Last chance to respond to National Grid Undergrounding consultation

You will be aware that I have not been updating my blog recently.  This is because on 24th May I posted a copy of my response to the National Grid Undergrounding consultation.  I have had many emails which have stated how useful this has been.  Grid having previously said that they would wait for the KEMA report, are now closing the consultation EARLY.  The closing date is the 4th July.  Please read 24th May blogpost for an example of a submission made to Grid.  After 4th July I will start posting regularly again.

Infrastructure, North Wales Power Lines

Today will see a large demonstration at the Assembly concerning the current Tan 8 Windfarm areas, and the associated infrastructure to support those windfarms.  This is going to be an issue in North Wales with additional electricity grid lines proposed which will cross Ynys Mon, Gwynedd, Conwy, Denbighshire and Flintshire.  The Undergrounding Consultation is running at the moment and North Wales residents concerned about a third supergrid line crossing North Wales should respond to that consultation.

I am posting a copy of my response to the consultation here:

Response to National Grid Undergrounding Consultation

This is a response to the National Grid Undergrounding Consultation.

Under Section 38 of the Electricity Act 1989, National Grid has a duty in formulating proposals for new development to:



“have regard to the desirability of preserving natural beauty, of conserving flora, fauna and geological or physiographical features of special interest and of protecting sites, buildings and objects of architectural, historic or archaeological interest; and shall do what [it] reasonably can to mitigate any effect which the proposals would have on the natural beauty of the countryside or on any such flora, fauna, features, sites, buildings or objects.”



It would appear that in many areas, including Snowdonia National Park, the considerations of providing a supply under Section 9 of the Electricity Act - to provide an “efficient co ordinated and economical” supply - are not considered appropriately. Too much weight is being given to Section 9, and insufficient weight is given to the consequences on local communities of the impact of overhead lines by National Grid as well as wider Section 38/Schedule 9 requirements. This can be seen in the recent Beauly Denny Inquiry where only short sections of line were required to be placed underground. This means that the absolute minimum weight was given to the impact on local communities despite over 17,000 people writing in to object to National Grid’s proposals.



In North Wales Tourism is the key industry. It accounts for 8.6% of the Welsh Economy and is the most significant industry from Anglesey in the West and all along the North Wales constituencies to Clwyd South in the East.



The preconditions set by National Grid under its Schedule 9 statement are such that too little regard is given to the wishes of local people in rural areas as well as the wider environmental and business impact at a local level to those affected and whose environment is ruined in order to export electricity to cities within the UK. This is amply demonstrated by the recent submissions from Somerset County Council in respect of proposed connections at Hinkley Point. Complaint is made in these submissions, and indeed those to the Beauly Denny Inquiry, that disclosure by National Grid to local stakeholders of both its reasoning and the detail of its proposal was insufficient. Whilst there may have been disclosure at a late stage, or indeed rectification caused by Stakeholders having to undertake detailed and further enquiries, National Grid’s actions go against the current policy National Grid purports to have.



This is of particular concern to North Wales, which has low density permanent population areas, but high visitor numbers.



There is also the issue of “equality of arms”. National Grid is a monopoly provider with access to huge resources both financial and technical, which local populations have no possibility of being able to match, whatever fundraising takes place. This, together with the fact that affected areas will cover a number of districts, makes it difficult for local people to travel and to deal with the large distances covering the diverse areas that any proposed route will affect.



It is my submission that a far greater balance needs to be given to the section 38/Schedule 9 obligations under the Electricity Act.



The current approach to existing overhead lines extracted from National Grid’s documentation is inserted for ease of reference:



1. Where it can be clearly demonstrated by the promoter that such proposals will

_ directly facilitate a major development or infrastructure project of national importance which has been identified as such by central government; and provide a beneficial step change in the environmental character and quality of the associated area; whilst at the same time not resulting in any unreasonable detriment to the environmental character and quality of the area to which the overhead line is relocated or undergrounded;

and

2. Where National Grid is satisfied that such proposals for relocation or undergrounding will

_ not compromise the security of supply, the reliability and the maximum capability of the high voltage transmission system now or in the foreseeable future; and be technically feasible, fully compliant with National Grid’s current design specifications and achievable in terms of system outages and resources within a timescale that does not adversely affect National Grid’s wider investment programme; and be fully funded by the promoter, who will also be responsible for securing all agreements in principle to allow National Grid to site its equipment on land and acquire any necessary land without the need to resort to compulsory powers.

Undergrounding policy:

Approach to existing overhead lines

* These comprehensive site layout, design and landscaping guidelines provide advice and pragmatic solutions to demonstrate how a creative design approach can minimise the impact of overhead lines. They promote design initiatives which help to retain land values; ensure that new good quality environments are built; that residential densities can be retained; and that the environmental impacts of overhead lines are minimised. They demonstrate that for many developments, overhead lines can be retained in situ without adversely affecting sites’ development potential. For further information visit the Sense of Place website at:

http://www.nationalgrid.com/uk/senseofplace



The above conditions are “and” conditions, namely that they all need to be satisfied before further changes will be considered, rather than “or” conditions, where if some conditions are met, consideration will be given to undergrounding cables. I would urge OFGEM in particular to monitor closely the way in which these conditions have been met, if ever. These are unduly onerous on local communities. It is clear that these stringent conditions will rarely, if ever, be met, and it is submitted that the current requirements as imposed again undermine National Grid’s obligations under Section 38/Schedule 9 of the Electricity Act 1989.



The Councils for the Protection of Rural England and Rural Wales have highlighted in particular the disregard that National Grid have had relative to their obligations in Snowdonia National Park, and indeed other Areas of Outstanding Natural Beauty both in Wales and in England. Over 10% of National Grid’s “overhead” lines are in National Parks or AONBs. I have no doubt that the CPRE and CPRW will raise their own submissions, and to the extent that their submissions relate to the natural environment in general, and North Wales in particular, I adopt their submissions.



Nuclear Safety



It is of considerable concern that in the 20 years from 1972 to 1992 the two high voltage power lines traversing Snowdonia National Park failed simultaneously on at least 6 occasions, cutting off Wylfa Nuclear Power Station from an external power supply. Consequently, a nuclear safety issue arises in relation to both the current Wylfa A and the proposed Wylfa B. The significance of this nuclear safety issue is now clear to see given what is happening to Fukushima after it was cut off from its external power supply.



No doubt National Grid are also aware that Wylfa is situated close to Wales’ most seismically active area, the Menai Straits.



In addition, North Wales is subject to extreme weather events, and it has already been noted that there have been simultaneous double trips on at least 6 occasions in the recent past. These weather events have happened, and no doubt will happen again, particularly as climate change is expected to result in more extreme weather events.



This poses a level of unacceptable risk to the local population. Consequently, the grid connection between Wylfa and the rest of the UK (via either Deeside or Pembrokeshire) should not run on over head wires. Rather, a subsea or underground cable should be a requirement, and not an option, for the entire length of the route.



In this regard, it is notable that a sub-sea cable has been proposed to run from the west of Scotland into Deeside. On Nuclear Safety grounds alone, space at Deeside should be reserved for a subsea cable running from Wylfa, and should be considered an absolute priority.



In summary it is my submission that insufficient regard is given by National Grid to both safety issues, in particular in North Wales, and its environmental obligations under the Electricity Act 1989. It is therefore my submission that the obligations under Section 9 of the Act need to be more appropriately balanced with National Grid’s obligations under Section 38/Schedule 9 to preserve amenity value. Finally, urgent consideration should be given to an underground or subsea cable from Anglesey to Deeside or Pembrokeshire in respect of Wylfa B and new Irish Sea windfarm development.

The Welsh Conservative Manifesto

One of the great things about being a regional candidate is that I go all over North Wales, from Anglesey in the West to Clwyd South and Wrexham in the East.  Each area has strengths and weaknesses, however all the constituencies have some things in common.  Since the creation of the Assembly in Cardiff it has been run by Labour, and let down by Labour.  Plaid has described their Labour counterparts as having a "culture of excuses" I would go further and say that there has been a culture of failure. 

Wales has more children living in severe poverty, its share of manufacturing has fallen by over 11% under Labour, our educational standards have slipped, and there is a funding gap of over £600 per pupil on average in each school, our farmers have "modulation" basically money taken out of their single farm payment, which no other european country does.  Small businesses have been hit by huge rate rises, and council tax has increased as a form of indirect tax because of poor settlements from Labour/Plaids WAG.  Most of all North Wales has been left out of many of the projects and funding, which has been allocated mainly in the South. 

The Welsh Conservatives will have a Minister for North Wales, to make sure that crackpot schemes such as that suggested by Edwina Hart for North Wales patients having to travel for over 6 hours for neurosurgery to South Wales.  The North has been taken for granted by Labour for too long.

Our manifesto was described by David Melding as a "mature programme for government".  You can read it here http://www.welshconservatives.com/.  It offers people in Wales clear choices, and a well thought out and sincere approach to how to tackle the key areas of concern here in North Wales.  All the proposals in the manifesto have been fully costed, and therefore can and could be delivered.  This is what we want to do.

Protect the health budget for the next 4 years against Labour's cuts in Wales, and free Doctors and Nurses to prioritise patient care

Directly fund schools so that head teachers and teachers are able to set their own priorities for right for their own school, in their area.

Encourage the potential of small businesses by taking them out of business rates so that they can take on new staff, or invest in new products.

Protect free bus passes and free prescriptions for older people.

Introduce an Armed Forces card to give benefits such as free bus travel and priority care on the NHS

Promote the use of the Welsh Language with a new charter mark for businesses that encourage its use.

Eliminate child poverty by 2020.

The details are in the manifesto, and reading it will show you that there is a real choice for voters in Wales. People are rightly concerned and worried about the cuts caused by Labours mishandling of the economy and huge debts meaning that we are paying £120 million a day in interest payments.  The longer Labour rules in Wales, the worse the outcomes for Wales will get.  Whatever Labour claims, the bald facts speak for themselves after over a decade of Labour rule in Wales.  It is time for llais newydd dros Gymru, a New Voice for Wales.

Could Fukushima happen at Wylfa?

The events at Fukushima in Japan have been devastating, and on top of the damage and death caused by the tsunami, is the very real prospect of nuclear meltdown at Fukushima.  Chris Huhne has already ordered a review of Nuclear Power stations in Britain, it will be interesting to see what his conclusions concerning Wylfa A will be.  What caused the failure of the systems at Fukushima was loss of Grid connection and power, together with failure of the backup systems.  Loss of power has happened on the 400kw supergrid line which crosses Anglesey via Pentir and Snowdonia National Park 6 times between 1972 and 1992 together with the second 400KW circuit, the loss of Grid power meant that Wylfa had to shut down or reduce its output to local area demand, without Anglesey Aluminium this demand is tiny.  Is there a possibility that a double trip could happen with an adverse weather event and/or earthquake in North Wales? 

This is an extract from the Museum of Wales website

"Where do earthquakes occur in Wales?

There are several long-active fault systems in Wales. Once faults form, they create weak zones in the crust that can be reactivated time and time again. For example, the fault system running parallel to the Menai Strait between Anglesey and Bangor in north Wales are known to have been active over 500 million years ago and have also been the sites of more recent earthquakes.

The Menai Strait area is the most seismically active area in Wales and one of the most active in the UK. The last major earthquake occurred here in 1984, but many others are known from historical records (including 1827, 1842, 1852, 1874, 1879, 1903). Although many events have been recorded in south Wales, from Pembroke to Newport, only the Swansea area shows consistent activity, with significant earthquakes occurring in 1727, 1775, 1832, 1868 and 1906.

Largest earthquake in Wales for 100 years

The 1984, magnitude 5.4, Menai Strait earthquake was the largest onshore UK event for over 100 years. The epicentre was located in northern Llyn, north Wales and the quake originated at a depth of approximately 22 km in the Earth's crust"


The above extract shows that seismic activity in Wales is a real and present concern, the 1984 quake being similar in size to the recent earthquake in New Zealand.  All of this means that there is a very urgent need to consider the risks in the current position at Wylfa, where the double trip of the 400KW Supergrid lines, as has happened 6 times already, could if combined with an earthquake have devastating consequences here in North Wales.  The exposure relates to the double trip on the Grid combined with an event that could knock out the electrical back up systems, with a reactor fault transient.  At present National Grid and Horizon do not seem to be considering a subsea or undergrounding cable from Anglesey into Deeside, with the 2009 ENSG report indicating that they propose to run overhead lines, susceptible to the very real dangers of a double trip which has already happened as the past records show.  This poses an unacceptable risk to the local population in North Wales, who have very real experience of the consequences of Nuclear fallout as a result of the Chernobyl disaster.  It is now that the lessons from Fukushima should be learnt here in the UK, particularly on Anglesey which has known fault line. DECC needs to look with care at the proposals from both Horizon and National Grid to ensure that those risk factors are urgently addressed and consideration given to subsea cable to Deeside, as a matter of nuclear safety.

National Grid Underground Cable Consultation

National Grid are currently running a consultation on their policies relative to running cables underground.  I hope that you will take the time to look at the consultation paper and respond.  The link to the consultation can be found here http://www.nationalgridundergrounding.com/.

Given that North Wales has been selected as a site for a new Nuclear Power Station on Anglesey it is vital that North Wales residents write and give their views on underground cables, particularly given the importance of the tourism and agricultural sector here in North Wales.

Strengthening families, the future of child maintenance

Any MP will know that a large part of their constituency mailbox will be problems associated with the CSA.  This organisation has been failing children and families for a long time.  Currently there are extensive problems with the IT system which upgrades have not solved.  The current consultation by the DWP provides an opportunity for single parents to have a say in shaping the future of the CSA.  The consultation paper can be found here
 http://www.dwp.gov.uk/docs/strengthening-families.pdf.

Whilst I am broadly in agreement with the aims of the Green Paper which wishes to strengthen the ability of families to make their own arrangements.  I am concerned that there appears to be little legal redress proposed to "back up" the arrangements made between parents.  One of the many failures of the last Labour Government was its failure to act upon the Law Commission report number 307 which outlined the problems caused by failing to give legal protection to those who are cohabiting.  For the full report see http://www.lawcom.gov.uk/docs/lc307.pdf.

If real meaningful action is to be taken, then it is vital that the gaps identified by the Law Commission are acted upon.  To fail to do so will have the consequence that many families and children will continue to suffer from inequality causing a rise in dependence on the state.

At present Gingerbread the lone parent charity are looking for the views of single parents who are dealing with the CSA to join their campaign and have your say click here http://www.gingerbread.org.uk/content.aspx?CategoryID=574.  In particular there is a proposal to charge for collecting child maintenance.  This has the capacity to hit those who can least afford it the hardest, and I shall be working together with Gingerbread and other lone parent organisations to oppose charges for parents with care of their children.


My own experience of the CSA can be described as a "nightmare".  Slow and unaccountable, lengthy failures to take enforcement, rewards those who lie, lacking the appropriate powers for the self employed and those owning their own businesses, with gaping holes in its remit.  I shall be responding to the consultation personally and I would encourage others to do so by the 7th April. 

Sex Offenders Register

Today Theresa May the Home Secretary gave a statement to Parliament on a Supreme Court ruling that those sentenced to 30 months or more, and who are listed on the Sex Offenders Register for life should be allowed to appeal that decision.  May said that "Public Protection must come first" and that the Government were "appalled" at the decision of the Supreme Court and the Government would do the absolute minimum to comply.

On Monday I was at a meeting with Police officers, Forensic Medical Examiners, Paediatricians, Counsellors, Crown Prosecution Service, and Judge Michael Farmer QC to discuss serious sexual offending in North Wales and the impact the SARC Amethyst Centre has made for victims in North Wales.  Once of the concerns expressed by HHJ Farmer QC was the ridiculously low sentences given to sex offenders and in particular those in possession of pornographic images of children.  Many victims of sex offenders are affected for the rest of their lives by the actions of their abusers.  This is a life sentence imposed by an abuser without any appeal for the victim of abuse.

As the SARC conference made clear, although there is an arrest rate of approx 96% by North Wales police, the conviction rate is 46%.  Also highlighted was the fact that only 11% of sexual assaults are actually reported according to information from the British Crime Survey.  I am delighted that the Government is going to tighten 4 loopholes in the Sex Offenders Register to ensure that public protection is a key priority.  The impact in the Court system is likely to be that offenders at risk of a sentence of 30 months or more, are likely to  fight their cases.  The CPS has come a long way in ensuring that victims do not have to go into Court and face their abusers with video link and screens available to victims, and changes in evidence rules which permit previous allegations to rebut defences of "consent" have gone a long way to improve the conviction rate......but there is alot further to go and the steps announced by the Home Secretary today in closing the current loopholes will help protect the public from predatory sex offenders.

High Voltage Power lines.

It would appear that finally Albert Owen MP has raised the question of submarine cables to be considered an option for Wylfa B and the new offshore windfarms that will form part of the Irish Sea development.  This issue has been raised on Anglesey with both me and Paul Williams since November last year.  I contacted National Grid on that point in November.  Where has Albert Owen MP been over the last few months?  Interestingly he has not picked up on the failure of Grid to consider that the Environmental Information Regulations apply to their projects.

The Electricity Networks Strategy Group (which includes National Grid) published a document in 2009 which shows that they are seeking to upgrade the Pentir 275kw line to a 400kw line apparently without any consultation with the local people that it will affect. (see pages 72-80 of the ENSG report.  For a more detailed discussion of Grid issues in Wales see the blogpost from Syniadau. 
http://syniadau--buildinganindependentwales.blogspot.com/2011/02/linking-north-and-south.html

Syniadau also highlights Welsh residents pay between 4 to 10 % HIGHER electricity costs as Wales is considered a net importer of electricity, despite the opposite being true.  How Labour's Welsh Assembly Government has allowed this to happen at a time of spiralling energy costs is beyond me.  Political pressure to force Grid and the Electricity Companies to accept that Wales is a net exporter of electricity could have meant money in the pockets of pensioners, families and businesses accross Wales. 

I find it surprising that Grid are now positioning themselves on the basis of  cost. bearing in mind the paragraph above.  They are running undersea cable from Scotland to Deeside at a cost of £780 million as the post from Syniadau shows.  It is vitally important that North Wales does not accept a second best option.    Why then are Grid not also considering running cable the 64 or so miles from Anglesey to Deeside.  Surely this would be a cheaper option than running cables down to Pembrokshire.

Avoiding disclosure? National Grid and Wylfa B

Recently the Government has indicated that they are reviewing a decision made by the Information Commissioner and the Tribunal about whether or not water companies need to disclose pollution information to members of the public under the Environmental Information Regulations 2004.  These regulations allow the public to access vital environmental information on projects which are likely to affect local people, and which may cause environmental damage in a particular area.  This is of particular interest to North Wales which is going to host the new Wylfa B Nuclear Power station.

National Grid are relying upon the recent Tribunal decision, saying that they have no requirement to provide information under the EIR.  This is rather a surprising decision by them, particularly as they exercise powers of compulsory purchase, and are responsible for providing  electricity grid infrastructure.  National Grid are going to have to provide new grid connections to Anglesey which will either mean submarine cables, or huge electricity pylons marching across swathes of North Wales.  There is supposed to be a "public consultation" on the grid connections required for Wylfa B and the proposed Irish Sea windpower developments.  This was due to happen in Spring of 2011, yet trying to get information about the proposed routes, is proving difficult.  What are National Grid trying to hide, and why are they refusing to comply with the EIR?  Time I think for the Government in its review of the EIR and the Water Companies, to extend their review to National Grid.  If the protections the EU wanted to give EU citizens are to have any meaning then private companies exercising powers which come from the state of "compulsory purchase" and indeed nuclear electricity transmission  need to comply with the EIR. I can not see why citizens of France would be able to access the information - and those in Wales can't.  Tourism is one of the biggest industry sectors in North Wales and it is vital that the public in North Wales have access to proper information prior to and about the environmental impact of decisions by companies such as National Grid who should not seek to avoid their duty to disclose information to any members of the public who request it.  This is particularly important where possible routes include routes through a number of Areas of Outstanding Natural Beauty and indeed Snowdonia National Park.

Lack of Scrutiny in NHS,

It would appear that the Welsh Assembly Government has stopped collecting NHS data in order to avoid answering difficult questions on the NHS in Wales.  This prevents members of the public asking questions under the Freedom of Information Act of those responsible for Health in Wales.  The Labour/Plaid Government would appear to want to limit the ability of the public in Wales to access key information on performance and delivery of services.  This begs the question if Labour/Plaid's Government does not have access to the data, how are they able to make sure that services are being delivered properly to people in Wales? Are they able to see if services are being delivered in a way that provides good patient care?  It also shows that they are not prepared to look at the clinical impact of their political decisions.

Nick Bourne AM has tabled a number of questions, over 50, which have gone unanswered.  Some of these questions have remained unanswered for over 6 months.  More seriously data  has shown massive increases in waiting times is now not being collected.  Waiting times for outpatient treatment has increased by 24,758%, yes that is over twenty four thousand percent, and inpatient treatment waiting times have increased by 4958%.  Now the data is "not available" as it is not being collected centrally.  This needs explanation, not an attempt to brush it under the carpet and hope that noone notices......

This lack of scrutiny is particularly worrying for the public, who should have the ability to know what the actual position is, rather than the Spin that Labour and Plaid would like to put on their health reforms in Wales.

NHS cuts in Wales

The NHS in Wales is under attack from Labour cuts,  £435 million each year for the next three years.  Labour's performance on the NHS in North Wales is dismal, with proposals for neurosurgery patients having to travel to South Wales (an ambulance journey of over 6 hours) rather than be able to receive treatment at the Walton Hospital in Liverpool, this daft plan from Edwina Hart was only pulled after howls of protest.   Why Ms Hart ever thought the idea was a good one was a mystery to me, but might have had something to do with the fact that she didnt want to have to decide between neurosurgery provision at both Cardiff and Swansea.

There is no children's hospital in North Wales, just over the border in England is world class Alder Hay, yet no proper provisions have been made by WAG for cross border health services.  The record of Labour on health is dismal there has been an increase in Managers in the NHS in Wales of 20% in the last 5 years.  Depressingly there has been a decline in the number of nurses, midwives and health Visitors of 24% in the same period.  For those living in England who want to know what a Labour Government would do for the Health Service, you can see it here in Wales: cuts of up to £1 billion over the next three years, underfunded stroke services, hospices with far lower funding than their English counterparts, and an explosion of money being moved from frontline services to management and bureacracy.  Here in North Wales maternity services are under threat at Ysbyty Gwynedd, Glan Clwyd and the Maelor. Recently bed cuts have been announced at Glan Clwyd under the guise of "refurbishment". Ambulance targets have been missed so many times it is a joke.

The Welsh Conservatives are committed to retaining funding for the NHS in Wales, and would increase funding for stroke services and hospices, by introducing prescription charges for those that can afford to pay for them.  Anyone who previously did not have to pay prescription charges, such as pensioners, children, those on benefits, or those with chronic conditions would not have to pay for their prescriptions.

One thing is clear Labour's record on the NHS in Wales has been dreadful for those living in Wales.  There is now an opportunity for change with the upcoming Welsh Assembly elections.  Perhaps this is why Ed Balls wont be drawn on his cuts agenda, Labours approach is there for all to see in Wales.  Even Labour's Shadow Health Minister in England, John Healy MP agrees in a template press release saying "patients in North Wales will start to see local health services go backwards".