordingly. Between 5 and 10 sub-areas per SSA is likely to be a sensible maximum. Any sub-areas not including a "technically feasible area" could be discounted from further analysis.

A1.6 Cumulative landscape and visual assessment The potential for cumulative landscape and visual effects is recognised as a matter to be included in Environmental Impact Assessment under the terms of the EIA regulations 1999. Consideration of cumulative and synergistic effects is also a requirement under the Strategic Environmental Assessment Directive which is required for development plans.

A cumulative landscape and visual impact assessment (CL VIA) will normally form part of an Environmental Statement for wind turbine proposals. Good practice guidance on how to undertake such as assessments is available (such as a recent publication by Scottish Natural Heritage"). Expertise of such assessments is now also well established amongst developers and their consultants within the UK. However, development-specific assessments are unlikely to consider the effects of a fully developed SSA. In particular:

a) it would be unreasonable for a developer to consider the effects of other wind turbines within those (as yet) undeveloped parts of an SSA and,

b) taken iri isolation, developer-specific CL VIAs are unlikely to provide the objective data to allow the local planning authority to consider which parts of an SSA can best be developed whilst minimising landscape change.

In order that cumulative landscape and visual issues are appropriately assessed, the SSA and its immediate surroundings should be subjected to a more detailed landscape value and visual sensitivity assessment. The assessment should consider all landscape aspect' character areas adjacent (or likely to be influenced by) development in a technically feasible area.

Visibility Analysis

The visibility assessment should be computer based, using a Geographical Information System (GIS) and an Ordnance Survey Digital Elevation model. The analysis should have two several separate but interlinked elements:-

• The relative visibility from outside the SSA of the different sub-areas within the SSA. The inter-visibility of the area within a 20-30km radius should be mapped using a GIS. The visibility information should be prepared for the likely size of wind turbines rather than be undertaken at ground level; wind turbines of a minimum of 110m in height should be assumed. The visibility of existing and consented proposals should also be considered and mapped.

• The identification of landscape and visual sensitive receptors, typically key viewing points from which visibility of wind turbines will be assessed e.g. roads, National Trails, National Parks/ AONBs, areas of settlement, key viewing points or visitor sites. Typically 6 view points would be used, the locations for which would be agreed in conjunction with the appropriate local authority officers.

Landscape and visual sensitivity assessment

A landscape and visual sensitivity assessment should be undertaken of the SSA, its immediate environs and the sub-areas within the SSA. Landscape sensitivity criteria which are particularly relevant to wind turbine development include landform character, scale and

25 Appendix5 -Guidance on the cumulative effect of wind farms (2005 ), Scottish Natural Heritage

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height, skyline character, pattern and grain of landcover, openness/ enclosure, character of vertical elements, manmade features, settlement/circulation patterns, time depth and condition. Some of this should already be in any LANDMAP assessment, but this should be developed further during fieldwork.

Building upon the results of the work above, the results of the visibility analysis should be combined with the boundaries of the aspect areas for the landscape assessment.

A1.7 Overall Analysis and Reporting There are various methods available for bringing together various spatial datasets to arrive at a picture of cumulative constraints and thus areas most suitable for development for wind turbines. These include multi-criteria analysis, whereby each constraint layer is assigned a score, and the scores are added together to arrive at an overall environmental performance. The scores for each environmental layer can also be weighted, to reflect the differing importance of the factors in the decision-making process. Whilst the rigour of multi-criteria analysis is often desirable, it pre-supposes that:

a) all the relevant datasets are available digitally

b) all parties to the decision making agree on any scores/weightings to be used.

It is envisaged that due to the data and resource limitation associated with this study, expert judgement should be used to bring the various factors together.

A matrix should be developed containing details of all the feasible 'sub-areas' within the SSAs. The technical, landscape and environmental performance of each of these sub-areas should be assessed and presented in the matrix. Precise criteria for environmental performance should be developed as part of the study in conjunction with the appropriate local authority officers but could include the landscape sensitivity and the degree to which any likely Sub area of Visual influence from proposals located within such a sub-area would affect sensitive visual receptors.

The areas should be ranked as a result of the matrix analysis.

An example matrix is shown below.

Table A.I -Example summary matrix: environmental performance of SSA Sub-areas

Sub-area Nature Historic Landscape Landscap Visual Visual Overall Overall Potential conservat landscape character e Value." sensitivity [to sensi ti vi ty [to sensitivity capacity/r capacity ion constraint sensitivity settlements sensitive anking constraint /roads etc] landscapes/

recreational receptors]

Sub-area I Sub-area 2 Sub-area 3 Sub-area 4 Sub-area 5 Sub-area 6 Sub-area 6 Sub-area 7 Sub-area 8· Sub-area 9

* Landscape value derived from combined LANDMAP ratings with weighting towards Visual and Sensory scores

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The issue of cumulative effects should also be reviewed and consideration given to the effects upon adjacent local authority areas.

Workshop

It is suggested that a stakeholder workshop should be held to test the findings. The exact attendees to the workshop could be determined in conjunction with the appropriate local authority officers but should extend to different officers within the Council, other key stakeholders plus any consultant team.

Recommendations

Recommendations could be made with respect to:

a) Whether adjustments should be made to the Strategic Search Area boundaries when transposed into the appropriate planning documents

b) Which sub-areas, or partes) of sub-area, within the SSAs should not be developed or should be developed in certain ways, to minimise environmental impact

c) What sorts of indicative policy regime might be appropriate for the Local Development Plan and thus development control.

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APPENDIX B Updated Strategic Search Areas


'40 I

'50 !

"60 !

"70 !

'80 I

'90 I

'10 I

'20 !

'3e !

'40 I

'50 '60 I ,

'70 'BO '90 -'OO '10 '20 '30

10

Suggested Strategic Search Areas for Final TAN 8

16,<):',06-.,or. 1 L2

L 20

OO

'90

'so

'70

'50

'41}

Motorway, Primary Ro"les andl A, Roads

Z2d National P'arifAullilorily

'OO

90

10 20 80 Kilornetrës

70

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4-50 Page BI Ove Arup & Partners Ltd

Issue 28 June 2005

Welsh Assembly Government Facilitating Planning For Renewable Energy in Wales: Meeting the Target. Review of Final Report - Research Contracts 105/2002 and 269/2003

SUGGESTED SSAs fOR FINAL TAN 8 - AREA A CLOCAENOG FOREST ARUP Facilitating Planning For Renewable Energy June 2005 Area 1 of 7

Drott TAN 8 strotegi 00 Area

N6!io nal Pa rk

Local Authority Bo .. ~ndary

.: ~




SUGGESTED SSAs FOR FINAL TAN 8 - AREA B CARNO NORTH ARUP Facilitating Planning For Renewable Energy

June 2005 Area 2 of 7

- strategic Area (Suggested) r"ý

Drai! TAN 8 strErtegic Area lai

~ ~

National Park

) Loc al Author~y Boundary

- ~/i P .• lry~·!:

Boundaries tl) b .... refined by l.oc.n PI,lIlning Authoritic«


Page B3 Ove Arup & Partners Ltd Issue 28 June 2005


SUGGESTED SSAs FOR FINAL TAN 8 - AREA e NEWTOWN SOUTH ARUP Facilitating Planning For Renewable Energy June 2005 Area 3 of 7

~ Dr ati TAN 8 st rategic Are ..

~ National Park a " Local .a,uthorrty Boundary

~ o -- ?,5 I - , ",.---

'. t: f .> ilarfnor Fore,sl ;/

"-.....-- ~ I t

il"c

Boundaries to be refined by Local Planning Aurhoriuc- SCOf1C ((1 iIlCICa:-.C SS,-\ II<I~ been idcnti ficd to the ~l)lIHH~,I,,( and west




SUGGESTED SSAs FOR FINAL TAN 8 - AREA D NANT-Y-MOCH ARUP Facilitating Planning For Renewable Energy June 2005 Area 4 of 7

Dralt rAN 8 strategic Area

~ Nenionel Perk

lWy ~ Local Author~y Bounda ry

'11,,, ~ }. 2.:- 'f:1 ~1

Boundaries 1<J be refilled by Loed PI.mnllll;! Authorities

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SUGGESTED SSAs FOR FINAL TAN 8 - AREA E PONTAD.AWE ARUP Facilitating Planning For Renewable Energy June 2005 Area 5 of 7

Boundaries to h~ refined by l.ocal Planning Authorities Scope to increase S~ ... l1a:-; been identified to tile north-west


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SUGGESTED SSAs FOR FINAL TAN 8 - AREA F COED MORGANNWG ARUP Facititating Planning For Renewable Energy June 2005 Area 6 of 7

Drai! TAN 8 strategic Area

National Park

Local Authority Boundary

, (.1

Boundaries h) be refined by L()cC11 Plilllll!llg Authorities Further consultauon will be necessary with Ni\TS Oil developments proposed at the

southern margi n~ of SSA F

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SUGGESTED SSAs FOR FINAL TAN 8 - AREA G BRECHFA ·FOREST ARUP Facilitating Planning For Renewable Energy June 2005 Area 7 of 7

Draft TAN Ô Str6tegic Area

Local Author~y Bounda ry

Bouudanc- LLI be refilled by Local PI'lIllllllg Authorities SC\)[1": to increase SSA has been identified to the north north-cast

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Research Report to theWelsh Assembly Government

July 2010

Research :Strategic Search Area (SSA)Reassessment and Validation

197

Wales Planning Policy Development Programme

This research was prepared for the Welsh Assembly Government by Ove Arup and Partners

Ove Arup and Partners Ltd4 Pierhead StreetCapital WatersideCardi�CF10 4QP

Tel + 44 029 2047 3727

Tel + 44 029 2047 2277

www.arup.com

Planning DivisonWelsh Assembly GovernmentCardi�CF10 3NQ

Email : [email protected]

Planning web site - www.wales.gov.uk/planning

F1541011© Crown Copyright 2010

Welsh Assembly Government Strategic Search Area Reassessment and ValidationFinal Report

Ove Arup & Partners Ltd Issue June 2010

Contents

Page

Executive Summary i

1 Introduction 1

1.1 Background and Aims 1

1.2 Specific elements of the research 2

1.3 Report Content and Structure 2

2 Methodology and Data Management 3

2.1 Research Methods 3

2.2 Data Management 4

2.3 Research Tasks 6

3 Onshore Wind in Wales 10

3.1 Results 10

3.2 Discussion 11

3.3 Development Control in Local Authorities 11

3.4 Technical Constraints on Forthcoming Developments 12

4 Wind Farm Deployment 13

4.1 Deployment issues 13

4.2 Timelines for Delivery 14

5 Remaining Land Suitable for Wind Farm Development 15

5.1 Overview 15

5.2 Part A: Outstanding land for wind farm development 15

5.3 Part B: Further project constraints and their likely impacts 18

6 Conclusions and Recommendations 22

6.1 Wind Farm Development in Wales 22

6.2 Wind farm deployment timeline 22

6.3 Remaining Areas of Developable Land 23

6.4 Other Opportunities 23


Ove Arup & Partners Ltd Issue June 2010

Appendices

Appendix A Environmental and Technical Constraints – Metadata and Analysis

Appendix B Infrastructure Planning Commission –Role and Impact

Appendix C Constraints Maps

Appendix D Remaining Areas of Outstanding Capacity

Appendix E Project Timelines

Appendix F BWEA Presentation (12th January 2010)

Appendix G Wind Farm Capacity Estimates

Appendix H Wind farm status and locations considered within the study

Appendix I LANDMAP Figures


Page i Ove Arup & Partners LtdIssue June 2010

Executive Summary

Arup were commissioned by the Welsh Assembly Government to undertake a study that would

provide an evidence base to inform a revised planning policy framework for onshore wind

development in and around the Strategic Search Areas (SSA). The study included the compilation of

a database of all wind farms in the planning system (pre-application scoping through to submission),

the development of a comprehensive GIS mapping system of all these projects and a cumulative

project timeline for the deployment of all projects.

A total of 320.75MW installed capacity of onshore wind is currently (March 2010) in operation across

Wales. Of this total, 173.55MW is currently in operation within the study area (i.e. SSAs and 5km

buffer). Proposals for some 2300MW of onshore wind are currently under consideration in and

around the SSAs, almost all since the publication of TAN 8 in July 2005. Of these projects, around

1950MW are located within an SSA and a further 350MW approx. of wind developments are located

within 5km of an SSA.

The study has shown that based on knowledge of current project developments, there appears to be

only the potential for around 300MW of additional development in and around (i.e. up to 5km) the

SSAs. This figure takes into account known environmental and technical constraintsas far as has

been possible to address in this study.

The study has also shown that around 2000MW of cumulative installed capacity should be possible

by 2015-2017 under a best case development scenario from within and around the SSAs based on

those known projects.


Page 1 Ove Arup & Partners LtdIssue June 2010

1 Introduction

1.1 Background and Aims

The UK faces a significant challenge in delivering a secure, affordable low and zero carbon

energy supply. In the short term, the UK must meet a legally binding target of 15% of our

energy consumption from renewable sources by 2020. The UK Renewable Energy Strategy

(RES) anticipates a small contribution from transport fuels and renewable heat which

highlights the importance of understanding and developing the renewable electricity

resource available1. In March 2010, the Assembly Government published ‘A Low Carbon

Revolution - the Welsh Assembly Governments Energy Policy Statement’ which builds on

the 2008 Renewable Energy Route Map. It indicates that Wales has the renewable potential

able to produce at least twice as much electricity from renewable technologies by 2025 –

with about 40% of this from marine wave and tidal, a third from wind, and the rest mainly

from sustianble biomass (including waste, hydropower, and microgeneration.

In 2004, Arup produced a ‘decision support tool’ which identified strategic areas in Wales

capable of accommodating large scale (>25MW) onshore wind farms. In total, 7 Strategic

Search Areas (SSA) were adopted and outlined in Technical Advice Note 8: Planning for

Renewable Energy2 in July 2005, these had a total indicative capacity of 1120MW of

onshore wind to accommodate a flexible target of 800MW proposed by the Welsh Assembly

in contributing to national renewable electricity targets. Prior to the adoption of TAN 8, the

technical basis behind the onshore wind energy aspects of Draft TAN 8 were extensively

reviewed following wide consultation. Recommendations were also aimed towards local

planning authorities (LPA) to undertake further assessment work to refine the SSAs to take

account of local factors (TAN 8 Annex D).

Given the One Wales3 agreement which contains a commitment to review TAN 8; in

October 2009, Arup were commissioned by the Welsh Assembly Government to undertake

a study that would provide an evidence base to inform a revised planning policy framework

for onshore wind development in and around the Strategic Search Areas (SSA).

The study aims were to:

• Accurately monitor current progress towards the TAN 8 onshore wind targets set in

2005;

• Through the implementation of best practice, locate the remaining areas of land suitable

for onshore wind farm development within (and 5km adjacent to)4 each Strategic Search

Area (SSA);

• Define the resource potential of the remaining areas of land for electricity generation

through onshore wind development;

• Introduce a well-structured timeline to successfully develop the SSAs to full capacity,

taking into account wind farm developments currently in operation and those in planning

(pre-application scoping through to submission) as well as the impact of grid connection.

The contents of this report and its appendices represent the view of Arup and are not the

policy of the Welsh Assembly Government.

1 The UK Renewable Energy Strategy, HM Government, 2009 2 Technical Advice Note 8: Renewable Energy, Welsh Assembly Government, 2005 3 One Wales – A Progressive Agenda for the Government of Wales, Welsh Assembly Government , 2007 4 Added to brief following Progress Meeting (8th December 2009)



1.2 Specific elements of the research

As outlined in the original Project Brief, there are five phases to the study.

i. Data collection and assimilation for Geographical Information Systems (GIS) analysis:

(a) Information on existing wind farm developments in Wales;

(b) Environmental constraints data; and

(c) Technical constraints data.

ii. Spatial analysis of environmental and technical constraints adjacent to existing wind farm

developments (operational through to planning).

iii. Digitisation of remaining areas of less constrained land suitable for wind farm

development taking into account a varying range of residential buffers (500m-1000m).

iv. An assessment of the average installed capacity per unit area based on developments in

the planning system (MW/km²).

v. Production of a project development timeline for individual SSAs in order to sufficiently

determine full capacity based on existing wind farm developments.

vi. Production of a project development timeline for all wind farm developments within (and

5km adjacent to) each SSA.

vii. To provide comprehensive list of caveats and assumptions influencing the results of the

study including advice on their likely implications on the remaining areas of identified land

suitable for wind farm development.

1.3 Report Content and Structure

This report describes the findings of the work that has been undertaken on the above

research elements. It forms a key part of the evidence base to inform any changes to the

planning policy framework, however policy development does not form part of this contract.

Whilst the information presented here is appropriate for a strategic level study at the

national scale, it is not a sufficient basis for decisions about individual renewable energy

proposals in Wales and it must not be used as such. Each wind farm application in Wales

must be considered on its merits, including site-specific issues that are not appropriate for

discussion in a national study such as this.

Chapter 2 Considers the three part methodology behind the study

Chapter 3 Reviews the existing status of wind farm project in Wales.

Chapter 4 Considers the delivery and project timescales associated with existing wind

farm projects currently in planning in Wales.

Chapter 5 Identifies and quantifies the remaining areas of developable land as well as

the constraints to the development of this land.

Chapter 6 Highlights the key conclusions and recommendations of the study.



2 Methodology and Data Management

This chapter can be considered in three parts. Firstly, there is a discussion of the methods

used by the researchers in collecting the data which has informed the study. Secondly, this

chapter sets out the different tasks that have been combined to fulfil the aims of the project.

And finally, in combination with Appendix A, this chapter presents the methods and

techniques used to generate and combine all datasets used as part of the study to

cartographically identify and quantify the main results of the study.

2.1 Research Methods

This section briefly explains the methods used to collect the evidence that has informed the

study. The primary results of this study rely upon existing information, and the consultant’s

professional view. It merges datasets from a range of sources in order to draw conclusions

on wind development expected to generate across Wales and what might be possible in

future.

The main research techniques used to inform the study have been:

• Internet research and Literature Review;

• Contact with Local Planning Officers;

• Contact with third party stakeholders;

• Contact with wind farm developers; and

• Consultation workshop presentation with BWEA Cymru Members5.

This section describes these research techniques in more detail.

2.1.1 Review of Existing Literature and Studies

There are many existing policy initiatives and studies which are relevant to the consideration

of onshore wind development in Wales. Together, these documents provide a solid basis

for, and endorsement of, the development of wind farms in Wales:

National Planning Policy

• The Wales Spatial plan (2004) and the Wales Spatial Plan Update (2008);

• Planning Policy Wales (2002);

• Ministerial Interim Planning Policy Statement (MIPPS) Planning for Renewable Energy

(2005);

• Technical Advice Note 8: Planning for Renewable Energy (2005);

• Renewable Energy Route Map for Wales (2008); and

• A Low Carbon Revolution – the Welsh Assembly Government Energy Policy Statement

(2010)

Relevant Technical Studies and Guidance

• TAN 8: Annex D Local Refinement Studies (SSA A to G), Arup (2005-2007);

• Facilitating Planning for Renewable Energy in Wales: Meeting the target, Arup (2005);

• Energy Assessment of TAN 8 Wind Energy Strategic Search Areas, Garrad Hassan

(2005); and

• ETSU-R-97 Noise Guidance for Onshore Wind Farms, DTI Working Group.

5 BWEA became Renewables UK in 2010



2.1.2 Contact with external parties

The following local planning authorities were consulted to obtain information on levels of

developer interest for onshore wind farms. The data requested included proposed site

location/name, installed capacity (MW), state of application, any additional information on

the proposed number of wind turbines, and the name of the agent/developer concerned:

• Powys County Council;

• Carmarthenshire County Council;

• Neath Port Talbot County Borough Council;

• Conwy County Council;

• Denbighshire County Council;

• Ceredigion County Council;

• Rhondda Cynon Taf County Borough Council;

• Bridgend County Borough Council; and

• Swansea City Council.

The following governmental/non-governmental organisations were consulted to obtain up to

date environmental and technical constraints datasets to inform the GIS spatial analysis:

• Ministry of Defence (MoD);

• Forestry Commission Wales (FCW);

• Royal Society for the Protection of Birds (RSPB);

• National Grid;

• British Wind Energy Association (BWEA) Cymru Members;

• Countryside Council for Wales (CCW); and

• Cadw Wales.

2.1.3 BWEA Cymru Members Presentation

Arup delivered a presentation to BWEA Cymru Members on January 12th 2010 in order to:

• Make members aware of the study (for those which had not already been in contact with

Arup);

• Present draft results from the study;

• Determine whether the members generally agreed with the methodology and draft

outcomes of the study; and

• Comment on the major issues which should be considered in taking the study forward

A summary of the main points raised at the presentation as well as a copy of the

PowerPoint presentation can be found in Appendix F.

2.2 Data Management

2.2.1 Developer Interest Late 2009/Early 2010

A developer interest database was compiled by the Welsh Assembly in June 2009. Arup

obtained updates on current application status and any additional information on planned

developments through each of the Local Planning Authorities whose boundaries intersect

any part of an SSA and the 5km region adjacent to each SSA.



Note: 5km buffer to SSAs in Wales. The main text of TAN 8 makes no reference to any

buffer zone around the SSAs. However in Annex D ‘Methodology for Local Planning

Authorities with Strategic Search Areas, paragraph 2.2 indicates for an assessment of

possible technically feasible areas “An overall study area of some 5km radius from the

margins of each SSA is recommended to allow consideration of technically feasible areas

for possible wind turbines”.

The 5km buffer has been used in all seven of the local refinement studies commissioned by

the appropriate local authorities in Wales when revising the nationally published TAN 8

boundaries for use in their plan preparation and development control activities.

Whilst the 5km buffer has no formal status, its use by the local authorities has encouraged

developers to push forward with projects within this distance of the SSAs; especially in

areas where the local authority refinement studies have indicated that there may be

environmental merits in including selected areas currently out with the SSAs,

The majority of the local authority local refinements studies carried out by consultants have

not been given any significant weight in the planning system e.g. by inclusion in

supplementary planning guidance. This study has therefore gathered data on all projects

within 5km of the TAN 8 SSA boundaries, regardless of local refinement exercises.

The data (on current application status and any additional information on planned

developments) was compiled in the form of an updateable spreadsheet and represents the

relative state of planning applications and the potential contribution to national targets.

Information within the spreadsheet can be broken down to identify the total installed

capacity of all developments in Wales for each allocated stage of the planning process. This

information can also be used identify which developments fall within an SSA, within 5km of

an SSA, sites located elsewhere in Wales, sites which do not yet have spatial recognition,

and those sites which have not been included in the study.

The allocated stage of the planning process identified for each development site considered

within the study is broken down as follows:

• Pre-application ad-hoc (undetermined due to early stage of application);

• Pre-application scoping (under the Town and Country Planning Act, 1990);

• Infrastructure Planning Commission (IPC) Pre-application (under the Electricity Act,

1989);

• Application lodged (under the Town and Country Planning Act, 1990, and/or the

Electricity Act, 1989);

• Consented (date provided if known); and

• Operational.

Note: From April 1st 2010, new developments with a capacity greater than 50MW are

subject to consent under the Infrastructure Planning Commission (previously Section 36)

and remain undetermined. A short note on the role of the IPC and the planning process

involved in consenting what are considered Nationally Significant Projects can be found in

Appendix B.

The allocated stage of the planning process identified for each development site not

considered within the study is broken down as follows:

• Refused – Following Appeal (date provided if known);

• Refused – Appeal lodged (under the Town and Country Planning Act, 1990);

• Refused – Withdrawn before appeal; and

• Superseded.



2.2.2 Geographical Information Systems (GIS) Datasets

The development of the GIS used during the study and a detailed description of the way the

data was collated and analysed in the GIS can be found in Appendix A. Arup was

responsible for identifying what factors to consider within the study, mapping each relevant

dataset, and undertaking several pieces of analysis to verify the aims of the study.

Data to inform the study was kindly provided by the Cartographic Unit in the Welsh

Assembly Government and through third party stakeholders as set out in Section 2.1.2.

2.3 Research Tasks

Several different task elements have been combined in order to meet the aims of this study.

Some – such as acknowledging developer interest – have to be considered iteratively, while

others have been undertaken in sequence. As a result, there are three main research tasks

which have been carried out on the SSAs and their 5km buffers, as part of the study:

• Task A – Identifying the remaining areas of developable land;

• Task B – Quantifying the remaining areas of developable land; and

• Task C – Developing project timelines for each SSA+5km buffer.

These are discussed in more detail in this section.

2.3.1 (Task A) Identifying the Remaining Areas of Developable Land

The principal method used for this stage in the study has been a GIS constraints mapping

exercise. Building on previous studies carried out as an evidence base for TAN 8 (and

similar elsewhere in the UK); a series of environmental and technical constraints were

mapped. The constraints were divided into two categories: ‘Absolute’ constraints and

‘Secondary’ constraints.

Absolute Constraints: Are defined as those which, for all intent and purposes (at the all

Wales level), would be likely to prevent large-scale wind energy developments.

Secondary Constraints: Are defined as those which are likely to inhibit the development of

large wind energy developments but for which there is either (a) some variability/uncertainty

in their spatial extent or (b) the possibility to develop within the area concerned but with

appropriate mitigation.

The constraints considered within this study are discussed in further detail in Appendix A.

The GIS constraints model and the two categories of data used to identify areas of

remaining developable land provide a valuable tool for assessing the remaining installed

capacity of Wales for the development of onshore wind in line with current/future targets.

In the same GIS model, the spatial extent (Consultation or Application Boundary) of each

wind farm development in the planning process and/or operational was included. This

information was assembled through Local Planning Authorities and individual Developers

and is available within the public domain. No wind farm development information has

been included within the study that cannot be obtained through public sources.

The methodology to identify the remaining areas of developable land follows two broad

stages (i.e. A1, A2).

A1. The first stage comprises a traditional ‘sieve analyses’ of spatial constraints (both

environmental and technical). These are constraints to the development of onshore

wind energy developments in Wales that are capable of being mapped and are

available digitally for use in a GIS.

To represent Stage 1, a map has been produced for each SSA (and adjacent 5km

zone) that indicates the spatial distribution of cumulative environmental constraints

to large-scale wind energy development in Wales. Each area of developable land

identified by Arup was viewed with the Ordnance Survey 1:25,000 map as a

backdrop. The Stage 1 maps can be found in Appendix C.



Note: Separation Distances

Phase 4 of the tender brief indicates that areas of outstanding capacities identified through

the constraints exercise should be tested against the possible introduction of a policy to

establish minimum separation distances (buffer zones) between the TAN 8 SSAs and

neighbouring settlements. These capacities should be tested against a variety of thresholds

of separation. In-line with best practice at the project level for wind farm development in

Wales, Arup have selected buffer distances of 500m, 600m, 700m, and 1000m, to test the

outstanding capacities against. A 2km residential buffer has not been included as part of the

study, this is because a 2km buffer would rule out the possibility of any further development

within and 5km around the SSAs. This is discussed further in Chapter 6.

A2. The second stage represents a refinement of the relatively unconstrained areas

that emerged from the sieve analysis and are not already recognised development

areas. Experience gained during similar work suggests that any estimates of

unconstrained land area remaining is likely to be an overestimate of the potential

land available, therefore further refinement must be undertaken. The approach

taken for this exercise is set out in Figure 2.1.

To represent Stage 2, a map has been produced for each SSA (and adjacent 5km

zone) that indicates areas of less constrained and undeveloped land for a variety of

residential separation distances. Each area of developable land identified by Arup

was viewed with the Ordnance Survey 1:25,000 map as a backdrop. Any area of

outstanding capacity less than 1km2 has been discounted ( Areas <1km

2 are highly

unlikely to give rise to the ‘large-scale’ wind farm projects anticipated by TAN 8 and

may not lend themselves to any form of commercial development). All maps are

presented in Appendix D.

Note: Grid Connection

The original study for TAN 8, Facilitating Planning for Renewable Energy in Wales: Meeting

the Target, carried out by Arup, broadly considered the limitations of grid connection to the

national electricity transmission network6 and local distribution networks (LDN)

7 in Wales for

wind farm developments. The principal constraints relating to grid connection have been

considered within Section 2.3.3.

Figure 2.1 – Refinement of remaining areas of undeveloped land

6 The National Grid connects North and South Wales to the English network and further afield. There is no National Grid connection directly between North and South Wales. 7 The Local Distribution Network (LDN) transmits power from the National Grid to consumers. This local grid tends to reflect the population density of the area it supplies.



2.3.2 (Task B) Quantifying the Remaining Areas of Developable Land

In order to assist in the quantification of the remaining capacities of each SSA and the

adjacent 5km area, a exercise was undertaken to identify an average installed capacity

(MW) representative of future wind farm developments within Wales.

To determine the average installed capacity of any given spatial area (>1km2) identified as

undeveloped within the study area, up to date information on the installed capacity per unit

area (MW/km2) of current wind farm developments in Wales must be acquired. For this

study, 40 wind farm developments were selected and the installed capacity (MW) per given

area (km2) was calculated.

Note: Wind Turbine Distancing

Wind turbines typically need to be positioned so that the spacing between them represents

a compromise between compactness, which minimises land required, and the need for

adequate separations to lessen energy loss through wind shadowing from upstream

machines. Spacing is typically defined by the rotor diameter spacing for wind farm modelling

i.e. 3 x rotor diameter facing wind, 2 x rotor diameter perpendicular to wind.

With regards to the unit by which the additional areas of outstanding capacity will be

measured, the current TAN 8 onshore wind targets concentrate on installed capacity (MW)

as apposed to energy yield (GWh), therefore the remaining capacity will be presented in the

same format.

2.3.3 (Task C) Project Development Timeline

In line with the tender brief, a timeline representing full capacity development of each SSA -

taking into account all wind farm developments currently in planning has been produced.

For wind farm developments currently in operation, information has been extracted from the

British Wind Energy Association (BWEA)8 website. For wind farm developments currently in

planning, specific dates regarding pre-application scoping reports and planning submissions

have been taken from various sources including Local Authority and developer websites.

Given the varying stages of development and the level of information available for different

projects, a time-based step-by-step approach typically involved in the development of wind

farm site has been assumed:

• Pre-application Environmental Impact Assessment studies and Environmental

Statement preparation and subsequent submittal of application: 1 Year

• Planning consent determination period (Local Authority): This could be 4-18

months depending on response of determining authority and completeness of

application. For those planning applications not yet submitted, 4 months has been

assumed based on a complete application and swift response of the planning authority.

Note: This assumes no public inquiries (singularly or in combination).

Or

• Planning consent determination period (Infrastructure Planning Commission

(IPC) i.e. +50MW):-

IPC Acceptance Stage: 1 month

IPC Pre-examination Stage: 3 months

IPC Examination Stage: 6 months

IPC Decision: 2 months

Note: This is still a new and untested process.

• Discharge of any conditions agreed: 6 months

• Order and delivery of turbines/construction of all turbines and rest of wind farm

infrastructure including grid connection: -

8 http://www.bwea.com/ukwed/operational.asp



Installed Capacity (0-25MW Scheme): 12 months



Installed Capacity (+100MW Scheme): 48 months

Note: Incremental phasing and generation from the larger schemes has been

discounted at this stage; timelines represent the worse-case.

The development of each individual wind farm project within each SSA (and adjacent 5km

zone) will be presented on a timetable which has allocated a time period for each stage of

the development process (as discussed above). In turn, this will identify an estimated date

of operation. Information for each SSA will be combined to present an overview of expected

development in Wales 2010-2020 and beyond.



3 Onshore Wind in Wales

3.1 Results

As discussed in Chapter 3, in order to determine the developer interest across Wales for

development sites located within each SSA and 5km outside of it, a number of sources

(including Local Authorities and Developers) were contacted for information9. Figure 3.1

and Table 3.1 present the results of the exercise. It shows the potentially significant

contribution which may be made by large scale wind farm developments, and additionally

the number of applications in the system.

Through discussions with wind farm developers throughout the study and Arup experience

from the technical design work, one consideration for the installed capacity of existing

schemes at Pre-application Scoping is that this stated project capacity may be lower

following detailed technical studies (including noise, landscape and visual, and cultural

heritage) which can alter the feasible area of development.

Figure 3.1 – Status of wind farm planning applications/interest and wind farms in

operation

Table 3.1 - Status of wind farm planning applications/interest and wind farms in

operation (as of March 2010)

Location Operational Consented Application Lodged

IPC Pre-Application Scoping

Pre-Application Scoping

Pre-Application Ad-hoc

Total

SSA A 21.25 81 27.5 85 0 0 214.75

SSA B 78.95 0 337 120 150 0 685.95

SSA C 0 0 187.7 0 16.1 0 203.8

SSA D 0 0 0 170 0 0 170

SSA E 0 39 77.5 0 48.3 0 164.8

SSA F 21 70.9 36 258 52 10 447.9

SSA G 30 0 0 178 0 0 208

Within 5km of SSA

22.35 13.35 202.3 0 125.9 20 383.9

Rest of Wales 147.2 26.9 2.95 69 17 0 263.05

9 Note: Data requested included – the name of the project, the developer, the number and size of turbines, the installed capacity/potential output of the scheme, the planning status of the scheme, the name of the host authority, and any spatial information (e.g. development boundary) which can be provided.

Welsh Assembly Government Strategic Search Area Reassessment and Validation Final Report

Page 11 Ove Arup & Partners Ltd Issue June 2010

3.2 Discussion

The key conclusions regarding existing developer interest information are highlighted below:

Baseline situation - a total of 320.75MW installed capacity of onshore wind is currently

(March 2010) in operation across Wales. Of this total, 173.55MW is currently in

operation within the study area (i.e. SSAs and 5km buffer);

Forthcoming developments – Proposals for some 2306MW are currently under

consideration in and around the SSAs, almost all since the publication of TAN 8 in July

2005. This is significantly in excess of the 2010 target of 800MW. Of these projects, a

total of 1944MW of wind farm developments (consenting through to pre-application ad-

hoc) are located within an SSA; and a further 362MW of wind farm developments

(consenting through to pre-application ad-hoc) are located within 5km of an SSA.

It should be noted developers have been working together on schemes which are

adjacent to each other in order to prevent cumulative issues, however cumulative

issues, especially noise, landscape and ecological issues, may progressively affect the

planning success of the last schemes to be determined (this is further discussed in

Section 4.4);

Of the forthcoming developments (within the SSAs and 5km around the SSAs), a total of

204MW have been consented, a total of 868MW of wind farm applications have been

lodged but are yet to receive a decision, and a total of 811MW have chosen to submit

their application through the IPC10

;

Developer interest within 5km of the SSAs is fairly substantial (16% of all wind farm

developments), given many of these projects could be argued to be at greater planning

risk under the current policy regime than those within the TAN 8 SSAs; and

Across the rest of Wales, approximately 116MW are currently in the planning system

(consented through to pre-application ad-hoc).

Up to date tables for each wind farm development considered within the study can be found

in Appendix H. This includes a list of developments which were not considered within the

study, and those which could not be located given the early status of development.

From Figure 4.1, it can be seen that there is a skewed distribution of wind farm

developments between the SSAs, in part reflecting the differential areas of the TAN 8 SSAs

as defined. There is a heavy reliance on SSA B (Carno North) and SSA F (Coed

Morgannwg) to deliver approx. 45% of all wind farm developments coming forward.

3.3 Development Control in Local Authorities

As discussed in Section 4.2, 811MW (39%) of forthcoming wind farm projects are submitting

their planning application through the IPC. Therefore, the remaining 1290MW (61%) of

forthcoming wind farm projects (including those which have already been lodged) will

require a decision from the relevant Local Authorities with support from stakeholders and

the Welsh Assembly. A breakdown of within the boundaries of which Local Authorities these

decisions will lie can be found in Table 3.2.

10

A timetable of all IPC Planning Applications can be found at: http://infrastructure.independent.gov.uk/?page_id=202

http://infrastructure.independent.gov.uk/?page_id=202



Table 3.2 – Projects expected to require Local Authority decision

Local Authority No. of

Projects

Installed

Capacity (MW)

% of Forthcoming

Developments (MW)

Conwy County Borough Council 2 77.4 3.5%

Powys County Council 20 915.3 44%

Neath Port Talbot Country Borough

Council 9 167.3 8%

Swansea City Council 1 47.5 2%

Rhondda Cynon Taff County Borough

Council 1 36 1.5%

Carmarthenshire County Council 2 46.8 2%

Total 35 1290 61%

It is evident from Table 3.2 that the majority of expected projects will fall in Powys County

Council and Neath Port Talbot County Borough Council. Both will share approximately 52%

of all wind farm application decisions within and 5kms around SSAs.

3.4 Technical Constraints on Forthcoming Developments

The planning success of forthcoming developments adjacent to each other will sometimes

rely on constructive communication and joint working between developers in order to avoid

any negative cumulative impacts on the surrounding landscape and surrounding receptors

(i.e. residential properties and ecological habitats/species).

From a technical perspective, cumulative noise and wind array loss can have a

detrimental effect on the energy output of a development depending on the location and size

of the wind turbines.

3.4.1 Wind Array Loss

Wind Array Loss refers to the reduction in energy output for a wind farm as a consequence

of another wind farm in close vicinity. Depending on the positioning of each turbine and wind

direction, if two turbines are functioning within the same wind catchment, the efficiency of

one turbine may fall as a result. The study has not considered the individual wind turbine

locations for each wind farm scheme and therefore is not in a position to quantify the impact

of wind array loss between adjacent schemes. Considerable consultation with wind farm

developers controlling the relevant schemes would also be required in order to understand

where array loss may become an issue.

3.4.2 Cumulative Noise

Noise limits should be set relative to the background noise at the nearest noise-sensitive

properties. The limits should reflect the variation in both turbine source noise and

background noise with wind speed. A cumulative assessment considers the impact of noise

from several wind farms to realise the absolute noise limits to local receptors, and if a noise

limit exceedance beyond ETSU-R-97 occurs, controlling turbine noise levels with minimal

impact on energy generation may be suggested. Noise receptors are subject to a maximum

noise limit; noise receptors located between developments are therefore susceptible to a

cumulative exceedance of noise limits without communication between developers.

Therefore, a fair apportionment of noise limits between developments must be agreed in

order for both schemes to successfully reach planning consent.

As with wind array loss, without considerable consultation with wind farm developers, it is

not possible to make a professional judgement on whether cumulative noise considerations

will impact the total installed capacity at forthcoming developments. However, it is clear from

Appendix C that the greatest potential for cumulative noise and wind array issues will occur

in SSA B, C, and D.



4 Wind Farm Deployment

This chapter represents the background context and results of Task C i.e. Project

development timeline. The timescales for delivery of each individual wind farm within the

study area have been estimated, and the short, medium, and long term national delivery

calculated. It should be noted that the remaining areas of developable land have not been

considered within this chapter.

4.1 Deployment issues

4.1.1 Planning

Despite the large number of wind farm projects that appear to be ‘in the planning system’

(i.e. Scoping Stage or Application Submission) at the time of writing this report11, the level of

decision making in recent years has remained low.

As part of TAN 8 Annex D, planning authorities were able to conduct refinement exercises

within each of the SSAs as a means to guide and optimise development within each of the

areas. However, in practice; this has contributed to planning delays whilst these refinement

exercises are carried out as; a) developers have been keen to await refinement outcomes

before submittal of their projects, and b) local authorities have been keen to complete and

endorse the refinement studies prior to determining applications.

There is also strain on planning stakeholders (councils, statutory consultees, and

government) who are targeted to provide advice both to developers in their technical

assessments, local authorities on the screening and planning application process, and

provide evidence at public inquiries. In response to this, the Welsh Assembly Government

has been providing financial resources to local planning authorities over the last two years

for dealing with large wind farm applications (+50MW).

4.1.2 Transport Networks

The quantity and close positioning of wind farm applications across Wales has raised

concerns between stakeholders, members of the public and developers in respect of the

number and frequency of abnormal load transport movements which are required for

simultaneous construction. In particular, the effects of this are likely to be most apparent in

Mid-Wales where majority of projects will await a significant grid reinforcement project (see

below).

Following the BWEA presentation and voluntary information from developers, it is clear that

all parties are working to resolve these concerns including a BWEA Cymru Transport sub-

group, the Welsh Assembly Government, the Mid-Wales Trunk Road Agency, and police

authorities. An assessment tool to manage these impacts has been commissioned in order

for the authorities to determine the scheduling of transport movements12.

4.1.3 Grid Network

In SSAs B, C, and D, the majority of developments (i.e. those which have not been given

consent to connect directly to the Local Distribution Network (LDN)) may be constrained by

the mid-Wales National Grid infrastructure which at present does not contain capacity for

large scale wind developments. Improvements to the grid are due to be ready by 2015 at

the earliest13.

11 Approx. 1950MW (within the SSAs) and 350MW (within 5km of the SSAs)

12 Wind Energy in Wales – State of the Industry (Report by BWEA Cymru), 16

th July 2009

13 New Transmission Line to mid Wales, National Grid, Presentation at BWEA Cymru, July 2009 (www.taplondon.co.uk/bweawales/.../BWEA%20Cymru09%20National%20Grid%20Presentation.pdf)



Those which are due to be connected directly to the LDN include:

• Mynydd Clogau (SSA B);

• Garreg Llwyd (SSA C);

• Llandinam P&L (Extension and Repowering) (SSA C); and

• Tirgwynt (SSA B).

4.1.4 Planning Appeals

Wind farm developments which do not fall under the IPC criteria (i.e. under 50MW), and as

such submit their planning application to a Local Authority, could trigger planning appeals

which could further delay the development process. As discussed in the note on the IPC

(Appendix B), public consultation through the IPC is dealt with separately commissioners

and an oral hearing.

4.2 Timelines for Delivery

A number of assumptions have been made to determine the likely timescales for wind farm

delivery, based on some of the deployment issues described above. In timescale

formulation for each SSA project, it has been assumed that all construction takes place at

the first available opportunity i.e. cumulative transport issues will have been resolved and

are not considered to constrain deployment.

Forecasts for delivery in each SSAs (and 5km surrounding region) can be found in

Appendix E. Figure 4.1 indicates the cumulative installed capacity of wind farm

development within each of the SSAs 2008-2020.

Figure 4.1 – Wind farm development timeline (2008-2020)

Current statistics indicate that since TAN 8 was published in July 2005 approx. 101MW of

installed capacity from onshore wind has been consented in Wales. This does not take into

account refusals, public inquiry, or any uncertainties regarding the IPC planning route.

Beyond 2013, it is anticipated that all applications in the public domain will be operational by

2020, this equates to approx. 2400MW.



5 Remaining Land Suitable for Wind Farm Development

5.1 Overview

The GIS established for this research project, as discussed in Chapter 2 has been utilised

to determine areas of land suitable for wind farm development ( within the SSAs and 5km

buffer ) which are not environmentally or technically constrained and have not yet been

leased to wind farm developers to the best of the study team’s knowledge. The results of

this exercise are summarised in Section 5.2 (Part A) below; supporting figures can be

found in Appendix D.

However including some of the technically or environmentally constrained land as potentially

developable would be misleading due to a number of additional factors which are

considered unmappable, and in many cases, unquantifiable. Discussion and likely impacts

of these caveats can be found in Section 5.3 (Part B) below.

5.2 Part A: Outstanding land for wind farm development

5.2.1 Constraints Mapping

A cumulative assessment of the land take impact of individual absolute technical and

environmental constraints within each SSA and its associated 5km buffer has been

undertaken using a GIS. The blue colour and transparency used to indicate areas with a

single constraint remains consistent throughout; hence darker blue shading indicates a

greater number of constraints are acting on the specific area of land. Conversely, lighter

blue shading signifies the presence of fewer absolute constraints.

Secondary constraints are shown with a blue cross-hatch symbol overlying the absolute

constraint data. White areas are those that remain completely unconstrained with respect to

the constraints defined for the purposes of this exercise.

The results of the constraints exercise for each SSA and 5km buffer are shown in Appendix

C and this represents Part A1 of the analysis. The major land use planning constraint

recognised in the study is the residential buffer (500-1000m). For the purposes of the

constraints mapping exercise, a buffer of 500m has been applied to the figures. The impact

of a larger residential buffer is analysed in Section 5.2.2.

5.2.2 Identification of remaining areas of outstanding capacity

The potentially developable capacity of an SSA for wind farms can be established by

totalling up the number of white ‘less constrained’ and undeveloped areas (>1km2) present

within the SSA and 5km buffer as shown on the constraints maps. The impacts of varying

residential buffers have been considered at this stage and are reflected within the results.

Areas identified as less constrained and undeveloped for each SSA and 5km buffer are

shown in Appendix D. The quantitative results of this exercise are shown in Table 5.1. For

clarity, the numbers of least constrained grid squares within and outside of the SSA have

been counted.

The total land potentially available for further development within all SSAs ranges 64-

192km2. The total land available for further development outside all SSAs but within 5km

ranges 36-107km2. Therefore, in total, 99-299km

2 of land is potentially available for further

wind farm development depending on the residential buffer distance.

Individually, SSAs B, D, and F all contain above 20km2 of land available for further

development with a 1000m residential buffer suggesting real project opportunities. It is clear

however, that for all figures, the majority of the areas of outstanding capacity are extremely

spatially fragmented. One assumption which can be drawn from this is that many of the

preferred areas for development have been taken, those areas left may be subject to local

constraints (e.g. access, landowner issues) or the cumulative effects of developments

already in planning/operation. These issues have been considered in more detail in Section

5.3.



Table 5.1 – Outstanding capacities within each SSA and 5km buffer

Residential

Buffer

Within SSA Outside SSA Total

No. of coherent blocks of least constrained land

Total Land Area (km

2)


Total Land Area (km

2)


Total Land Area (km

2)

SSA A

500m 5 28.27 3 6.94 8 35.21

600m 6 20.54 2 4.79 8 25.33

700m 5 12.61 1 3.15 6 15.76

1000m 2 4.11 1 1.17 3 5.28

SSA B

500m 8 39.71 3 15 11 54.71

600m 8 32.02 3 13.71 11 45.73

700m 7 24.73 2 11.14 9 35.87

1000m 5 10.15 2 8.85 7 19.00

SSA C

500m 4 32.75 6 33.73 10 66.48

600m 6 25.84 5 21.79 11 47.63

700m 4 13.07 4 20.89 8 33.96

1000m 1 2.82 2 11.39 3 14.21

SSA D

500m 3 23.89 4 19.3 7 43.19

600m 3 21.71 3 16.24 6 37.95

700m 3 14.58 3 19.91 6 34.49

1000m 3 17.21 3 9.82 6 27.03

SSA E

500m 3 12.45 3 7.42 6 19.87

600m 4 13.47 2 3.02 6 16.49

700m 3 10.68 1 1.26 4 11.94

1000m 2 5.69 0 0 2 5.69

SSA F

500m 8 45.99 2 13.46 10 59.45

600m 8 41.55 3 12.12 11 53.67

700m 9 36.89 3 10.53 12 47.42

1000m 7 22.23 2 4.4 9 26.63

SSA G

500m 1 9.39 4 11.13 5 20.52

600m 2 7.44 2 5.87 4 13.31

700m 2 5.61 1 1.83 3 7.44

1000m 1 1.29 0 0 1 1.29

Total

500m 32 192 25 107 57 299

600m 37 163 20 78 57 240

700m 33 118 15 69 48 187

1000m 21 64 10 36 31 99

5.2.3 Quantifying the Outstanding Capacities

In deriving the remaining/outstanding capacity totals for each SSA and 5km buffer, the

assumption is made that all potential areas are developed and that each area duly

accommodates the maximum number of turbines achievable (an unlikely scenario in reality).

At this stage a ‘theoretical’ maximum installed capacity for each SSA and 5km buffer at

varying residential buffer distances is presented.

As a rule of thumb, the potential installed capacity of each 1km2 area of less constrained

and undeveloped land is taken as being an 8.5MW/km2. Further justification for this figure is

included in Appendix G. It should be noted that this figure lies towards the upper limit of

average installed capacity per unit area for Welsh wind farms.



In some cases, the installed capacity would be less per unit due to the presence of a range

of site specific constraints which cannot be considered in a study of this scale. Taking into

account the range of theoretical total area (km2) available for further development and the

average installed capacity (MW/km2), the analysis reveals an estimated additional total

capacity range of 843MW-2545WW for all SSAs and 5km buffers. Results for all SSAs and

5km buffers are shown in Table 5.2.

Table 5.2 – Estimated additional capacities (MW) of each SSA and 5km buffer

Residential Buffer

Within Strategic Search Area

Outside Strategic Search Area

Total

Remaining Capacity (MW)



SSA A

500m 240.30 58.99 299.29

600m 174.59 40.72 215.31

700m 107.19 26.78 133.96

1000m 34.94 9.95 44.88

SSA B

500m 337.54 127.50 465.04

600m 272.17 116.54 388.71

700m 210.21 94.69 304.90

1000m 86.28 75.23 161.50

SSA C

500m 278.38 286.71 565.08

600m 219.64 185.22 404.86

700m 111.10 177.57 288.66

1000m 23.97 96.82 120.79

SSA D

500m 203.07 164.05 367.12

600m 184.54 138.04 322.58

700m 123.93 169.24 293.17

1000m 146.29 83.47 229.76

SSA E

500m 105.83 63.07 168.90

600m 114.50 25.67 140.17

700m 90.78 10.71 101.49

1000m 48.37 0.00 48.37

SSA F

500m 390.92 114.41 505.33

600m 353.18 103.02 456.20

700m 313.57 89.51 403.07

1000m 188.96 37.40 226.36

SSA G

500m 79.82 94.61 174.42

600m 63.24 49.90 113.14

700m 47.69 15.56 63.24

1000m 10.97 0.00 10.97

Total

500m 1636 909 2545

600m 1382 659 2041

700m 1004 584 1588

1000m 540 303 843

Further constraints and their likely impacts are discussed further in Section 5.3 which

follows.



5.3 Part B: Further project constraints and their likely impacts

In addition to the strategic environmental and technical constraints analysed to determine

the theoretical outstanding capacities, there are other issues which will undoubtedly have an

influence on the appropriate location and scale of further wind turbine development in and

around the SSAs. This section will look at both the issues which directly impact the

outstanding capacities to determine a more realistic figure, and the indirect issues which will

not influence the outstanding capacities immediately but are issues which should be

considered looking forward.

5.3.1 Further constraints directly influencing outstanding capacity

Table 5.3 outlines the key caveats and assumption which have not been included within the

study to date but are likely to directly impact upon the remaining outstanding capacity

resource.

Table 5.3 – Direct impacts on outstanding capacity

Caveat Comments and Assumptions

Residential

Buffer /

Noise

Assessment

The cumulative/individual effect of noise from wind turbines on residential

properties is a key constraint to wind farm developments. The Welsh Assembly

have made it clear from the brief that a variety of residential buffers must be

considered as part of the study and the results of which can be seen in Table 4.1

and 4.2 on land area and installed capacity.

TAN 8 (2005) Annex D suggests that ‘data should be buffered by 500m….some

flexibility is advised’. At a presentation to BWEA Cymru Members in January 2010,

it was agreed that due to recent public inquiries, the use of larger modern turbines

in developments, and the effects of cumulative noise, 700m should be considered

as a MINIMUM for ‘large-scale’ wind farm developments ( e.g. typically greater

than 25MW ) in this strategic exercise. In some SSAs, given the complications of

existing applications and the potential cumulative impact on outstanding

capacities, 700m still remains an optimistic separation distance but will present the

minimum buffer as part of this study.

700m is not suggested as a new planning criterion or policy for use in

development control or forward planning. Suitable separation distances would

have to be determined on their merits.

Planning

success of

existing and

future

applications

The local planning system has been subject to a large number of applications in

the past 5 years, Developers submitted a total of 24 wind applications in the period

July 2005-July 2009, of which there were 8 refusals (33%)14. Of those refusals, 3

applications (Gorsedd Bran, Hirwaun, and Glyncorrwg) were situated within an

SSA.

Taking into account the current refusal rate, a conservative 25% refusal rate

(upheld at appeal) on all outstanding capacity areas identified will be applied.

This figure assumes that many of the larger schemes, anticipated to submit their

planning applications through the IPC, will be approved.

14 Wind farm refusals: Gorsedd Bran (2009), Merthyr Common (2009), Mynydd James (2009), Blaen Bowi (2009), Hirwaun (2008), Glyncorrwg (2007), Clun Felin (2006), and Rhos Garn (2006). Nant Bach was also refused (2006) but has since altered its design and has been consented, therefore has not been included.



Caveat Comments and Assumptions

Unmappable

Constraints

A number of detailed issues at the local level which are not appropriate to address

individually for a national scale study, but may inhibit development coming forward

at all, or the capacities of projects, are listed below.

• Habitat Regulation Assessments at project scale;

• Protected Species;

• Geology and hydrological features (above and below ground);

• Local wind conditions (e.g. localised turbulence);

• Telecommunications;

• Utilities and services (e.g. gas and electricity mains);

• Shadow flicker;

• Archaeological and cultural heritage features;

• Historic landscapes;

• Transport access for turbine installation;

• Bridleways and public rights of way;

• Landowner refusal to sign development leases;

• LANDMAP15;

• Areas allocated for habitat management; and

• Biodiversity and habitat mosaics especially peat and peaty soils.

In previous studies carried out by Arup16, the impact of these issues has been

assumed to represent a 50% reduction of the theoretical maximum resource. In

the absence of other data this reduction is taken forward as part of the study.

Taking into account the quantifiable reductions as shown in Table 5.3, it is possible to

determine a ‘practical’ scenario for the outstanding capacities identified during the study.

The method of reaching this ‘practical’ scenario is shown in Figure 5.1.

15 LANDMAP (Landscape Assessment and the Decision Making Process) is the adopted methodology for landscape

assessment in Wales. All environmental assessments in Wales are expected to include LANDMAP in their consideration of landscape. Landscape evaluation and capacity plays a significant part in appraising areas for potential new wind farm development. LANDMAP is a GIS based landscape resource where landscape characteristics, qualities and influences on the landscape are recorded and evaluated into a nationally consistent data set. Although LANDMAP is an essential local landscape consideration for wind farm development, it has not been possible to quantify the impact it would have on the remaining areas of outstanding capacity. The super-imposition of LANDMAP Visual and Sensory and habitats aspect data on the remaining areas of land in and around the SSAs is shown in Appendix I. 16 Previous Arup Studies applying the same methodology include: Northern Ireland Renewable Electricity Targets to 2020 (2009), Towards Broad Areas of Renewable Energy Development in the North West (2008), Planning for Renewable Energy in the East of England, and Technical Advice Note 8: Planning for Renewable Energy – Strategic Search Areas (2006/07).



Figure 5.1 – Route to ‘practical’ outstanding capacity scenario

Cumulative issues will be a particularly important limited factor on the availability of project

opportunities on the remaining developable land within the SSAs and 5km of the SSAs. New

projects entering the planning system going forward will have to demonstrate compliance

with acoustic standards taking into account all existing projects either operational,

consented or under determination. There may also be a need for space to remain between

current known projects to allow for ecological mitigation, especially disturbance effects upon

birds.

It is considered therefore that a figure of 595MW is still too high to represent a realistic

residual developable capacity within and around the SSAs. Following a review of the

remaining areas of potentially developable land, it is suggested that only around half of this

land is spatially distributed in a way that lends itself to a series of deliverable projects. Also,

there are some specific factors which may inhibit/reduce development on some of the

remaining land. These are briefly set out in Table 5.4.

Areas identified as less constrained and undeveloped for each SSA and 5km buffer are

shown in Appendix D, and primarily comprise the areas with 1000m buffer (yellow).

Each of the remaining areas has been reviewed to gain an understanding of their

development potential, especially whether there are any other factors which may inhibit

projects coming forward. The size of the remaining areas has also been consdered ie. Is

there likely to be a significant project opportunity available? It is recommended that in the

light of the information presented in Table 5.4, an indicative figure of 300MW represents a

more realistic residual developable capacity within and around the SSAs. 300MW therefore

represents a possible development potential over and above those projects made available

to the study team.

Practical Maximum Outstanding Capacities

595.5MW

Reduction of 25% for anticipated planning application refusals

(Reduction = 198.5MW)

595.5MW

Reduction of 50% due to Unmappable Constraints

(Reduction = 794MW)

794MW

Reduction to reflect 700m MINIMUM Buffer

(Reduction = 957MW)

1588MW

Theoretical Maximum Outstanding Capacity (500m Residential Buffer)

2545MW



Table 5.4 – Factors affecting remaining developable land in and around the SSAs

SSA Commentary

A

• Land around Alwen Reservoir may not be available for development due to

ownership restrictions.

• Cumulative noise may be a significant issue in combination with other projects.

B

• Cumulative noise likely to be significant issue and may rule out some of the

indicative areas.

• One or more areas possibly reserved for habitat management for existing

schemes.

C • Cumulative noise likely to be significant issue and may rule out at least one area.

• Land ownership/title issues may restrict development.

D

• Cumulative noise may be a significant issue in combination with proposed project.

• Plynlimon and areas of LANDMAP visual and sensory outstanding evaluation may

further reduce capacity.

E

• Mineral rights/opencast mining may restrict development.

• Cumulative noise may be a significant issue in combination with existing project.

• Land ownership/title issues particularly in some forestry areas may restrict

development.

F

• Cumulative noise likely to be significant issue and may rule out a number of the

areas.

• Land ownership/title issues particularly in some forestry areas may restrict

development.

G

• Broadcast/telecommunication likely to restrict development.

• Cumulative noise may be a significant issue in combination with proposed

projects.



6 Conclusions and Recommendations

6.1 Wind Farm Development in Wales

In total, based on data gathered for this study, approx. 2500MW installed capacity of

onshore wind could be in operation by 2020 (existing and in planning). However, current

constraints to development including slow planning approval, planning application refusal,

strategic transport restrictions, and slow grid capacity connection could lower this figure

significantly. This figure of 2500MW would assume a 100% planning/IPC approval rate.

Of these projects, a total of 1944MW of wind farm developments (operation through to pre-

application ad-hoc) are located within an SSA; and a further 362MW of wind farm

developments (operation through to pre-application ad-hoc) are located within 5km of an

SSA.

6.2 Wind farm deployment timeline

Current statistics indicate that since TAN 8 was published in July 2005 approx. 101MW of

installed capacity from onshore wind has been consented in Wales. This does not take into

account refusals, public inquiry, or any uncertainties regarding the IPC consent route.

Beyond 2013, it is anticipated that all applications (within the study area) in the public

domain will be operational by 2019. This is shown in Figure 6.1 as the cumulative total.

The recent publication of Wales’s Energy Policy Statement ‘A Low Carbon Revolution’

indicates an aspirational target of 2GW onshore wind to be delivered 2015-2017. This not

only includes commercial scale onshore wind but also smaller schemes identified by criteria

based Local Authority policy, community scale schemes, and brownfield opportunities (this

is further discussed in Section 6.4).

It is clear from Figure 6.1, that this aspirational target is achievable by the later 2017 date.

However, it does assume concurrent construction of wind farms, planning consent for all

schemes (Local Authority, DECC and IPC), on-time delivery of improvement to the National

Grid, and negligible construction/transport delays i.e. it is a best case scenario.

Figure 6.1 – Wind Farm Development Timeline (2008-2020)



Therefore, Figure 6.1 represents the ‘best case’ scenario for commercial scale wind

development in Wales to 2020. However, it does not take into consideration schemes

outside of the SSAs or 5km around the SSAs, therefore there is the possibility of ‘windfall’

outside the study area granted by the IPC or Local Authorities or sites on brownfield land.

6.3 Remaining Areas of Developable Land

Somewhere between 99 and 299km2 of undeveloped land remains in the SSAs and within

5km of the SSAs, depending on the size of the residential buffer used in the analysis. This

could give an installed capacity between 843 and 2545MW.

The study has shown that based on knowledge of current project developments, there

appears to be only the potential for around 300MW of additional development in and around

(i.e. up to 5km) the SSAs. This figure takes into account known environmental and technical

constraintsas far as has been possible to address in this study.

6.4 Other Opportunities

As discussed in Section 6.2, aside from commercial scale wind there are a number of other

opportunities for onshore wind development in Wales which will contribute to the

aspirational 2GW target as presented in the Energy Policy Statement:

• Criteria based schemes: A criteria based ‘toolkit’ for Local Authorities in identifying

opportunities for onshore renewable energy in Wales is due to be published in 2010.

This may well allow technical officers to identify sites capable of delivering 5-25MW of

onshore wind against environmental and technical criteria.

• Brownfield opportunities: The Welsh Assembly is keen to promote further use of

brownfield sites across Wales for onshore wind17.

• Community Scales Schemes: The Energy Saving Trust alongside the Welsh Assembly

Government is providing funding to deliver community scale renewable energy schemes

across Wales, including onshore wind, below the 5MW size. Some 22 projects are

anticipated.

17 Technical Advice Note 8: Renewable Energy, Welsh Assembly Government, 2005

Scale 1/30316

Public rights of way, plynlimon

Centre = 278332 E 287689 N

Date 12/3/2015© Hawlfraint y Goron a hawliau cronfa ddata 2015Arolwg Ordnans 100024419

© Crown copyright and database rights 2015Ordnance Survey 100024419

NID y Map Diffiniol yw’r map hwn sy’n dangos HawliauTramwy Cyhoeddus, a gallai fod mân wallau ynddo.

This map indicating Public Rights of Way is NOTthe Definitive Map and May be open to minor error.

Scale 1/30316

Common land , Pumlumon (red, green & blue)

Centre = 278332 E 287689 N

Date 12/3/2015© Hawlfraint y Goron a hawliau cronfa ddata 2015Arolwg Ordnans 100024419

© Crown copyright and database rights 2015Ordnance Survey 100024419

NID y Map Diffiniol yw’r map hwn sy’n dangos HawliauTramwy Cyhoeddus, a gallai fod mân wallau ynddo.

This map indicating Public Rights of Way is NOTthe Definitive Map and May be open to minor error.

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