Eryri Local Development Plan

Background Paper 5

Energy

May November 2017

Background Paper 5: – May November 2017 1. Background

1.1 Emissions from energy production, mostly CO2, are the principal cause of increased levels of greenhouse gases in the atmosphere. There is now overwhelming scientific evidence that these increases are leading to climate change, which is regarded as a serious threat to the world.

1.2 On a national scale, energy emissions primarily arise from power generation, transport, buildings and industry. In the National Park, industry and power generation are insignificant; the predominant cause of energy emissions is transport and buildings (heating, lighting, cooling and construction). Although there are no figures specific to energy consumption in Snowdonia, research conducted for Gwynedd indicates the per capita energy consumption was above the UK average. It is therefore likely that this will be true in the National Park. Transport contributes significantly to this, partly due to the high numbers (estimated at 10 million visitor days) visiting the Park by car.

1.3 The UK is subject to the requirements of the EU Renewable Energy Directive. These include a UK target of 15% of energy from renewables by 2020. The UK Renewable Energy Roadmap sets the path for the delivery of these targets, promoting renewable energy to reduce global warming and to secure future energy supplies. The Welsh Government is committed to playing its part by delivering an energy programme which contributes to reducing carbon emissions as part of our approach to tackling climate change whilst enhancing the economic, social and environmental wellbeing of the people and communities of in order to achieve a better quality of life for our own and future generations. This is outlined in the Welsh Government’s Energy Policy Statement Energy Wales: A Low Carbon Transition (2012).

2.0 Energy Policy 12.3 1 The Welsh Government’s policy on planning for renewable energy is set out in Planning Policy Wales – edition 9. November 2016 (PPW) and Technical Advice Note (TAN) 8.

1.42.2 PPW considers that in order to meet the Government’s renewable energy target of 4TWH per annum, local planning authorities should support proposals for renewable energy projects provided environmental impacts are avoided or minimised, and the integrity of nationally and internationally designated areas are not compromised.

1.52.3 LPAs should, it is stated, “facilitate the development of all forms of renewable energy and energy efficiency and conservation measures which fit within a sustainable development framework”. LPAs should seek to make positive provision for such developments in order to meet society’s needs now and in the future. This may be done by:

• considering the contribution that their authority area can make towards developing and facilitating renewable energy and energy efficiency and conservation, and ensuring that development plan policies enable this contribution to be delivered;

• ensuring that development control decisions are consistent with national and international climate change obligations, including contribution to renewable energy targets, having regard to emerging national and international policy on the levels of renewable energy required and on appropriate technologies; and 2 Background Paper 5: Energy – May November 2017

• recognising the environmental, economic and social opportunities that the use of renewable energy resources can make to wider planning goals and objectives and the delivery of renewable energy targets.

2.4 PPW considers that Local planning authorities should facilitate local authority-wide scale renewable energy in development plans by undertaking an assessment of the opportunities and potential for renewable energy in the area. They should also look for opportunities to co-locate major developments in order to optimise renewable energy potential and to promote district heating schemes. However these aspirations may not be achievable, or appropriate in National Parks where precedence must be given to conserving and enhancing natural beauty, wildlife and cultural heritage.

Scale of development Threshold (electricity and heat) Strategic Over 25MW for onshore wind and over 50MW for all other technologies Local Authority-wide Between 5MW and 25MW for onshore wind and between 5MW and 50MW for all other technologies Sub Local Authority Between 50kW and 5MW Micro Below 50kW

1.6 2.5 PPW further considers LPAs should undertake an assessment of the potential of all renewable energy resources, renewable energy technologies, energy efficiency and conservation measures within their areas and include appropriate policies in local development plans.

1.7 2.6 In undertaking such assessments local planning authorities should:

• take into account the contribution that can be made by the area towards carbon emission reduction and renewable energy production targets; and

• recognise that different approaches will be appropriate for the deployment of the different renewable technologies and energy efficiency and conservation measures.

1.8 Technical Advice Note 8 established a target of 800MW of installed onshore capacity for wind energy developments. TAN8 sets out Welsh Government’s view that large-scale (defined as being over 25MW installed capacity) onshore wind energy developments should be concentrated into particular areas defined as Strategic SearchAreas (SSAs) which are all located outside National Park boundaries.

12.7.9 Welsh Government Policy however does not specifically exclude the National Parks as areas for the location of small-scale wind energy developments of less than 5MW. However Paragraph 8.4 of TAN8 Renewable Energy has the objective “to maintain the integrity and quality of the landscape within the National Parks/AONBs of Wales i.e. no 3 Background Paper 5: Energy – May November 2017 change in landscape character from wind turbine development.”

In the context of protected landscapes such a categorisation based on output is not always appropriate as the different types of renewable energy developments have the potential to have adverse visual land landscape impacts in different ways.

2.8 For example the Welsh Government does not exclude the National Parks as areas for the location of small-scale wind energy developments of less than 5MW. However a single turbine of 4.5MW rated output would be well in excess of 120m to blade tip and visible up to 30kms. It is ’s highly likely that a single turbine of this size would have a significant detrimental visual and landscape impact and as such would be inappropriate within the National Park. A wind cluster of three 1.5MW turbines – typically some 100m to blade tip - would similarly have adverse visual and landscape impacts. The Supplementary Planning Guidance on Landscape Sensitivity and Capacity Assessments provides greater detail on the potential impact of wind turbines in Snowdonia.

2.9 Field scale arrays of photovoltaic panels (solar farms) of 4.5 MW would require some 8 hectares of land. In National Park terms that would constitute “Major Development”. In addition they introduce a man-made “industrial” type of development into a very rural area.

2.10 A 5MW hydro-power run-of river scheme would involve significant works to impound and abstract water, the burial of the penstock and the erection of a turbine house and outfall would have the potential to have a variety of adverse impacts on riverine ecology visual amenity, fisheries, recreation, hydrology and geomorphology. Hydro power and pumped storage schemes reliant on the creation of a high level reservoir or the utilisation of existing lakes would also have potentially wide-ranging and damaging impacts.

23. Supplementary Planning Guidance on Low Carbon and Renewable Energy Developments

23.1 The Authority issued Supplementary Planning Guidance (SPG) on Low Carbon and Renewable Energy Developments in 2013. This supports the ELDP policy and provides householders and developers with more detailed information on low carbon and renewable technologies and how the Authority will deal with planning applications for such developments.

34. Renewable Energy Capacity Assessment for Snowdonia

34.1 In 2012 the Snowdonia National Park Authority (SNPA) commissioned Arup to undertake a renewable energy generation capacity assessment for Snowdonia. The purpose of this study is to provide information on the potential and capacity for renewable and low carbon energy generation, as such it will form part of an updated evidence base for the first review of Eryri Local Development Plan (LDP). The methodology is based on the Welsh Government Practice Guidance: Planning for Renewable and Low Carbon Energy - A Toolkit for Planners (June 2010, referred to as the “Welsh Government Toolkit”). 4 Background Paper 5: Energy – May November 2017

34.2The Toolkit was updated and re-issued in September 2015. The use of the toolkit was aimed at assisting planning policy officers from Local Planning Authorities to deliver two national planning policy expectations as set out in Planning Policy Wales, namely, Planning for Renewable Energy, and Planning for Sustainable Buildings.

34.3 The Toolkit states that, for the assessment of windpower and solar farm potential, it can be assumed there is no potential for large-scale wind development in the areas listed below, although in practice some of these sites may not be particularly sensitive to wind power and solar farm developments

• Special Protection Area (SPA) • Special Area of Conservations (SAC) • Candidate Special Area of Conservation (cSAC) • RAMSAR sites • National Nature Reserves (NNR) • Site of Special Scientific Interest (SSSI) • Marine Nature Reserves (MNR) • Scheduled Ancient Monuments (SAM) • Area of Outstanding Natural Beauty (AONB) 34.4 Whilst the 3 National Parks are not mentioned specifically in the REA Toolkit Planning Policy Wales states that in planning terms:

“National Parks and Areas of Outstanding Natural Beauty are of equal status in terms of landscape and scenic beauty and both must be afforded the highest status of protection from inappropriate developments. In development plan policies and development management decisions National Parks and AONBs must be treated as of equivalent status. In National Parks and AONBs, development plan policies and development management decisions should give great weight to conserving and enhancing the natural beauty, wildlife and cultural heritage of these areas”. (Para. 5.3.6)

45. Implications for the Plan

45.1 Planning Policy Wales states that National Parks and Areas of Outstanding Natural Beauty are of equal status in terms of landscape and scenic beauty and both must be afforded the highest status of protection from inappropriate developments. To that end it is considered that there is no potential for large-scale windfarm and solar farm developments in the National Park because of its designation as a protected landscape. No spatial allocations will therefore be made for these technologies in the Eryri LDP revision.

45.2 It is not considered practical to undertake the detailed site surveys necessary to establish the spatial disposition of potential sites for future microgeneration. There is great awareness by landowners and developers of the potential for small- scale hydro in the National Park, as evidenced by the large number of planning applications received by the Authority. It is considered therefore that continuing 5 Background Paper 5: Energy – May November 2017 with a criteria based policy on renewable energy developments, judging each application on its merits, remains the best option.

45.3 Appendix 1 and 2 sets out the findings of the revised Renewable Energy Assessment for the National Park. Appendix 1 sets out the current energy consumption and production in Snowdonia, while Appendix 2 provides an estimation of the theoretical renewable energy capacity available within Snowdonia.

45.4 Out of a potential capacity 51.7 MW (electricity) some 35.5% may be provided by microwind and 33.4% by photovoltaics with only energy crops and biomass (18.6%) out of the other technologies making a meaningful contribution. The figure of 7.5%. for hydro is based on low-head schemes (1.9MW) and an estimate of small-scale high head schemes (2MW) that may come forward.

45.5 Whether this theoretical capacity of 51.7MW will be achieved will be very greatly dependent on environmental, technical and economic considerations. Certain small domestic scale technologies will benefit from permitted development rights.

6 Background Paper 5: Energy – May November 2017 Appendix 1: Current Energy Consumption in Snowdonia 5.1 Energy efficiency is one means of combating climate change. By using energy more efficiently and reducing demand for energy in our homes we can, not only save money, but go some way to reducing greenhouse gas emissions from electricity generation. 5.2 A detailed breakdown of domestic gas and electricity consumption within the National Park is not available. However figures are available for Conwy and Gwynedd, from these an estimate of energy consumption can be derived based on the percentage of the population of Gwynedd and Conwy that is estimated to live in Snowdonia1. These figures do not include energy use for transport. 5.3 Estimates of Current Gas Consumption in Snowdonia The Table below shows estimated domestic and non-domestic gas consumption within Snowdonia for the years 2014 compared to 2010.

Domestic Gas Commercial and Sales per Customers Customers Industrial Customers Average Year No. of No. of Average C&I Sales Sales Domestic Customers Customers Consumption (GWh) (GWh) Consumption (Thousands) (Thousands) (kWh) (kWh) 2010 111.8 8.1 39.9 0.1 3016.3 77672.4 2014 94.9 8.2 31.0 0.1 2518.3 66124.1 Table 1: Snowdonia gas consumption for the years 2010 and 2014

5.4 Estimates of Current Electricity Consumption in Snowdonia The base electrical consumption data for the Snowdonia is provided to DECC at Meter Point Administration Number (MPAN) level by the data aggregators, agents of the electricity suppliers. These agents collate and aggregate electricity consumption levels for each MPAN2.

5.5 The Table below shows estimated domestic and non-domestic electricity consumption within Snowdonia for the year 2014 compared to 2010.

Domestic Electricity Commercial and Sales per Customers Customers Industrial Customers Year Average Average C&I Sales MPANs Sales MPANs Domestic Consumption (GWh) (Thousands) (GWh) (Thousands) Consumption (kWh) (kWh) 2010 56.6 12.8 56.4 1.6 972.4 7717.9 2014 51.3 12.9 65.3 1.6 881.1 8795.0 Table 2: Snowdonia electrical consumption for the years 2010 and 2014

1 Based on 2011 census figures. No account has been taken of potential differences in housing stock or industrial sectors within and outside the Park. 2DECC (2012) Sub-National Electricity Consumption Data. Available from: http://www.decc.gov.uk/en/content/cms/statistics/energy_stats/regional/electricity/electricity.aspx

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6. Current Energy Production 6.1 Information on renewable energy schemes in Snowdonia benefitting from Non- Fossil Fuel Obligation (NFFO) contract payments3 (3 & 4) and is set out in Table 3 below.

Installed Capacity Scheme Technology Status Source (MWe) Gywnedd Afon Tyn y Cornel Hydro Hydropower 0.195 Operational DECC

Maentwrog Hydropower 30 Operational DECC

Cwm Croesor Hydropower 0.5 Operational NFPA Cwm Dyli, nr Beddgelert Hydropower 9.9 Operational RWE

Twrch, Pandy Hydropower 0.475 Operational NFPA

Afon Ysgethin, nr Harlech Hydropower 0.86 Operational NFPA

Harnog, nr Rhyd y Main Hydropower 0.45 Operational NFPA

Afon Ty Cerig, Rhyd y Main Hydropower 0.195 Operational NFPA

Gain, nr Ganllwyd Hydropower 0.55 Operational NFPA Dolhendre, nr Bala Hydropower 0.45 Operational NFPA

Cwmorthin, Tan y Grisiau Hydropower 0.415 Operational NFPA

Dolgoch, nr Tywyn Hydropower 0.30 Operational DECC

Pant yr Afon, Llechwedd Hydropower 0.4 Operational DECC Bryn Fedw Hydro, Rhyd Hydropower 0.7 Operational DECC Ddu Llyn Celyn Hydropower 4.38 Operational SNPA Ganllwyd Hydro Power Hydropower 0.645 Operational NFPA Station Gelli Iago Hydropower 0.18 Operational NFPA

Cerist Nant y Graig Wen Hydropower 0.38 Operational NFPA

Cwm Llan Nant Gwynant Hydropower 0.44 Operational NFPA

Tryweryn nr Craig y ronw Hydropower 0.43 Operational NFPA

Dwynant Glandwr Barmouth Hydropower 0.31 Operational NFPA

Cadair Llanfihangel, Tywyn Hydropower 0.6 Operational NFPA Llaethnant Llanymawddwy Hydropower 0.435 Operational NFPA

Mawddach Hydropower 0.46 Operational NFPA

Cynfal Hydropower 0.18 Operational NFPA

Treweunydd Rhyd Ddu Hydropower 0.75 Operational NFPA

Machno Pandy Mill Hydropower 0.1 Operational SNPA

3 NFFO refers to a collection of orders requiring the electricity Distribution Network Operators in England and Wales to purchase electricity from the and renewable energy. Five orders were made under the NFFO before the UK government replaced it with the Renewables Obligation 8 Background Paper 5: Energy – May November 2017 Conwy Dulyn weir Hydropower 0.5 Operational NFPA

Dolgarrog Hydropower 33.38 Operational RWE

Total 88.38 MW Table 3: Snowdonia Current Renewable Energy Installed (Feb 2016) 6.2 Table 4 below sets out the current estimated microgeneration technologies installed within Snowdonia, taken from Feed-in-Tariff (FiT) data. As this data is only available at a local authority level, an assumption has been made about the installed capacity within the Park, based on the percentage of the households of Conwy and Gwynedd within Snowdonia.

Gwynedd Conwy Total Total, Snowdonia (Conwy and (assumed) Gwynedd)

Domestic PV 5.3 (2.4) 3.2 (1.24) 8.5 (3.64) 0.96 (0.4) Non-domestic PV 6.5 (0.09) 3.7 (0.01) 10.2 (0.11) 1.2 (0.01) Domestic wind 0.37(0.02) 0.25 (0.02) 0.62 (0.04) 0.07 (0.00) Non-domestic wind 0.59 (0.01) 0.67 (-) 1.26 (0.01) 1.44 (0.00) Domestic Hydropower 0.11(0.05) 0.034 (0.02) 0.144 (0.07) 0.016 (0.01) Non-domestic hydropower 1.9 (0.23) 0.31 (0.06) 2.21 (0.29) 0.29 (0.03) Domestic micro CHP - 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) Total 3.98 (0.46) Table 4: Current assumed microgeneration installed, Snowdonia (MWe)4 (previous reported figures in parentheses) 6.3 Current assumed microgeneration installed has increased over eightfold from the figure of 0.46MWe reported in 2012. This has mainly been due to the increase in domestic pv and the introduction of permitted development rights for some of the technologies.

6.4 Table 5 sets out the total estimated current renewable energy generation in Snowdonia, combining larger scale generation with feed-in-tariff scale installations.

Hydropower Microgeneration Total

Installed Capacity (MW) 88.38 3.98 92.36

Electrical Generation (GWh) 286.5 12.9 299.4 Table 5: Total renewable energy generation in Snowdonia (Feb 2016)

6.5 These figures for microgeneration must be viewed with some caution as the declared output of schemes granted planning permission - see below - in Snowdonia between July 2011 and June 2015 totals some 4.18MW. The total will be higher as 25% of the applications did not include output figures5.

4 Cumulative installations as at Sept 2015 confirmed on the Feed-in Tariffs Register by Local Authority 5 There may be an element of “double counting” of schemes in addition to any errors arising from estimating microgeneration uptake on apportioning Gwynedd and Conwy LA figures to the National Park 9 Background Paper 5: Energy – May November 2017

6.6 Renewable Energy and Low Carbon Developments Permitted in National Park. Whilst not all types of renewably energy technologies are appropriate in designated landscapes such as Snowdonia, the map below highlights all the renewable energy applications that have been granted planning permission since the adoption of the Eryri Local Development Plan (July 2011 until June 2015). 136 applications for renewable energy production were granted planning permission during this time period.

Planning Applications Planning Renewable Energy type Received (including Applications withdrawn application) Granted Hydro 86 73 (84.8%) Wind 20 16 (80.0%) Solar 48 45 (93.8%) Other 3 2 (66.6%) Table 6: Planning Applications for Renewable Energy Schemes in the National Park

6.7 73 hydro applications have been granted planning permission since July 2011. 34 of these were in 2013 whilst 26 were granted during 2014. The majority have been for relatively small-scale high head run of river hydro schemes on farms. The SNPA developed its own hydro scheme at Plas Tan y Bwlch. Another scheme on Afon Machno featured an Archimediean screw design.

6.8 The other main technology deployed include photovoltaic (pv) panels, some of which are small free-standing arrays. Others have been retro-fitted to dwellings, and provided certain conditions are met such developments benefit from permitted development rights The two “other” renewable energy applications which were granted permission were for a biomass boiler cabin and a chip storage unit with a combined heat and power system

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Appendix 2

A1. The Table below sets out the findings of the revised Renewable Energy Assessment for the National Park. It provides an estimation of the theoretical renewable energy capacity available within Snowdonia.

Potential Potential Potential Generation Potential Capacity Capacity (GWh) Generation Category Sub-Category (MWe) (MWt) (GWh) [Electricity] [Electricity] [Heat] [Heat]

Micro-wind 18.4 - 16.1 - Managed 4 8 31.55 63.11 Woodland Biomass Energy Crops 5.66 11.33 44.65 89.31

Animal Manure 0.18 0.28 1.42 1.2 Anaerobic Poultry Litter 0.048 0.072 0.37 0.32 Digestion Sewage Sludge6 0.07 0.10 0.52 0.43

Landfill Gas Gas engine 2.13 - 11.2 -

Low head 1.9 - 6.1 - Hydropower High head 2.0 6.5

Solar 17.3 17.3 15.15 15.15 Microgeneration Heat Pumps - 55 - - Total 51.7 93.1 133.56 169.52

A2. Microgeneration presents a reasonably significant resource available within Snowdonia. Planning policy can encourage and facilitate greater integration of renewable energy technologies (e.g. pv panels) through the appropriate retrofitting of such technologies into existing buildings. A3. However, some barriers to retrofit, particularly on domestic properties, remain, and it may be hard to deliver the full quotient of renewable energy that is technically available. A4. With over 2.16MW capacity granted planning permission between July 2001 and July 2015 high head hydropower may continue to provide opportunities within Snowdonia. However it is difficult to predict the high-head resource that will be available in future years as it can be reasonably assumed that the least constrained resource will be developed first. It is expected therefore that applications for such schemes will taper off as sites become more difficult to develop due to ecological, hydrological, landscape

6 It is intended that a substantial amount of sewage sludge from Snowdonia will be transported to the Advanced Digester at Treborth Waste Water Treatment Plant 12 Background Paper 5: Energy – May November 2017 and other technical constraints, for example access to the local electricity distribution network.

A5. To that end based on past trends an estimate of 2MW additional capacity has been made.

A6. It is not considered practical to undertake the detailed site surveys necessary to establish the spatial disposition of potential sites for future microgeneration. There is great awareness by landowners and developers of the potential for small-scale hydro in the National Park, as evidenced by the large number of planning applications received by the Authority. It is considered therefore that continuing with a criteria based policy on renewable energy developments, judging each application on its merits, remains the best option.

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