Content guidance
Here are some ideas for points you may wish to include in your letter, but most important - keep it personal
Statement:
Opposed to the development of Nant Mithil Energy Park. Radnor Forest is steeped in history. It is one of the most beautiful upland areas in Mid-Wales, with Great Rhos, at 660m, the highest point in Radnorshire. The proposed installation of 31 turbines, up to 220m tall would be seen across much of Wales and into England. This area should not be industrialised, especially for corporate greed. Once it’s done, it’s done.
Deficient Consultation:
Flawed and biased.
Many Bute staff there were inexperienced and ill-informed, with different information from different people.
Insufficient representatives for the numbers attending, many were consultants.
Representatives not fully briefed and often unable to provide satisfactory answers.
Insufficient engagement with concerns raised which gave the impression of a biased presentation, not of a true consultation.
No sign of any senior directors (Millican, George, Lawson), whose absence was considered by many to be rude and off-hand.
No note taking or recording of points raised despite this being a formal consultation. Just told that we had to write in for our views to count.
Impact on Visual Landscape
Turbines over 200m high placed on the highest land in Radnorshire will dominate the landscape and have a devastating impact for miles around (DD1).
The forest offers “stunning views of Cadair Idris and Snowdonia ….the Long Mynd…the Malvern Hills and ….the Brecon Beacons” (NRW). These views will be adversely affected and the reverse views even more so.
Described as “a land of hill farming and great moorlands, steep narrow valleys and hills….”https://naturalresources.wales/days-out/places-to-visit/mid-wales/fishpools/?lang=en . Radnor Forest is an iconic landscape visible from all around.
Turbines so large, placed above and close to local settlements will have a devastating and overwhelming visual impact on communities and individuals (DD17).
Bute’s visualisation pictures not accurate - or are taken behind hedges and houses.
Impact on Tourism
The Heart of Wales Railways Line is said by Visit Wales to take “a scenic, meandering route through the beautiful green hillsides of Powys.” It passes the Pales historic (1717) Quaker Meeting House.
The new (opened 2019) Heart of Wales Trail is a 225km hiking route that “shadows the tracks, wending between stations and through miles of wonderful Welsh countryside.” Bute has provided a visual modelling of its proposed Nant Mithil Energy Park from the Heart of Wales Trail near the Pales (Viewpoint 9) (DD14).
Tourists arriving into Radnorshire along the A44 would be confronted with views of Nant Mithil turbines, then Hendy Wind Farm turbines, plus overhead power lines on wooden poles, becoming pylons at a switching station further down the A 481..
Impact on Residential Visual Amenity
Bute concludes that: “The Proposed Development has not been found to breach the Residential Visual Amenity Threshold from ANY residential property or group of properties” i.e “the Proposed Development will not appear so overbearing, overwhelming, unpleasantly encroaching, inescapably dominant or detrimental to living conditions that the property will become widely regarded as an unpleasant place to live”. Based on their own visualisations this is patently untrue.
Impact on Heritage and Historical Landscape:
Radnor Forest is a former Royal Hunting Ground. It wasn’t covered in trees but was an unenclosed piece of land legally set aside for the Norman Kings to hunt deer. (NRW) https://naturalresources.wales/days-out/places-to-visit/mid-wales/fishpools/?lang=en to destroy this ancient area with industrial-scale wind turbines would be cultural vandalism.
Bronze Age round barrows deliberately sited there around 3,000 years ago, together with ring cairns, prehistoric hut circles shown as distinctive platforms are all present. This development would destroy an ancient landscape thousands of years old.
Pre-Assessed Areas for Wind
These are areas in Wales where Welsh Government has found the landscape “capable of accommodating” wind development “in an acceptable” way. Only about one quarter of the Nant Mithil proposed site, and six of the 30 proposed turbines are within a Pre-Assessed area. Wind farms can be built outside a PAA, but these must meet stricter rules about a variety of unacceptable impacts.
Cumulative effect of planned developments
Bute is planning to build two further energy parks near to proposed Nant Mithil; Bryn Gilwen and Aberedw. Together with Hendy Wind Farm (built but not working), which lies between Nant Mithil and Bryn Gilwern, effectively a giant wind farm of 72 turbines covering 17 square miles would be created. Bute Energy says it has “scoped out” ie not taken into account the cumulative effect of these developments near to the Nant Mithil proposed site in its plans for Nant Mithil because it has not yet submitted a planning application for each of them. Nant Mithil would be a Developments of National Significance (DNS) being over 10MW. DNS planning rules say nearby wind turbines that are “existing, under construction and consented” should be taken into account, as well as those at the planning application stage. It is inconceivable that Bryn Gilwern and Aberedw are not included, as, with Hendy, they are all within 2.5km of each other, and they are proposed by the same developer, Bute Energy, as is Nant Mithil .
Bute Energy also proposes a number of other energy parks within 40km of Nant Mithil.
Ecology/Bio Diversity (non-avian)
The site overlaps a Site of Special Scientific Interest.
According to NRW there are extensive areas of upland habitats at the site. Particularly interesting are dry heath, blanket bog and mosses/liverworts including some rare species. Also, some locally rare plants and typical upland breeding birds. Other habitats include acid grassland, degraded bog, acidic springs, mountain streams and dense bracken. This mixture of habitats is important for much of the wildlife and management of this site should aim to look after these habitats and species as well as those listed above.
Impact on Protected Birds
Many protected birds, some red and amber listed found within 5km of the site. These include Golden Plover and Merlin. Full species list (Ecological and Ornithological Desk Study) is not available to the public.
Impact on Starlings and other target species
Occasional records of six target wintering birds were identified – Golden Plover, Goshawk, Jack Snipe, Peregrine, Red Kite and Snipe (DD16).
A total of seven scheduled birds, including starlings were recorded, each only recorded during one visit over the two year survey. Starlings are on the Environment (Wales) Act Section 7 list of birds of principle importance for maintaining and enhancing biodiversity in Wales. Did the surveyors know about the huge murmurations of tens of thousands of starlings at the Hendy Wind Farm site 2km from the Nant Mithil site?
Did the surveyors even look at the Hendy Wind Farm ecological surveys or any relevant local records during their desk-top study, which is confidential?
What will happen to this famous starling roost if the Hendy or Nant Mithil turbines ever turn?
Impact on Bats
The Nant Mithil proposal site scores 91% of maximum site importance for bats in this area of Wales. This is based on a points system based on the number of different bat species present. All UK bat species are protected by domestic and international legislation. Bute survey in 2022 recorded an average of over 90 bat passes at each detector each night.
Five species are listed as a high collision risk with the turbines. A value of county importance is 45%, regional importance 55% and national importance 70%. The proposed Nant Mithil wind farm scores 91.6%, recording 13 of the 14 bat species found in Mid-Wales. This includes all five of the very rare species Bute believes the very rare five should be removed from the calculation because their activity counts for less than 1% of the total.
Bute plans to prevent collisions by reducing the speed of 11 turbines June to October - which it says could reduce bat casualties by half. But its not just collisions that kills bats. They are also at risk from near-contact barotrauma (lung failure from severe and abrupt pressure change) caused by the spinning blades. Mitigation is questionable.
Hydrology
Nothing done to establish the chemistry of surrounding brooks and ponds.
Nothing on leaching from concrete foundations.
Hydrological disturbance from peat excavation and digging borrow pits not recognised.
No appropriate geological surveys have been done in relation to the proposed borrow pits onsite, or groundwater levels or flowpaths. Therefore, there is no knowledge that the borrow pits will yield the aggregate required, the foundations of each turbine mast can’t be optimized, groundwater levels are unknown and groundwater flowpaths can’t be modelled.
No boreholes have been drilled or test pits dug.
Most baseline surveys are inadequate in terms of their data sets. Bute says this will be covered by a planning condition post-approval, which RE-think considers is not good enough.
Impact on Property Values (NB this is not a planning issue)
No compensation promised by Bute Energy for consequential fall in property values as a result of turbines and pylons. Already anecdotal stories of sales falling through and reduced prices.
Impact on Health and Wellbeing:
Risk of stress and anxiety associated with turbines – mental wellbeing.
Local communities being treated as guinea pigs.
No one knows exactly how such large turbines will affect communities .
Noise – Bute has used an assessment tool called ETSU-R-97, the year of introduction indicated by the name. It is out of date.
Amplitude Modulation – is described as a “regular fluctuation of the sound level associated with the passage of the blades”…. A “swish” or “whoomph” sound which increases wind turbine noise annoyance. Current guidance does not adequately address the adverse impact of this, which is the main reason for wind turbine noise complaints. https://scotlandagainstspin.org/2023/02/report-for-uk-government-a-review-of-noise-guidance-for-onshore-wind-turbines/
Community Benefit:
Bute Group’s lack of connection and long-term interests with Wales (based in Scotland and financed by Danish investment company.
No significant job and wealth creation for Wales.
Lack of clarity over size of community fund but in reality, this is likely to be a relatively small sum per community.
No direct compensation for those severely affected financially or otherwise.
Community benefits coming from a central trust fund, not linked to individual developments, with hand-outs based on a number of headings decreed by Bute Energy.
Relies on continuing contributions by whatever company owns the wind farm at the time of commission – which may then change again several times over the course of the lifetime of the wind farm.
Bute have previously said that benefits would be paid for 40 years but this commitment has been withdrawn.
Who is Bute Energy?
Bute Energy is controlled by one individual – Oliver Millican. It is financed by a company controlled by an offshore Luxembourg venture capital fund. The fund will acquire the energy parks at the start of construction by exercising a call option
The Wales Pension Partnership which includes pension funds from several Welsh Local Authorities, has announced it will invest £68m in the energy parks. However, some members of the WPP Bute fund have raised concerns.