Radnorshire Wildlife Trust (RWT) is supportive of the principle, intent, and policy objectives set out in relation to Net Zero 2050, for Wales and the UK. Increasing the UK’s production of low-carbon and renewable energy is a key part of achieving these goals, along with other measures such as reducing overall energy demand and increasing energy efficiency.
RWT is a registered environmental Charity, its main objectives can be viewed on the Charity Commission website here.
RWT has responded to the public consultation on the plans put forward for the Nant Mithil Energy Park and its associated infrastructure.
Our primary focus for engagement with any planning application is to protect wildlife and places of interest and value for plants, animals, ecological, geological, or their scientific interest or their natural beauty or landscape value.
Without de-carbonising our sources of heating and energy, the future of plants and wildlife, and the natural beauty and character they give to our landscape, is very bleak.
The difficulty with which RWT is faced, and we would argue with which Radnorshire is faced, started many years ago with a decision to locate very large wind power arrays in remote rural areas far away from the areas which would eventually consume the power generated.
Out of sight of consuming areas should never be out of mind for decision makers, wherever they are located.
And sadly, that appears to have been at the heart of this matter.
We cannot overstate the importance of avoiding these situations in the future, it will make development and deployment cheaper, faster, and much easier.
That initial energy planning framework decision which can be crudely but accurately summarised as “let’s generate energy from large onshore arrays in mid Wales then run pylons through deeply rural counties to distribute the energy to South Wales and England” has set the scene for all the planning difficulties – and all the costs – which have followed.
The resulting costs and difficulties are being borne by local communities and their planning authorities. But costs and difficulties are also being borne by developers who were (as far as they were concerned) given a green light by that original policy.
So in this respect, all parties are, to some extent, victims of a policy which paid too little attention to the foreseeable consequences – especially the needs of transmission infrastructure.
The key to addressing both a future powered by renewables and having communities who will welcome the necessary infrastructure is a policy framework based on having the right technologies, in the right places, deployed at the right scales.
This is not an unreasonable expectation by local communities of industry or of government.
This argues for
a) concentrated effort on reducing demand by making homes and businesses more economical to heat and power, and
b) a capacity mapping as part of a land use framework – urban and rural – making maximum use of existing infrastructure such as roofs for solar before taking up additional agricultural land.
We note the calls made to ‘simply’ relocate the arrays off-shore: but relocating the adverse impacts to different fragile ecosystems and to Red Listed marine species is not the remedy and RWT would be acting irresponsibly if it was to back such calls.
All this might put RWT in a difficult position, as we recognise the need for a decarbonised future, and we welcome policies which will achieve Net Zero, but both must be achieved without damaging protected biodiversity. But both can be, it isn’t such a difficult position.
The challenge is to achieve all three objectives without unacceptable impacts on the natural beauty or landscape value either of our reserves or the wider countryside in which they site.
This is much more difficult due to the size and scale of the proposed infrastructure and the absence of proposed alternative designs which would meet the twin challenges of
a) visual intrusion, and
b) significant earthworks necessary to build the transmission route (undergrounding the transmission cabling potentially makes the extent of ecological impact worse)
A great skill of the private sector is its ability to innovate and adapt to its operating environment.
The operating environment to which Bute Energy and Green Gen Cymru should be required to adapt is one which demands the protection of the biodiversity, fresh water, integrity of peatland, and avoids adverse impacts on the natural beauty and landscape value.
With those as design and siting parameters we would have expected a much more sympathetic proposal to be forthcoming.
RWT responded to the preliminary consultation with Bute Energy and continued to be in dialogue with them about some elements of the design following the submission of the initial Environmental Impact Assessment (EIA) scoping report. As a result of engagement, changes to the original plans resolved RWTs initial concerns in relation to the proposed crossing of the river Wye, which we welcome.
However, as stated in our final response, we continue to have concerns around moorland birds, peat (blanket bog and heathland).
The in combination and cumulative impacts have not, we believe, been fully assessed or addressed to date.
While we are pleased to note that Bute are operating on the principle of an uplift of 20% for habitat mitigation using Biodiversity Net Gain metrics, some of the issues and the potential for damage to peat and moorland birds will remain red lines for us.
We will continue to engage on the impacts on wildlife, habitats and landscape, and are working with colleagues in neighbouring Wildlife Trusts.
We have been engaged in discussions with members, supporters and community groups - as resources allow - to support our responses and decision making.