OBJ/008/POE/S4 PROOF OF EVIDENCE FROM MAP TO THE MID-WALES CONJOINED PUBLIC INQUIRY, SESSION 4: CUMULATIVE EFFECTS SUMMARY TO ACCOMPANY SUBMISSIONS MAP AND THE NATIONAL GRID We are submitting this statement of evidence on behalf of Montgomeryshire Against Pylons (MAP). MAP was founded in March 2011 after some 500 people had turned up on a rainy night to a meeting to protest the proposed National Grid giant pylon route of 38 miles to West Felton from the wind turbine installations currently under consideration at this Inquiry, plus the hordes of others in prospect should these ones be approved. Subsequently demonstrations involving thousands of people have taken place here in Welshpool and in Cardiff, as the Inquiry already knows. At many protest meetings and demonstrations involving hundreds of people have been held in such communities as Cefn Coch, Llanfair Careinion, Meifod, Pontrobert, Bwylch-y-Cibau, Llanstanffraid, Four Crosses, Oswestry, Llanymynych and Maesbury – in fact along the proposed pylon route. These, because so many communities are affected, have triggered off interest in the proposed industrial proliferation of wind turbines further upstream. MAP represents a mass of people in the Vyrnwy valley, and those originally threatened by the giant pylons of the proposed mid-Wales link along the Severn and Rae valley, who are appalled at the proposed destruction to those who visit and live in one of the most beautiful, historic and unspoilt landscapes in the British Isles. Polls carried out by independent community councils suggest we have 85-95% support against pylons and turbines along the route. MAP is a popular organisation, having a loose federal structure of different communities particularly concentrated down the Vyrnwy valley where the National Grid has made clear its intention to build the pylons with sometimes quite forcible tactics to enter onto land and conduct their surveys. We know also that the National Grid has rejected the Severn Valley option as well as conditionally suspending the 1 bypass route around the hills from Pontrobert in favour of the Vyrnwy valley to West Felton route. There is nothing ‘speculative’ about this. The National Grid have decided along a very narrow corridor, already being aggressively pursued for three years, which is designed to blend with the timetable for construction of the wind turbines being considered at this Inquiry and those that will inevitably follow. Basically, the National Grid appears to regard the outcome of this Inquiry as a foregone conclusion, and has decided its route already. National Grid have a statutory duty to connect up anything over 100mw. This is less than the amount of electricity that would be generated if this Inquiry recommends in favour of all four of the projects it is considering. Even if it does only one or two, the others are queuing up behind – particularly Scottish Power with its giant wind turbine proposal in the Dyfnant Forest. The Inquiry will set a precedent for subsequent applications which are likely to be in many hundreds in the Strategic Search areas. This would be an inevitable and enormous cumulative effect if these wind turbine concentrations are approved. Inevitably the pylons, or mid-Wales connection, will be constructed following a decision to proceed with the projects under consideration here. If approval is given to the mid-Wales turbines, the National Grid will have to provide the connection. It has a statutory obligation to do so under the Electricity Act. Overwhelming evidence we provide here [Claire: already submitted] shows the National Grid regards this Inquiry as a foregone conclusion and is pressing ahead regardless at great expense to provide the connection for the mid-Wales turbines – even though they are not yet approved, a point we have raised repeatedly with the National Grid and which has never been satisfactorily answered. What inflames popular opinion in the affected areas is the lack of empathy with local people whose lives and businesses are going to be so adversely affected by effectively turning the whole of mid-Wales into one large power station, with smaller grid connections, the sub-station and the mid-Wales connection. MAP considers that because the details are known almost to the nearest three hundred yards, these must be matters for consideration at this Inquiry, and that the applicants have an 2 obligation to provide detailed EIA assessments based on the wealth of information obtainable from the National Grid as to that route. Failing this the Inquiry should be halted until the assessments are made. In this document and submissions [most already submitted] we provide strategic and ‘high level’ evidence from information already in the public domain, of the kind the Inspector has allowed, with, for example, a few specific references to famous aspects of cultural heritage assets certainly threatened by the grid connection. The point is that the grid connection is a fundamental part of the cumulative effect of the windfarm proposals considered at this Inquiry. No wonder the applicants are seeking to separate the two decisions in a cynical attempt to steamroller their proposals through, with the National Grid as an accomplice. MAP (as the Alliance already has) would seek to highlight again the Secretary of State’s policy for energy – EN-I, and its paragraphs 4.9 2-3 which states, pretty clearly: 4.9.2 The Planning Act 2008 aims to create a holistic planning regime so that the cumulative effect of different elements of the same project can be considered together. The Government therefore envisages that wherever possible, applications for new generating stations and related infrastructure should be contained in a single application to the IPC or in separate applications submitted in tandem which have been prepared in an integrated way. However this may not always be possible, nor the best course in terms of delivery of the project in a timely way, as different aspects may have different lead-in times and be undertaken by different legal entities subject to different commercial and regulatory frameworks (for example grid companies operate within OFGEM controls). So the level of information available on the different elements may vary. In some cases applicant(s) may therefore decide to put in an application that seeks a consent only for one element but contains some information on the second. Where this is the case, the applicant should explain the reasons for the separate application. 4.9.3 If this option is pursued, the applicant(s) accept the implicit risks involved in doing so, and must ensure they provide sufficient information to comply with the EIA Directive including the indirect, secondary and cumulative effects, 3 which will encompass information on grid connections. The IPC must be satisfied that there are no obvious reasons why the necessary approvals for the other element are likely to be refused. The fact that the IPC has decided to consent one project should not in any way fetter its subsequent decisions on any related projects. MAP would merely observe that the National Grid has worked well in advance of any decision by the Inquiry or planning authorities to deliver the connection and has provided a huge amount of information on the proposed connection already [already submitted]. The developers instead have provided virtually no information on the Grid connection as required and have not explained any reason for a separate application and indeed have not made one, leaving it to the National Grid at a later stage. We would also comment that the last two sentences of paragraph 4.9 3 are ambiguous. The necessary approval for the other element, the pylon line, is not just unlikely not to be approved but – whatever the recommendations of the subsequent Inquiry on the pylon route – must be approved by statute under terms of the electricity act which gives the Grid its statutory duty to connect unless the 2008 act indeed overrides this. In regard to the second last sentence, can the (now) IPU take a decision on a second, inevitably related project which not only contravenes statute, but would overturn its consent to the first project (assuming it does)? In this respect, the Inspector in his opening session, referred to the Welsh government’s view that the 400KV lines may be unnecessary: but of course the IPU and National Grid policy can override Welsh government policy, if indeed that is still its view. As the Inspector observes ‘in the absence of any other scheme for connecting the four windfarms for certain the applicants could not then provide sufficient information on indirect, secondary of cumulative effects associated with the grid connections’ and therefore that it was likely that consent for the windfarms would be refused’. But that must happen at this Inquiry not at the IPU hearing about the pylon line which would be inevitable following approval of the wind turbines at this Inquiry. The Welsh government has made its position clear against the pylon line, TAN-8 which ruled out any major pylon connection, is plain on the policy, and the applicants have failed to provide information on indirect, secondary or cumulative affects associated with the 4 grid connections. On that basis alone, this Inquiry should refuse consent. Granting consent to the wind turbines would make the pylon line legally inevitable, and the subsequent Inquiry into the pylons themselves would be a rubber stamp. MAP would also draw attention to the Minister of State for DECC’s reply to MAP of October 20, 2011 [already submitted] and in particular paragraphs 3, 4 and 5, which states explicitly that it is ‘for the transmission owner companies including National Grid to bring forward the proposals to provide specific transmission connections, including proposed routes and types of connection’ and that they must consider amenity and consult local communities (a position now heavily reinforced by the DCLG’s latest guidelines and the Localism Act, and indeed Ofgem’s regulations in regard to visual amenity.