A Climate Change and Renewable Energy Policy Statement
Mynd i afael â newid yn yr hinsawdd wrth amddiffyn y tirwedd
The Cambrian Mountains have, do, and can further play their part in both;
- mitigating the effects of climate change (via carbon sequestration and natural flood management), and
- making a contribution to Wales’ renewable electricity supply.
Mitigating the effects of climate change (via carbon sequestration).
The Cambrian Mountain’s blanket bogs can make a significant contribution to mitigating the effects of climate change. These hills hold a major portion of Wales’ blanket bogs – ecosystems whose bog mosses, in laying down peat, sequester massive amounts of carbon. With further care of those bogs in good condition and restoration of ones that have become degraded even greater quantities of carbon can be put into store. But it is not only their capacity to reduce atmospheric carbon dioxide levels that is important: through their sustained maintenance, release of the much more potent greenhouse gas, methane, is prevented.
The excavation of foundations for wind farms, the construction of new roads for access by construction and maintenance traffic and the erection of pylons for connecting any new wind farms to the grid would severely damage the ability of the upland bogs and soils to retain carbon already stored in them or to continue to absorb further carbon from the atmosphere.
Renewable electricity supply – hydroelectricity and medium to large scale wind farms
10MW and above (for which permission must be granted by Welsh Government via The Planning Inspectorate)
The Cambrian Mountains currently supply renewably generated electricity from schemes such as;
- Cefn Croes windfarm above Cwmyswth (39 wind turbines with an installed capacity of 58.5MW),
- Cwm Rheidol Hydroelectric Power Station with its 4 ‘runners’ and generators providing 55MW of installed capacity, and
- Llyn Brianne Hydroelectric with 6.4MW installed capacity including the 2021 installation 1.6km downstream of the dam.
The construction of further medium to large wind farms (of over 10MW) across these hills is inappropriate, for landscape, biodiversity, climate resilience, human well-being and infrastructure reasons.
Large scale wind farms placed within the Cambrian Mountains uplands will inevitably disrupt the sense of remote, open spaces which are such a crucial element of this region. It is not possible to reconcile preservation of the landscape as a whole with the intrusion of large individual turbines or large arrays of turbines. Each installation degrades the unique unspoilt appearance and spaciousness of the remaining uplands, thereby diminishing the case for retaining the remainder unpopulated with further turbines. The eventual outcome is likely to be the landscape which is already emerging on the outskirts of the uplands, such as the environs of Llanidloes where, as a result of the cumulative effect of construction of several wind farms it is no longer possible to look at any point on the horizon without a turbine forming part of the vista.
Welsh Government’s February 2021 high level planning document – Future Wales – the National Plan 2040 – appears implicitly to recognise that the Cambrian Mountains should not host any more such large installations. It states:
“We recognise landscapes across Wales whose intrinsic value should be protected from inappropriate development. Sites in National Parks and Areas of Outstanding Natural Beauty are considered unsuitable for large-scale wind and solar.”
As it is widely recognised that the Cambrian Mountains should be included within the family of Welsh Designated Landscapes, they also should be included in this moratorium on large-scale wind and solar schemes within such areas.
None of the ‘Pre-Assessed Areas for Wind Energy’ appear within the Cambrian Mountains. In fact, in ‘Future Wales’ Welsh Government, through Policies 17 and 18, appear to have put in place what is effectively a Strategic Environmental Assessment, the application of which leads inevitably to the conclusion that wind energy is not an appropriate use for the Cambrian Mountains:
- “In Pre‑Assessed Areas for Wind Energy the Welsh Government has already modelled the likely impact on the landscape and has found them to be capable of accommodating development in an acceptable way. There is a presumption in favour of large‑scale wind energy development (including repowering) in these areas, subject to the criteria in policy”;
- The ‘National Natural Resources’ map shows that the Cambrian Mountains are: an “Upland Habitat”, a “biodiversity hotspot” an “ecosystem service hotspot” as well as being part of a “Biodiversity Network”;
- Policy 18, parts 3 & 4:- covering “…….no adverse effects on the integrity of Internationally designated sites…..” and “….no unacceptable adverse impacts on national statutory designated sites for nature conservation….” The Cambrian Mountains include a large number of scientific designated sites including: Special Areas for Conservation, Special Protection Areas, Sites of Special Scientific Interest, and National Nature Reserves. In addition, Cors Caron, a UN RAMSAR site, abuts the boundary of the Cambrian Mountains;
- Policy 18, part 6 stipulates that there be “no unacceptable adverse impacts on statutorily protected built heritage assets.” Scattered across the Cambrian Mountains are numerous built heritage assets, including: many Bronze Age Cairns, Ystrad Fflur (Strata Florida) Medieval Monastery and Craig Goch Dam Valve Tower – part of the Elan Valley Reservoir System;
- Policy 18, part 8 requires that there be “no unacceptable impacts on the operations of defence facilities and operations (including aviation and radar) or the Mid Wales Low Flying Tactical Training Area (TTA‑7T).” Much of the Cambrian Mountains are within TTA-7T.
Given these criteria, there is no justification for further large-scale renewable energy schemes, specifically wind farms, within the Cambrian Mountains.
This conclusion is reinforced by NRW’s “Landmap” – the Geographical Information System which provides evaluations of various aspects of landscape quality across Wales. The prominent hill tops within the three massifs which make up the Cambrian Mountains as a whole each rate highly in the Visual & Sensory layer of the system:
- Pumlumon Fawr, in the Pumlumon range – Visual & Sensory = Outstanding,
- Drygarn Fawr, in the Elenydd Massif – V & S = High,
- Crugia Merched in the Mynydd Mallaen massif – V & S = Outstanding.
For all three of the above hills/massifs the evaluations for the other layers of the GIS (geologic, habitats, and historic) are either Outstanding (8) or High (1).
Biodiversity and climate resilience
The Cambrian Mountains retain a substantial and important degree of biodiversity not found in the rest of Wales. This is largely the result of being so remote as to be less-exploited through human history than more intensively farmed or visited areas. Consequently, the region represents an opportunity to support and increase biodiversity from a higher starting point than areas closer to urban areas. Construction and the action of large numbers of wind turbines would cause undeniable damage to all of the habitats and species of the region, whether or not within the nominal sites of such construction. Further, by disrupting the vital connections between plant and animal habitats, it would result in a more fragmented and therefore less resilient ecosystem overall. To condone such destruction in the name of reducing the climate impact of energy production for ongoing human activity elsewhere, is fundamentally a contradiction in terms.
The physical and mental benefits of time spent outdoors and away from the industrialised environment in which most people live, are well understood. Mental health charity MIND states that time spent outdoors can reduce the risk of depression by 30%. Spaces such as the Cambrian Mountains, where it is easy to lose sight of even the most fleeting traces of human presence, are extremely rare in the crowded island of Great Britain, and their importance all the greater as a result. Open spaces in which the dominance of human industry is unavoidable, however, offer a far shallower sense of connection with nature greater than ourselves, and their impact on well-being is less profound. The construction of 180-200m wind turbines along the hill tops, visible from up to 30 miles away, would severely diminish the value of the whole region for those who come seeking solitude, retreat from social pressures and a reconnection with nature and the planet as something larger and more enduring than ourselves.
What matters is not only what we live by, but what we live for.
Renewable electricity supply – small scale renewable energy schemes
below 10MW (for which permission is granted by Local Planning Authorities)
There may be some opportunity for small scale schemes such as; single medium sized wind turbines, small photovoltaic installations and micro-hydro plants, within the Cambrian Mountains. Each installation must, however, be subject to a full Environmental Impact Assessment (EIA) as part of the planning process. Each EIA should include an appraisal of cumulative impact as, for instance, the erection of several medium sized wind turbines in an area is, in effect, creating a wind turbine landscape.
The Cambrian Mountains Society is of the opinion that by far the greatest contribution that the Cambrian Mountains can make in mitigating the effects of climate change is through the area’s blanket bogs, with their ability to sequester large amounts of carbon. Based on ‘Future Wales’ planning policies (notably P17 & P18) no further large wind farms should be permitted in these hills. The siting of new, small scale renewable energy schemes must be subject to rigorous planning control and the precautionary principle must be adhered to as regards maintaining (or enhancing): landscape quality; wildlife diversity & numbers; habitat quality; as well as historic & cultural buildings together with their settings.
This statement is based on evidence and data derived from either NRW or Welsh Government sources.