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;
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.
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:
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.
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.