Save Our Rivers would like to thank the Capel Curig Community for inviting them to speak alongside the developer in discussion of the proposed Llugwy HEP project.
Having listened to both the developer’s description of the scheme, along with the comments from members of the community Save Our Rivers has decided it will be officially objecting to the planning application.
During the meeting the developer talked extensively of how in the future the community may be allowed to purchase some share in the project, or how they could change the way the construction is carried out, or how the turbine may not be taking water for as long as described in the abstraction application. However; what we must remember is that these are simply words with no guarantees, what is important is what has actually been applied for, and that is this:
A private company has applied to remove, through a 2m by 15m metal grill, 4.2 Cumecs of water above a tiny compensation flow from Pont Cyfyng Falls (this will be nearly 70% of the flow for around 70% of the year). To pass this water through a 2m diameter 100m long tunnel (it will bore over a series of months) to a pipe line and turbine house built in a patch of Ancient Semi Natural Woodland (requiring the felling of 1/3 of the trees on site). Using a historic bridge and small unclassified road as it’s main route of access. All this to provide, when running at full power, enough electricity to run 40 electric showers.
Save Our Rivers main points of objection are listed below:
Impact on Ancient Woodland
The arboricultural report lists 87 trees in the vicinity of the development, 31 are listed to be felled, over a third. Some of these trees are suffering from Ash die back, but many are not (because they aren’t Ash trees), in any case Ash die back would not have the impact of removing all the trees in a single event.
Ancient woodland and semi-natural woodlands and individual ancient, veteran and heritage trees are irreplaceable natural resources, and have significant landscape, biodiversity and cultural value. Such trees and woodlands should be afforded protection from development which would result in their loss or deterioration unless there are significant and clearly defined public benefits; this protection should prevent potentially damaging operations and their unnecessary loss.
Planning Policy Wales ed 10 6.4.26
The ecological impact of the “depleted reach” on the bryophyte assemblages and other flora and fauna of this section is not to be underestimated. The ecological survey presented by the developer states:
The river at the time of the survey was in full spate and it was considered too dangerous to undertake a full in:stream survey. Therefore, the survey was confined to the immediate right bank of the river only where it was accessible. One must bear in mind also that only a very small proportion of this large river will be abstracted so it is considered that any potential impact on the in stream ecology is likely to be extremely modest.
However the abstraction regime applied for is 70% over Q95 up to a maximum of 4.2 Cumecs (which will be reached at around Q22. The abstraction is for most of the river to be abstracted for most of the time. The ecological report is therefore both inadequate and based on an incorrect premise.
SNPA must ensure that adequate assessment of possible biodiversity impacts have been made. The poor quality of the developers ecological assessment makes this impossible
The S6 duty requires that public authorities must seek to maintain and enhance biodiversity so far as consistent with the proper exercise of their functions and in so doing promote the resilience of ecosystems.
Environment (Wales) Act 2016 Section 6 – Biodiversity and resilience of ecosystems duty
Visual impact of the development
Visual impact of the development falls into 2 main areas:
- Impact of the built structures into a wild and dramatic section of waterfalls. The presence of the 2m by 15m intake grill, turbine house, metering house and tunnel / pipeline will be considerable. All will be visible from the A5, a viewpoint lay-by and by the popular footpaths both to Moel Siabod and along the right bank of the Afon Llugwy. Consideration of the visual impact in terms of artist impressions or photomontages are entirely absent from the application.
- Impact of the abstraction on the visual and aural amenity of the falls. The abstraction regime applied for would see nearly 70% of the water being diverted around the falls in all but the lowest 5% of flows and the highest 20%. There is no visual assessment of this in the planning application, but it will certainly be considerable.
This acts against the 2 core purposes of the national park:
To conserve and enhance the natural beauty, wildlife and cultural heritage; and
To promote opportunities for the understanding and enjoyment of the special qualities of the (National) Park by the public.
Inadequacy of the application to asses the impact of construction
There are multiple inadequacies in the application with regards the using of the A5, historic bridge and unclassified road as the main routes of access for the construction. These include but are not limited to; no information as to how the footpaths to both Moel Siabod and along the Afon Llugwy (directly impacted by the development) will be affected, a lack of swept path analysis of roads for the delivery and construction vehicles required, no detailed plans of new gateways/access points required and no arboricultural report of any trees that may be required to be removed or cut back to facilitate access along the unclassified road. Many of these points are raised in the response by Welsh Highways.
One further concern is the description in the CMS of the use of a front-loading dumper for transportation of excavated material. The construction will require the dumper to operate around 2 popular rights of way and a row of houses close to the unclassified road. Front loading dumpers have been responsible for 6 deaths in the last 6 month period in the UK and there is no indication in the CMS of how health and safety concerns regarding this will be dealt with.
If you wish to object to the development download this template letter, fill it in with your own views or use ours for guidance. Then email it to email@example.com .
Update 13th Feb 2019
See our full objection letter here: Pont Cyfyng objection
Our objections summary:
I am sure the SNPA will make the correct decision and refuse permission for the obviously unsuitable and poorly presented development. One must consider why such a poor-quality application has been submitted. Recent planning decisions, such as the initial recommendation for approval of the Conwy Falls HEP, the permissions in retrospect for the appalling Afon Las HEP or the granting of permission for yet another barrier to migrating Salmon on the Afon Colwyn may be a contributor. With lax permitting and lax oversight of hydro developments and with no consequences for breach of planning conditions it is no surprise that developers feel Snowdonia has become somewhat of a free for all when it comes to hydro development.