The Wood SY10 8QU Tel: 01691-682213 email: [email protected] Freepost National Grid Mid W Connection [email protected] 9 February 2015 Dear National Grid

Consultation Feedback on Statutory Consultation 18 November 2014 to 9 February 2015

Shropshire North Against Pylons (SNAP) represents many people in North Shropshire who wish to campaign against the imposition of pylons by National Grid’s Mid Connection Project in Shropshire and Powys, which is a project driven by the needs of controversial windfarm proposals in Mid Wales. We set out our consultation responses under the various headings below. Documentation The large amount of information in the PEIR and associated documents (about 1,800 pages and 1.8GB of electronic files) were provided to us only on a USB stick which it turned out did not contain all the documents on the NG website, nor any of the photomontages. There was no sensible index to these documents and it took us well over a day to produce our own catalogue in order to make sense of what documents there were, let alone what information they contained. Unlike or Powys County Council we do not have paid staff to read this huge amount of material so our comments are necessarily selective. As we are able to print only at A4 size, much of the detail in plans and drawings (most of which were produced at A3 and A1 size) was lost at that A4 scale. Several of our members who were not able to obtain one of your USB sticks found difficulty, with their slow internet connections, in downloading files (some unnecessarily large) from your website (again largely unindexed). They were therefore disenfranchised to some considerable extent from being able to participate properly in the consultation process. Criticisms of consultation methods During the course of the consultation process we have become aware of several instances of dissatisfaction with your consultation methods. Independently of any efforts by SNAP, Maesbrook residents felt that your NG consultation had inadequately informed people. Local residents therefore felt it necessary to organise their own public meeting. They carried out a door-to-door leaflet drop which drew many

people to that meeting who were insufficiently aware of the consultation and of the impacts from your proposals. We understand that they have written to you separately as a result. We are aware of the disgruntlement by the British Ironworks Centre with your attitude towards them and of the meeting you had with them on 21 January, which reached no resolution. We are aware of the dissatisfaction of residents at Berghill and Lower Frankton with your ignoral of their earlier suggestions for routing of your proposed line. We are also aware of the reputation NG have earned for themselves, particularly in Montgomeryshire. Glyn Davies, MP for Montgomeryshire, said in a parliamentary debate on 4th February which he secured that he was shocked by NG’s behaviour in Montgomeryshire and north Shropshire and went on to say: “Yes, it has produced glossy leaflets and yes, it has arranged hundreds of local meetings, but it has never listened to anyone. It never had any intention of listening. National Grid is programmed not to listen but to cajole, to persuade and then to enforce its proposals by whatever means possible”. You may not agree with that view but it is a view that has been produced by your own actions and by those of your agents. Statutory and non-statutory consultation Your publicity material has not made it clear to all that your current round of consultation is the only statutory one under Planning Act 2008 sections 42 and 47, which is the one that counts for your eventual proposed application to NID. People are more likely to believe it to be a (non-statutory ‘informal’) consultation just like the previous rounds of consultation, and because of those previous rounds, may have developed ‘consultation fatigue’. In any case the proposals that you originally consulted on, involving ten possible route corridors, have now changed. For instance, you have changed the location of the sub-station near Cefn Coch, and rather than offering a choice of T-pylons or ‘low-height’ lattice pylons along ‘our’ section of the route, the choice was originally between conventional high pylons and undergrounding. Alternative route corridors have also been suggested, particularly to avoid all the static caravans around Llansantffraid, which you originally appeared to be unaware of. For these reasons of ‘changed goalposts’ we believe that these former choices should have been the subject of a statutory consultation rather than of a non-statutory one. Need We question the need to have brought out your PEIR and started this round of consultation when you did. You are aware that there is a widespread view, particularly in Montgomeryshire, that you should at least have waited for the result to be known of the Mid Wales Conjoined Public Inquiry into five windfarms and a 132kV connection before launching the PEIR and this consultation. The Inspector’s report from that CPI was known to be imminent at the time your consultation was launched, and it went to DECC on 8th December. DECC’s decision should be available within about three months, which seems little time to wait in the long time-scale that has already passed since your first announcement to the general public in March 2011.

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The prevailing view was again encapsulated by Glyn Davies in the parliamentary debate on 4th February in which he said: “To finish, I will press the Minister to call on National Grid to suspend the mid-Wales connection project, at least until there are approved wind farms to be connected by it”. Because you have brought out your PEIR and started this round of consultation when you did, the PEIR is a very incomplete document, in some cases with inadequate information on which to make a properly informed decision at this stage. Many people are most concerned about the visual impact and the transport impact of your scheme, yet the photomontage material was very thin compared with the number of viewpoints, and there was no data from the traffic surveys carried out in July 2014, nor any figures shown for total HGV movements. Table 2.1 on page 10 of Vol 2.2 of the PEIR lists the windfarms that have caused you to launch your scheme (there is a view that the mid Wales windfarms and their necessary connection to the grid have always been envisaged as a single scheme, see SNAP submission re Mynydd y Gwynt). As we know, Scottish Power Renewables has decided not to progress any further with Dyfnant Forest (although you say that the associated connection agreement has not yet been withdrawn). What we would like to know is whether your proposals can be scaled back accordingly as windfarms drop out (e.g. also Nant-y-Moch), for instance by allowing for less capacity at the substations, which in turn might allow for lesser connector wires? Alternatively, are your proposals over-engineered by reference just to the windfarms listed in Table 2.1, to the extent that the MWC could accommodate many more windfarms in mid Wales? If so, that fact is not made clear in your need case. Landscape and Visual As noted above, the visual impact on people is one of their chief concerns. Although you believe that viewpoints have been ‘agreed’ with Shropshire Council we understand that they have agreed general principles only, rather than individual viewpoints. Where a property or favourite view would have your ‘line’ imposed upon them we believe you should produce a photomontage to give an indication at least of how that view might change. At the moment there are too few viewpoints, too many inappropriate viewpoints and too few photomontages. We agree with the Maesbrook Residents that you should consult residents of the affected villages about suitable viewpoints so that a more informed opinion might be made about pylon choice; and that you should produce a landscape plan to show how you could mitigate visual impact and should share that with residents. We also question whether your photomontages can be trusted as realistic representations of views. Photomontage 21 (view from Hill) looks particularly suspicious to us. T- pylons are shown as prominently white to the left (catching the sun?) and prominently black to the right whereas the ‘low-height’ L12pylons are not shown like that. The conductor wires on the T-pylons are shown as prominently black to the right but not on the ‘low-height’ L12 pylons (when presumably the same wires are used?). The overall impression is one of artificiality.

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Transport As also noted above, the impact of construction traffic on people is also one of their chief concerns. Transport is what will impact most people first, and possibly most. Because you have not released the data from the traffic counts carried out in July, it is not possible to assess the relative increase that your scheme would cause. Clearly it is likely to be significant, particularly along the single track roads that you need to use to access pylon sites, so generous mitigation should be offered by you. Primary concerns are: congestion on and damage to all roads but particularly single track roads, their verges, and the properties at their side; mud on roads; increased volumes compared to baseline; known inconvenience to regular users of roads to be closed; and associated possible mitigation for all these impacts. You should also provide information on the cumulative effects of your scheme with all the wind farm construction traffic travelling along the A483 through Shropshire, particularly the narrow stretch in the settlements of Pant and Llanymynech. After all, your rationale for pressing on with your project at the pace you are is so as to be ready for the windfarms should they be consented. The congestion that all this construction traffic will cause will inevitably lead to ‘rat-running’ through the network of side roads in north Shropshire. Tourism Tourism is a major part of the economy in north Shropshire and we believe that you are not fully aware of aspects of tourism that will be affected by your proposals. There is a suspicion that some of your work is ‘desk-top’ rather than being based in the field – for instance the documentation for the Scoping Opinion recorded the Montgomeryshire canal north of Marsh as being non-navigable, a gross mistake that we feel may have influenced your original choice of route corridor. We believe that you have not been properly aware of the tourism offer and future potential of the British Ironworks Centre, and have failed to appreciate the visual impact your current scheme would have on them. Similarly, we are aware that there is a belief that you earlier (if not now) completely failed to appreciate the number of static caravan owners and occupiers along the route (particularly around the Llansantffraid and Llanymynech areas) who would be seriously adversely affected by your scheme. That mistake is again thought to have influenced your choice of route corridor, which is partly why we believe that that earlier choice should be re-consulted upon at the statutory consultation phase. Flooding Your scheme passes through areas (indeed in places it seeks them out) that are regularly flooded. Those people with a lifetime of experience of living in such areas are aware that slight differences in local topography make a significant difference to the passage of flood water, which usually acts more like a river than a lake. When the wartime ammunition dumps were built in the area (possibly the last previous such major civil engineering project in that area) one of the side railways had to be blown up shortly afterwards because of the adverse effects it was having on local flooding. There is naturally therefore concern that the huge amounts of concrete and stone that will be laid down for pylon bases, access tracks and haul roads, will increase the risks from Page 4 of 6

flooding, particularly when their likely effects have been assessed on a desk-top basis by people without direct experience of local conditions. Pylon types We believe that the information you have provided in the consultation material is insufficient for an informed decision to be made about pylon types. For instance, on the subject of T-pylons, page 2 of your Project News Autumn/Winter 2014/15 says: "Effective in more open landscapes as the majority of the pylon is seen against the sky". However, this is in direct conflict with page 25 of the Overview (to which we are directed by Q4 in the Consultation Feedback Form) which says "The T-pylon has a modern monopole design and can be suitable in more open and flatter landscapes, where the majority of the pylon would be seen against the surrounding landscape". This merely emphasises the difficulty of making an informed decision about a pylon type that does not yet exist in the UK, which nobody being consulted has experience of in the landscape, and which may yet have production difficulties when it is actually built. The so-called low height lattice pylon (L12) is said in Paragraph 2.10.3 on page 18 of Vol 2.2 of the PEIR to have an average height of 41.5 m. The range is between 29.3m and 44.4m so for an average height of 41.5m most are closer to 44.4m which seems little different to a conventional L8 pylon. Furthermore the wide low arm of the L12 and its heavier metalling may mean that it is more obtrusive in the landscape than the conventional L12 pylon. Again, the people being consulted would have no experience of L8 pylons in the landscape, because the nearest examples appear to be near Thirsk in Yorkshire. Viewing them in Google Street View is not quite the same as the real thing. However Figure 2.2 depicts both the L8 and the T-pylon as being a set 35m in height compared to the stated averages in Paragraph 2.10.3 and 2.10.4 of 41.5m for the L8 and 38.2m for the T-pylon, which again is rather misleading. Undergrounding option We cannot understand why in your eyes Shropshire is considered to be less worthy of undergrounding than the Meifod valley. Is it simply because the people of Montgomeryshire shout louder, rather than on any objective landscape or other assessment? Our preferred option (apart from no mid Wales windfarms) would be to underground the whole line, which is also the view of Shropshire Council. You imply that this would be too costly but that is an assessment of financial cost (to yourselves in the first instance) rather than also taking into account all social and environmental costs arising from the adverse impacts of your scheme. Blight, compensation and mitigation There are several known instances in north Shropshire of individuals or businesses suffering financial blight because of the threat of having your proposed MWC near them. In some cases the financial hardship is real. It was therefore disappointing that at one of the last of the consultation events an NG employee, on the land side, denied the existence of such blight. We have recently learnt that when Lake Vyrnwy was built in the 1880s all the inhabitants of Llanwddyn, which was the village that was flooded, were rehoused and given jobs for life. It

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would be reassuring to feel that National Grid too would have sufficient social conscience to compensate those who have already suffered financially and socially, and those who will suffer, as a consequence of your actions. It is iniquitous, particularly compared with that Victorian Vyrnwy example, and in the light of modern Human Rights Acts, that individuals should be caused to suffer, ostensibly in the public good, without any prospect of compensation for that suffering. There should at least be adequate mitigation for the various harmful effects of your proposals. Conclusion The essence of consultation is: (a) That it must be undertaken at a time when the proposals are at a formative stage; (b) It must include sufficient reasons for the particular proposals to allow those consulted to give intelligent consideration and an intelligent response; (c) It must give adequate time to allow those consulted to give intelligent consideration and an intelligent response; (d) The product of consultation must be conscientiously taken into account when the ultimate decision is taken. From our above comments there remains doubt as to whether (b) and (c) above have been satisfied. It remains in your hands as to whether (d) is satisfied, or whether Glyn Davies MP is proved to be right. We would be grateful if you would acknowledge receipt of this consultation response please. We would also be pleased to have responses to the various questions we have posed within it. Yours sincerely

Charles Green

C W Green Chairman SNAP

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