SUPPLEMENTARY PLANNING GUIDANCE ON RENEWABLE ENERGY DEVELOPMENTS

Wind Farm Development in the Brechfa Forest Area

Summary of responses received to the Draft Supplementary Planning Guidance

The Supplementary Planning Guidance was published on 17th January 2007, with comments requested by 16th February 2007.

Thirty-two responses were received to the Draft Supplementary Planning Guidance. Responses have been received by email as well as paper letters. Many respondents also commented on the Discussion Paper and Arup Report. A summary of relevant comments and the Council’s comments on them is given below.

A list of respondents and their reference numbers is included at the back of the report.

Abbreviations:

AR Arup Report, as prepared by Ove Arup and Partners Ltd and published October 2006

AS The Arup Study i.e. the process that led to the Arup Report

AWEG All-Wales Energy Group

BFA Brechfa Forest Area, as defined in the DP

CCC Carmarthenshire County Council

CCW Countryside Council for Wales

CPRW Campaign for the Protection of Rural Wales

DP Discussion Paper

DTI Department of Trade and Industry

ES Environmental Statement

FCW Forestry Commission Wales

kV kilovolts (1000 volts)

m metres

MW Megawatt (1,000,000 watts)

PROW Public right of way

RSPB Royal Society for the Protection of Birds

SLA Special Landscape Area, as designated by the UDP, especially Mynydd Llanllwni SLA

SSA Strategic Search Area (from TAN 8)

SPG Supplementary Planning Guidance

TAN 8 Technical Advice Note 8: Planning for Renewable Energy (July 2005)

UDP Carmarthenshire Unitary Development Plan (July 2006)

WAG Wales Assembly Government

Draft SPG - Summary of Responses

Topic Respondent ref Issue CCC Comment

Access

18 Adverse impact of tracks should not be CCC would expect any application to

underestimated - drainage and overall have regard to these issues

environmental and recreational quality

may be significantly affected, including

by attracting off-road motorists

Arup Methodology

12 Given that protection of views from A distinction may be made between

dwellings is not normally a material impacts on a few dwellings and

planning consideration, it does not follow impacts which affect the character

that Arup methodology is correct or of an area, as measured by the

necessary cumulative impact on a large number

of dwellings

Arup Preferred Areas

25 Extremely disappointed to note that the The SPG cross-references to the

SPG currently proposed does not Arup Report and notes that it would a

synthesise with that (Arup) Report to material planning consideration for

provide a basis for guiding large scale applications for major wind farm

wind farm development within the area, development in the BFA. Maps from

but insteads seeks to rely on UDP the Arup Report will be included in

policies the SPG

30 Give stronger guidance to steer The SPG attempts to be realistic in

developers to the Suggested Areas its presentation of development

options

34 These are not minor adjustments to the The areas suggested are where

SSA boundary and are contrary to TAN 8 development which could meet the

advice SSA target would have the least

landscape and visual impact. The

Report indicates that other areas

may still be acceptable in landscape

and visual terms

9 Recommends that the Arup Report map Maps from the Arup Report will be

showing the four suggested areas for wind included in the SPG, along with

farm development be included in the SPG references to the published Arup

Report where appropriate

Arup Report

12 States that as the Arup Report was limited Disagree. Technically suitable areas

in scope to primarily a landscape and for major wind farm development

visual assessment, it did not assess were identified, in accordance with

whether areas were technically feasible Annex D of TAN 8, prior to the

for development assessment of landscape and visual

impact implications

13 March 2007 Page 1 of 24

Topic Respondent ref Issue CCC Comment

17, 33, 44 Warmly welcomes the overall results of It should be noted that the Arup

the consultants' study, particularly the Report primarily focussed on visual

conclusion that development in any of the impact. Other factors will need to be

eleven zones which are technically assessed before deciding whether a

suitable for major wind farms would be site is acceptable

acceptable

25 No mention as to whether CCC accepts The SPG cross references to the

the findings of the Arup Report is Arup Report where appropriate and

considered a serious omission that will identifies it as a material planning

lead to confusion consideration when considering

relevant applications

34 Greatly concerned that some areas, Background data will be made

including Bryn Llewelyn were excluded available in due course

from the Study, and would welcome

publication of background data to help

assess why areas were excluded

Arup Zones

33 Welcomes the fact that the Blaengwen Noted

project is in a zone ranked sixth out of

seven zones assessed as being

necessary for development in order to

achieve the WAG target for the BFA

Aviation

48 The RAF should be notified to reduce risk The Ministry of Defence is consulted

of accidents involving low-flying aircraft on all wind farm proposals

48 Illuminating turbines at night for safety There is currently no requirement to

would make them very visible light the structures likely to be

proposed in the next few years

Biodiversity

25 The SPG provides an opportunity to This is a matter which should be

promote and identify areas where dealt with in relation to a specific

biodiversity gain can be incorporated into proposal

any development proposal

43 Noise would unacceptably disturb peace Disagree

and tranquillity

13 March 2007 Page 2 of 24

Topic Respondent ref Issue CCC Comment

45 The CCW Phase One Habitat Survey is Noted

now 15 years old and not entirely accurate

46 Brechfa Forest will lose its owl population Disagree

46 A wind farm will not help wildlife Noted

48 Turbines kill birds, as indicated by Noted

reduction in eagle population in part of

Norway.

Common Land

18 Requests clarification of the reference to CCC may not always have the final

common land management changes, say on planning decisions and it is

given that development on common land appropriate to identify such

is to be resisted management as a relevant issue

33 Agrees with the importance of protecting Support welcomed

common land, particularly that with SLAs

45 Burning has been a practice on Mynydd Noted

Llanllwni Commons, much of it

uncontrolled and illegal. Negotiation with

commoners to resolve the issue is

ongoing

Community Benefits

12 SPG fails to refer to the need for This section will be amended in the

community benefits to be relevant to final SPG

planning and to be reasonable

13 March 2007 Page 3 of 24

Topic Respondent ref Issue CCC Comment

25 S.7.5 could be strengthened by repeating The current wording is considered to

TAN 8 advice that "such contributions make this point clearly enough

should not enable permission to be given

to a proposal that would otherwise be

unacceptable in planning terms"

44 Welcomes the fact that CCC would Support welcomed

encourage and facilitate offers of

community benefits in accordance with

UDP Policy GDC33

Consultation

56 Considers public consultation to have Three stages of public consultation

been inadequate between July 2006 and February

2007 have contributed to SPG

preparation. Information has been

freely available via CCC's website.

Notices have been published in a

local newspaper

Energy Policy

41 Wind turbines are inappropriate because This is outside the scope of the BFA

of varying output, difficulties with SPG

electricity distribution, and subsidy

42 Wind turbines are inappropriate This is outside the scope of the BFA

SPG

48 Wind turbines are inappropriate because This is outside the scope of the BFA

of varying output, use of energy- SPG

intensive concrete during construction,

and subsidy

Environmental Assessment

12 Background noise levels should be Noted

assessed in accordance with advice in

ETSU-R-97

12 Objects to ecological impact being Disagree. Where land is proposed to

assessed with regard to environmental be managed to offset visual

enhancement which might be proposed as intrusion it is appropriate that the

it seeks to require inappropriate ecological impact of this is assessed

compensation over and above mitigation

which might properly be required

13 March 2007 Page 4 of 24

Topic Respondent ref Issue CCC Comment

12 Landmap is not a user friendly tool and is Landmap is being developed as an

not suitable for assessing landscape increasingly useful tool, although

sensitivity CCC recognises that other sources

of landscape sensitivity assessment

may be available

12 Scale of assessment of visual impact The SPG will be amended

given in the SPG conflicts with accordingly

professional guidance and is inconsistent

with the recommendation that regard be

had to best practice

16 Concerned that this paragraph is over- Agreed. This will be corrected

simplified and could be misleading

25 Reference could be made to work done by Noted

Scottish Natural Heritage and others as

examples of best practice

25 Given that ES for wind farms in Carms. Agreed. Relevant wording will be

may be referred to as examples of best amended

practice, comments from statutory

consultees should be made available as

well, as there have been a number of

deficiencies in the content of recent ES

Forestry

12 States that 80-90% of the preferred areas The Arup Study recognised this and

suggested in the Arup Report are on assumed a low density of

Forestry Commission land whereas TAN 8 development to allow for it

suggests that only 25-50% of such land

would be available for development

18 Forestry plantation is dedicated as open The SPG will be amended to refer the

access land and has an inherent open access land status of the

recreational importance, offering unique Forestry Commission estate

opportunities

44 Acknowledges the importance of Noted

protecting those areas managed by

Forestry Commission Wales which are of

ecological and recreational value

13 March 2007 Page 5 of 24

Topic Respondent ref Issue CCC Comment

45 Areas of ancient woodland need to be Agreed

afforded high protection

45 Destruction of existing habitats on WAG- Noted

owned land and contributing to

atmospheric carbon must be avoided as

this would contradict existing WAG

policies

48 Loss of trees from turbine development in Agreed

wooded areas such as Brechfa would lead

to loss of efficient absorbers of carbon

dioxide

General

12 Welcomes CCC's commitment to Support welcomed

monitoring and review

13 Generally happy with the SPG Support welcomed

16 Welcomes SPG as a valuable means to Support welcomed

assist resolution of tensions between

different UDP policies

17 Broadly welcomes the SPG Support welcomed

17 Considers that the SPG would carry little Disagree. Carms. has had significant

weight as the plan which it supplements experience of wind farm

makes no reference to TAN 8 or the MIPPS development, and planning for this,

over many years prior to publication

of TAN 8 and the MIPPS

13 March 2007 Page 6 of 24

Topic Respondent ref Issue CCC Comment

17, 34 Suggests SPG should be published for the This is outside the scope of the

whole of the county to avoid giving the current SPG.UDP policies and

impression that the Brechfa Forest Area is existing wind farms, etc. do not give

the only part of the county suitable for this impression

wind farm development

18 Would prefer the SPG to make more This is outside the scope of the BFA

absolute the unacceptability of large-scale SPG

wind farm developments

18 Suggest that reference be made, following This issue will be considered as part

TAN 8, that the area outside the SSA of LDP preparation

should remain free of large wind power

schemes

18 All factors should be considered in Agreed. CCC would expect any

assessing impact, including grid application to have regard to these

connections, turbines, tracks, borrow-pits, issues

substations, etc.

18 The opportunity to define appropriate The Brechfa Forest Area is identified

criteria for smaller, community-based wind as an area for large scale wind

farms has been missed farms, and smaller schemes are less

likely to be proposed. Other parts of

the county are outside the scope of

the SPG

18 By not clarifying where to limit Noted

applications it may not limit the number of

applications made, which might test the

capacity of the public to respond

18 Disappointed that the SPG is restricted to A wider approach would be outside

the Brechfa Forest Area the scope of the current SPG.UDP

policies and existing wind farms, etc.

do not give this impression

25 Suggestions are made for improving the The layout of the SPG will be

layout of the SPG amended

25 Some minor factual errors are corrected Corrections will be incorporated into

the final SPG

13 March 2007 Page 7 of 24

Topic Respondent ref Issue CCC Comment

33 Welcomes SPG as a valuable means to Support welcomed

assist resolution of tensions between

different UDP policies

34 Welcomes CCC's commitment to Support welcomed

monitoring and reviewing the

effectiveness of the SPG

34 Considers that the SPG would carry little Disagree. Carms. has had significant

weight as the plan which it supplements experience of wind farm

makes no reference to TAN 8 or the MIPPS development, and planning for this,

over many years prior to publication

of TAN 8 and the MIPPS

34 Welcomes CCC's proactive approach in Support welcomed

producing the draft SPG

34 Generally endorse the response made by Noted

BWEA

44 Welcomes CCC's commitment to Support welcomed

monitoring and reviewing the

effectiveness of the SPG

45 Some minor alterations to text suggested These will be included in the final

SPG

58 Support the BWEA response Noted

58 The SPG provides a useful summary of Noted

existing policy guidance although the tone

is somewhat negative and possibly

contrary to the facilitating nature of TAN 8

13 March 2007 Page 8 of 24

Topic Respondent ref Issue CCC Comment

58 The attempt to resolve potential conflict in Support welcomed

advance of a planning application is

welcomed

58 The clarification on the status of the SPG Support welcomed

as a material planning consideration is

most welcome

General Objection

40 Because of the mpact on tourism The general debate on wind farms is

outside the scope of the SPG

consultation

40 Because wind farms are subsidised The general debate on wind farms is

outside the scope of the SPG

consultation

40 Due to increased noise The general debate on wind farms is

outside the scope of the SPG

consultation

40 Due to extreme intrusion on visual The general debate on wind farms is

amenity outside the scope of the SPG

consultation

40 Due to over-optimistic forecasts of power The general debate on wind farms is

output outside the scope of the SPG

consultation

40 Due to the impact on rates The general debate on wind farms is

outside the scope of the SPG

consultation

13 March 2007 Page 9 of 24

Topic Respondent ref Issue CCC Comment

40 Due to variable output The general debate on wind farms is

outside the scope of the SPG

consultation

53, 54 General objection to major wind farm Noted

development in the Brechfa Forest Area

Grid Connection

48 Additional wooden or steel pylons would be Pylons would probably be wooden,

needed, and would further desecrate the rather than steel

landscape

Guidance Area Boundary

56 Consider that any variation to the Disagree

Strategic Search area boundary should be

within the wide hatched lines set by the

Welsh Assembly Government

9, 56 Object to the inclusion of the 5km buffer Noted

area

Health and Safety

46 Impact on health and lifestyle should not Noted

be overlooked

48 It has been claimed that low frequency Noted

noise is intrusive and even detrimental to

health

Hydrology

13 March 2007 Page 10 of 24

Topic Respondent ref Issue CCC Comment

48 Construction of concrete bases might Good construction practice should

affect watercourses and damge wildlife avoid this potential problem

habitat

Introduction

12 Suggest stating that impact on character Noted

and visual impact are only two of a

number of issues to be considered

12 Considers that major wind farm Disagree. TAN 8 refers to significant

development may not have a significant change in landscape character from

impact on character, and that "may" wind turbines in SSAs

should be substituted for "will"

12 Consider that "…. much of the land within Reasons for technical unsuitability

the buffer Area is not technically feasible will be given in the final SPG

…." should be deleted or amended, as

there are unconstrained areas which were

not then assessed

12 Do not consider that CCC is best placed Disagree. CC is capable of

to assess whether locations are examining broad parameters, such

technically suitable for wind farms NOABL wind speed data, contours

and distances from dwellings

16 Concerned that the SPG would run only The SPG has been prepared to

until 2010 accord with the timescale of TAN 8.

16 Concerned at the statement that major TAN 8 refers to a significant change

wind farms will have a significant impact in landscape character from wind

on the character of the area turbine development in and

immediately adjacent to SSA

34 Notes that the UDP plan period runs until The SPG has been prepared to

2016 and considers that the SPG should accord with the timescale of TAN 8.

do the same

13 March 2007 Page 11 of 24

Topic Respondent ref Issue CCC Comment

34 Failure to look beyond 2010 is considered The SPG has been prepared to

na´ve given that a planning application accord with the timescale of TAN 8.

submitted in 2007 would not be operational

until beyond 2010, and that the approach

taken will unfairly exclude many parts of

the Brechfa Forest Area from development

Landscape

11 Notes lack of reference to the European The importance of landscape has

Landscape Convention long been recognised as an important

factor in planning decisions in

Carms.

18 Absolute safeguarding of Mynydd Noted

Llanllwni SLA would contribute to

implementing the European Landscape

Convention

18 Visual and landscape impacts should be Disagree. The importance of

reappraised in the context of the European landscape has long been recognised

Landscape Convention as an important factor in planning

decisions in Carms.

25 Compatibility of wind turbines within the Agreed

Brechfa Forest SSA needs to be drafted

in the context that there is an acceptance

in TAN 8 that there will be landscape

change within and immediately adjacent to

SSAs

41 Wind farms would industrialise and Noted

desecrate beautiful countryside

42 Beautiful countryside should be protected CCC has limited control over the

by the County Council for future beauty of Carmarthenshire's

generations countryside

46 A huge wind farm as far the eye can see Whilst the wind farms would have a

will completely destroy this beautiful significant effect on landscape, they

landscape forever would not destroy it

13 March 2007 Page 12 of 24

Topic Respondent ref Issue CCC Comment

48 Huge height of turbines will dominate the Impact will vary greatly from one

skyline and few will claim they increase skyline to another. Most turbines

the beauty of the Tywi Valley would be at least 10km from the

Tywi Valley

Local community

46 A wind farm will have too huge an impact Noted

for the local community

Locations

11 General objection to major wind farm Noted

development in the Brechfa Forest Area

12 Suggest references to areas and zones Similarly considerations apply to the

and they capacity they could supply, targets identified for SSA by WAG

assuming no unidentified constraints, be

deleted in view of the uncertainty of

unidentified constraints

12 Reference should be made to Agreed. The SPG will be amended

consideration of land within the Buffer Area accordingly

16 Concerned about the identification of no- The SPG does not identify no-go or

go areas and preferred search areas, as preferred search areas

suitability of sites may not be apparent

before detailed environmental

assessment, with a consequent danger

that too little land may be identified for

development

30 Considers that the map forming part of Disagree. Maps and other data

the SPG is confusing and that it would be included in the Arup Report, etc.

better to include a map showing the should be read with the supporting

Suggested Areas text. The SPG map provides a

simple overview of the area to which

the SPG relates

47 Support the implication in the Arup Report The Arup Report referred to areas

that wind farm development in the separated from the main part of the

Llanfynydd area would be inappropriate SSA by the Cothi Valley as being too

small and too dispersed to

contribute to a strategic wind farm

area

13 March 2007 Page 13 of 24

Topic Respondent ref Issue CCC Comment

49, 50, 51 Object to wind farms in the Llanfynydd Noted

area, referring to the Arup Report

implication that land is not suitable

52 Asks why Llanfynydd is still being The Arup Report does not identify all

considered as a potential wind farm potential wind farm sites. It focuses

location when the Arup Report has on the best areas for large wind

indicated that it is not suitable farms

55 Object to wind farms in the Llanfynydd Noted

area

Objectives

17, 33, Welcomes objectives, particularly those Support welcomed

34, 44 for biodiversity enhancement, carbon

storage and enhancement of lanscape

features

Offsetting Principle

12 The Council must act reasonably in Agreed. The SPG will be amended to

seeking to secure environmental benefits emphasise this point

by only requiring these where are

considered necessary to mitigate against

adverse environmental effects

12 Para. 7.1 does not acknowledge that the This circumstance seems higly

careful siting and design of turbines may unlikely in the Brechfa Forest Area,

mean that a proposal does not intrude into particularly given the importance of

panoramic views using the best wind resource

12 Objects to reference to modern, industrial This is a factual statement which

objects in a sparsely-populated and ighlights issues of general concern

relatively wild part of Carmarthenshire, as

it suggests that turbines will appear out of

place and prejudges environmental

assessment

12 Objects to the references to major Disagree. TAN 8 refers to a

landscape and visual impact in para. 7.1 significant change in landscape

on the grounds that impacts may not be character from wind turbine

major, and that environmental development in and immediately

assessment is prejudged adjacent to SSA

13 March 2007 Page 14 of 24

Topic Respondent ref Issue CCC Comment

16 Whilst in principle, the principle is FCW has been consulted throughout

accepted, concerned that new land uses, SPG preparation, but has not

restoration of habitats and other habitat commented on the SPG

management on FCW land might be

difficult to implement due to the

objectives/needs of FCW.

25 Concerned about wording as there will be Agreed. The SPG will be amended

instances where no amount of ecological accordingly

enhancement will offset the visual

damage caused by major wind farms

34 Land management strategies are Agreed. Such strategies would be

something that could be implemented on welcome, although they need not

sites such as the Common land and could necessarily be associated with wind

add significant value both in ecological farm development

and habitat enhancement terms

44 Welcomes the acknowledgement that Support welcomed

ecological impact should be assessed

having regard to site management to

enhance environmental character to

offset visual intrusion in the wider

landscape

Peat

45 Disturbance of peat soils on heath must Noted. This issue should be seen in

be avoided to avoid adverse impact on the wider context of land

stored carbon management generally

47 Advises that common land in the Noted

Llanfynydd area is mainly made up of

peat bog which itself is a significant

reservoir of carbon dioxide

48 If peat is destroyed methane will be Agreed

released and contribute to global warming

Policy

11 Recommend reconsideration and revision Noted

of SPG Purposes

13 March 2007 Page 15 of 24

Topic Respondent ref Issue CCC Comment

11 CPRW had received WAG's "Planning for Disagree.The document is unlikely to

Climate Change" (Consultation Draft -Dec affect WAG policy on onshore wind

'06). No decisions on wind farms in the farms before 2010

Brechfa Forest area should be made until

WAG guidance is known

11 Recommend that SPG will be needed after Much will depend on WAG's approach

2010 to updating TAN 8

11, 47 WAG's "Planning for Climate Change" Disagree.The document is unlikely to

(Consultation Draft -Dec '06) should be affect planning policy on onshore

published before deciding SPG wind farms before 2010

12 Also appropriate to refer to UDP Policy Agreed. The SPG will be amended

UT5 accordingly

12 The increased need for renewable energy Agreed. The SPG will be amended

since the Dyfed SPG was published accordingly

should be recognised

12 Appropriate to acknowledge that Policy The SPG will refer to Policy GDC3

GDC3 recognises that wind farm

development is appropriate in the open

countryside

13 Was looking for a summary which said, All applications will be considered

for example, wind farm developments favourably unless UDP policies, etc.

within the area identified on Map One will indicate otherwise. In the absence

be considered favourably pending of comprehensive environmental

outcome of local environmental assessment CCC does not have

assessment sufficient information to identify

such an area.

17 Welcomes the SPG's role in interpreting Support welcomed

UDP policies CUDP9, CUDP10 and

CUDP14

17, 44 UDP Policy UT5 is a pertinent detailed This policy will be included in the

policy final SPG

13 March 2007 Page 16 of 24

Topic Respondent ref Issue CCC Comment

18 Turbine heights should be less than one Noted

third of the landform

18 A clearer set of locational and design Noted

criteria should be included, adopting a

precautionary approach to design

18 Development should avoid skylines Noted

(protecting views from valleys and

reducing prominence in the long view

18 Visual intrusion should be broken up by Noted

irregular turbine separation and grouping of

turbines

18 Recognises a fundamental conflict Similar conflicts are already

between the UDP and TAN 8 - the UDP embedded in the UDP

Policy UT6 seeks to avert developments

with an adverse impact on the local

environment, whereas TAN 8 accepts that

there will be significant change in

landscape character

18 Residents should be protected from being Noted

surrounded by turbines, e.g. by ensuring

turbines would not appear in a field of

view of 180 degrees or more

25 The SPG provides an opportunity to Guidance on this is given in the UDP

identify areas acceptable for development and the Arup Report. More specific

and to highlight areas where development guidance would require a great deal

should be avoided of environmental and other

assessment for which CCC does not

have appropriate resources

25 Suggests that the SPG should identify the Precise identification of suitable

most appropriate locations within the SSA turbine locations would require a

to locate wind turbines great deal of environmental and

other assessment for which CCC

does not have appropriate resources

33 Welcomes the intention to facilitate Local Support welcomed

Development Plan policy preparation and

to repond to further WAG planning advice

expected around 2010

13 March 2007 Page 17 of 24

Topic Respondent ref Issue CCC Comment

34 Consider that TAN 8, MIPPS and the UDP Wind farm applications will be

should take preference over the SPG assessed against the UDP and other

when assessing the merits of a wind farm material planning considerations.

application The balance struck will depend on the

character of the application

34 Welcomes the SPG's role in interpreting Support welcomed

UDP policies CUDP9, CUDP10 and

CUDP14

44 Welcomes the SPG's role in interpreting Support welcomed

UDP policies CUDP9, CUDP10 and

CUDP14

53 Grouping wind farms together would Noted

reduce the amount of new access roads

and grid connections needed

53 The more spread out wind farms are, the Noted

greater the opportunity for subsequent

infilling with additional turbines

56 Object to changes to UDP which would The SPG does not change UDP

facilitate invasive industrial developments policies

in some of our best open countryside

57 Suggests a closer link in the SPG to Noted

recommendations in the Arup Report

where this would minimise impact

Policy CUDP 10

33 Pleased that CCC recognises the Support welcomed

importance of the Mynydd Llanllwni

commons and Brechfa Forest as

important areas of open space

Policy CUDP 9

13 March 2007 Page 18 of 24

Topic Respondent ref Issue CCC Comment

17 Welcomes CCC's commitment to Support welcomed

protecting Mynydd Llanllwni SLA ancient

woodland and other identified biodiversity

habitats

17, 33, 44 Welcomes CCC's obligation to utilise Support welcomed

management schemes and initiatives as a

tool in meeting conservation objectives

33 Warmly welcomes CCC's commitment to Support welcomed

protecting Mynydd Llanllwni SLA ancient

woodland and other identified biodiversity

habitats

58 Welcomes the safeguarding of natural This will be amended to read "other

environment features listed in 7.2.6 but identified habitats important for

considers that "other identified habitats" is biodiversity

extremely vague

Policy CUDP10

17, 34, 44 Welcomes the requirement to protect Support welcomed

important areas of open space, including

the Mynydd Llanllwni commons and

Forestry Commission land

Policy CUDP14

12 Suggests the SPG expand on Policy General information on wind energy

CUDP 14 and explain the benefits of is readily available elsewhere. The

major wind farm development, or at least SPG focuses on matters particular to

acknowledge those benefits, and the Brechfa Forest Area

recognise that they are important material

considerations in the determination of

applications

Policy EN16

16 Consideration should be given in the SPG The SPG identifies issues which

to development within the SLA would need to be addressed if

development in the SLA is proposed

17, 34 Points out that three operational wind Noted

farms in Wales are found within Areas of

Great Landscape Value, which are

considered to have a higher landscape

value than Carms.' SLAs

13 March 2007 Page 19 of 24

Topic Respondent ref Issue CCC Comment

17, 34 Asks CCC to look beyond the 2010 target CCC will update SPG/draft LDP

and consider areas currently within the policy in tandem with updated advice

SLA, given that 2010 is less than three from WAG

years away and WAG will be producing

further guidance in the meantime

17, 34 Points out that in England reference has Similar advice does not apply in

been made in government planning advice Wales

to phasing out of local landscape

designations

Policy UT6

12 Suggests deleting reference to driver The SPG will be amended

distraction or qualifying the reference accordingly

12 Separation distances between dwellings Estimated noise impact would be one

should be considered in relation to of several factors to be considered

estimated noise impact, in accordance when siting turbines near dwellings

with ETSU-R-97

12 Suggests increasing flexibility in relation Agreed. The final SPG will be

to distance between dwellings to accord amended accordingly

with TAN 8

12 States that visual amenity of residents Noted

may be affected but that this may not

always amount to an impact on residential

amenity

12 The Council cannot properly require grid TAN 8 advises that "developers are

connections to be assessed as they are encouraged to provide details of

outside its control likely routes"

16 Considers the sentence "Residents should The text of the final SPG will be

be protected from the effects of amended

turbines" to potentially cause

scaremongering. Suggests that reference

is made to possible effects, including

noise, shadow flicker and overbearing

appearance

13 March 2007 Page 20 of 24

Topic Respondent ref Issue CCC Comment

16 The sentence "Protection of views from Noted

individual dwellings is not normally a

material planning consideration" is

welcomed

17, 33, 44 Concerned that the SPG reference to Disagree. Significant adverse impact

development which would take place is taken to be an indicator of

without causing demonstrable harm or demonstrable harm

having significant adverse impacts is an

incorrect interpretation of Policy UT 6(i)

53 Would like wind turbines as far away from Noted

dwellings as possible

Procedure

12 Suggests amending the reference to the The SPG will be amended

size of proposed developments to be accordingly

determined under the Electricity Act 1989

25 No reference is made to the preparation The SPG does not amount to a plan

of a Strategic Environmental Assessment or project and therefore these

or Habitat Regulation Assessment, and assessments are not necessary

strongly advise that screening be

undertaken

58 The statement that any s36 application This will be corrected in the final SPG

would be determined by an Inspector is

incorrect

Property Values

42 Concerned about the drop in value of my Changing property values are not

property (in Gwernogle) and assume there material planning considerations,

is some compensation in place although the reasons for them may

be.

48 Property prices in the Brechfa and local Changing property values are not

areas will be reduced and some properties material planning considerations,

may be unsaleable although the reasons for them may

be.

Purposes

13 March 2007 Page 21 of 24

Topic Respondent ref Issue CCC Comment

12 Suggests that "as far as they are able to Disagree. This may be taken as read

within technical limits" is added to the

second purpose

Recreation

12 In some cases, wind farm development Agreed

can improve public access to the

countryside

12 Helpful if the SPG could acknowledge that This will be recognised in the final SPG

wind farms and outdoor recreation can

co-exist without detrimental or adverse

effects

16 Important to state that open access land This will be recognised in the final SPG

would remain open access land if

developed for wind turbines

18 Turbines should be sited at least 500m Disagree. A closer approach may be

from public rights of way valued by some walkers, etc.

18 Changes to the quality of recreation on Noted

open access areas should be recognised

and compensated for, perhaps by creation

of an equivalent area of new open

access land

18 Impacts on recreational amenity might be Noted

offset

18 Refers to the proposed Cistercian Way Noted

and suggests that this should have been

considered in the Arup Study

13 March 2007 Page 22 of 24

Topic Respondent ref Issue CCC Comment

18 Request reference to rights of way as a Agreed. The final SPG will be

material planning consideration amended accordingly

18 The SPG should make specific reference Agreed. The final SPG will be

to open access land amended accordingly

18 The value of recreational walking has been Agreed. The SPG will be amended

under-estimated. in the SPG accordingly

Targets

12 Suggests that the SPG recognise that Noted

shortage of grid capacity in mid-Wales

until after 2010 will increase pressure on

other SSAs to make up the shortfall

12 Lack of grid capacity may mean that The final SPG will be amended in

developments are not able to contribute to recognition of this uncertainty

the 2010 target

12, 17, 33 Disagrees with the interpretation of the The statement will be deleted from

phrase "come forward" and strongly the SPG

suggests that the statement be removed

from the SPG

12, 17, The 90MW target is misquoted as 80MW A correction will be incorporated into

33, 44 the final SPG

16, 44 Disagrees with the interpretation of the Noted

phrase "come forward" and suggests that

the statement is ill advised

13 March 2007 Page 23 of 24

Topic Respondent ref Issue CCC Comment

34 There is a high risk that reliance on Provision of installed onshore wind

development in the Arup Suggested Areas capacity will be monitored by WAG,

will not enable the 90MW target to be which may be expected to update

achieved, and that there are even TAN 8 when appropriate

substantial concerns that the SSA, as

identified in TAN 8 will not accommodate

the proposed target

44 Disagrees with the interpretation of the Noted

phrase "come forward" and suggests that

the statement is ill advised

57 Consider that the reference to a more The statement will be deleted from

"relaxed" target needs explanation the SPG

Tourism

30 Development should be focused to Agreed

minimise long-term impact on landscapes,

especially those valuable for tourism

43 Noise would unacceptably disturb peace Noted

and tranquillity

46 A wind farm will not help tourism Noted

48 The adverse effect on tourism in the Tywi Most turbines would be at least 10km

Valley and the Garden of West Wales is away from the Tywi Valley and its

likely to be considerable and may result in notable gardens

job losses

9 States that the County's finest asset is Noted

the landscape which attracts and will

continue to attract large numbers of

tourists even after other industries have

closed

NB The list below refers to respondents to the Discussion Paper and Arup Report, as well as to the draft SPG

Resp ref Respondent

1 Eco2/Cambrian Renewable Energy

2 Airtricity/Dulas

3 Civil Aviation Authority

4 AWEG

5 Cefn Croes Action Group

6 Glyn Thomas, Rhodri AM

7 Price, Adam AM

8 Douglass, Tina

9 CLAWS

10 Richards, Alan

11 CPRW

12 Gamesa Energy UK

13 DPEnergy

14 National Trust

15 Carms Local Access Forum

16 Npower Renewables

17 BWEA

18 Ramblers Association

19 Llanllwni Community Council

20 Mynydd Llansadwrn Action Group

21 Forestry Commission

23 Smith, James

24 Cambria Archaeology

25 CCW

27 Natural Power

28 Llansadwrn Community Council

29 Renewable Energy Partnerships Ltd

30 Worsley, Dr D

31 Jenkins, Lyn

33 Force 9 Energy

34 RES

35 Jessop, Joanne

36 Energiekontor UK

37 Cadw

38 Royal Society For The Protection Of Birds

39 Llanegwad Community Council

40 Hopkinson

41 Haskell

42 Bradbury

43 Ellis

44 Acciona Energy UK Ltd

45 Senior Ecologist Department for Environment, Planning and

Countryside (WAG)

46 Blackman

47 Rural Pursuits Ltd

48 Pace

49 Martin

50 Thomas

51 Grundy

52 Pierce

53 Wray

54 Percy

55 Davies

56 Dinefwr Green Group

57 Cyngor Sir Ceredigion

58 Scottish Power Renewables

13 March 2007 Page 24 of 24