Comment on Planning Officer’s report:

After careful consideration Save the Conwy feels the Planning Officers report does not adequately investigate the planning application and presents its report with apparent bias. We feel it does not give the Planning Committee enough information to make a well informed decision.

The report can be found here:

http://www.snowdonia-active.com/docs/conwyfalls-snpa-planning.pdf

Our comments on the report are listed below:

In listing permanent features of the development 2 major factors are missed.

1. A large 100m long impoundment of water upstream of the intake weir.
2. A significant reduction of flow of water through the Fairy Glen.

Non-statutory/interest groups listed

Only 3 groups have been listed here, despite many other groups listed as being consulted further up the document.

No mention of:

Strong objection by Canoe Wales – governing body for paddle sport in Wales.

Strong objection by Snowdonia Active

Objection by North Wales Wildlife Trust

Objection by Betws y Coed Anglers Club / Gwydyr Fishery – owners of the fishing rights affected by this scheme.

The objection of a campaign group, Save the Conwy, with over 2500 followers who have been engaged with the developer and affected groups from the outset .

The language surrounding the public comments shows bias.

Over 650 individual letters expressing concern.

Should this not be objecting , my personal letter and that of Save the Conwy strongly objected within the frame work of the planning policy of the national park, it did not merely express concern. To say the objectors fall into certain groups; anglers, kayakers and local businesses is also untrue and aims to portray them as self-interested. Personally my objection and that of Save the Conwy was broad based. This also totally ignored the 351 objection that came through the Woodland trust’s supporters that are presumably concentrated on environmental factors.

The statement

32 letter of support for the scheme have been received who have generally highlighted the benefits of hydro eclectic schemes of this nature, being clean, renewable energy source with long term benefits.

Shows the Planning Officer already holds the opinion that this scheme will provide long-term benefits, this is meant to be what he is impartially assessing.

The benefits of the scheme shown as

The benefits of an HEP scheme of this nature (5MW) are quoted as an average generation of electricity up to 15,000 Megawatt Hours, annual average carbon dioxide offsetting of up to 6,450 tonnes and up to an equivalent of 3177 domestic homes supplied by the electricity generated.

This shows average power production over the year and then claims the equivalent of 3177 homes supplied forgetting that the figure is an average and for 35% of the year no power is produced. The main problem with these schemes is the irregularity of supply and this is not considered here at all.

Enforcement

It is considered that the environmental and visual effects can be adequately managed and mitigated against through rigorous conditions during the construction phase and post construction. A position that is backed up by the responses from statutory consultees who have not raised objections to the proposed scheme. It is considered that sufficient powers are in position between the various agencies including the National Park Authority to ensure no long term harm to matters of importance.

Is this true? The form of / method for enforcing these conditions should be spelled out before permission is granted. Does recent experience with projects such as this back up this claim?

Other areas of concern:

Visual impact of the weir: your officers have expressed concern over the visual impact of the weir construction in the long term

Why only concerned by the visual impact of the weir. Save the Conwy submitted an experts report to planning concerned with the safety of the weir design shown in the plans. This was with regards to both its design and position.

Visual impact on Rhaeadr y Graig lwyd (Conwy falls) the extraction regime will ensure that the falls will remain a visually impressive feature. The exact nature of the extraction regime is yet to be considered, this will be done as a part of the extraction licence application with NRW. If not considered appropriate the licence will be denied.

Conwy falls will no doubt remain impressive, but obviously less impressive. The concern for ensuring this is then passed to NRW to consider after planning permission has been granted; surely this must also be the SNPA’s concern.

Only a very small part of the development site falls within an area that has been included in the inventory of ancient woodlands………..

…... However, the application does show extensive compensatory native broadleaf planting extending to approximately 2.5 acres.

New planting is not considered compensatory for loss of any (however small) amount of ancient woodland. New trees are by their very nature not ancient and nor will they become so with in the life span of the proposed hydroscheme.

A detailed assessment of the effects of vehicular movements in association with this proposal has been undertaken.

But no traffic management plan has been submitted. In fact the Welsh Highways Agency response to the application although not objecting in principle lists an enormous amount of information missing from the application that must be in place before development begins. This surely should be in place before planning permission is granted.

Based on survey work and vehicle counts it is predicted that this proposed development will result in an increase in overall traffic movements in the order of 2.6% for the A470, 0.59% for the A5 and 2.59% for the B4406. There will inevitably be peaks and troughs in vehicular movements depending on on-site development phase activities

The traffic aspect of the EIA has obviously not been studied in any detail or is being deliberately presented in the best possible light. Suggesting there will be peaks and troughs is correct. Up to a peak increase of 144% on the A470 (data taken from EIA Vol 1 Table 11-11).

Also an increase in overall traffic flow is very different from an increase in HGV traffic. Taking data from the B4406 as an example, based on August traffic flows there would be a 35% increase in HGVs. Based on October traffic flows this would rise to a 42% increase in HGVs (data taken from EIA Vol 2 Pt 2 – Tables 5.10 & 7.1).

The officer has also not picked up on the fact that 3 out of the 9 traffic surveys were carried out on an August bank holiday to give a higher baseline figure for traffic increase to be measured against.

There is also no consideration of traffic stoppages that will be required .

‘The Welsh Government has indicated that should the tunnel be constructed using ‘drill and blast’ methods there may need to be temporary road closures of up to 20 minutes to safe guard road users.’ (EIA Vol 2 Pt 2 - 8.10.2)

Recreational concerns:

The concerns of the angling fraternity and the use of the river by kayakers in terms of the water level in the depleted reach of Afon Conwy will be a matter that is raised at an appropriate time when the extraction regime is considered by NRW.

Concerns of the 2 biggest user groups of the affected area, who arguably will also be the 2 groups most affected have been passed over for consideration after planning permission has been granted. Recreational needs cannot be fully resolved by NRW during the abstraction licence process (abstraction licences do not normally consider recreational needs and there has been no evidence of this in similar scheme built in Scotland). Recreational needs must be the concern of the SNPA.

• The opportunity for people to understand and enjoy the National Park actively, whilst maintaining areas of tranquillity and solitude, thus promoting aspects of health and wellbeing.

From the SNPA development plan.

A recent RWE hydroscheme on the Braan in Scotland was rejected by planners until the scheme was altered (outlet moved upstream) to meet the needs of recreational users.

It is considered that this proposal does not conflict with Eryri Local Development Plan policies

As I see it the proposal contradicts the plan multiple times mostly with regards to

3.19 Whilst large-scale energy power generation projects are incompatible with National Park status an assessment of renewable energy in Snowdonia considered that scope might exist to contribute to reduce demand for electricity derived from fossil fuels through efficiency savings and through small-scale renewable energy developments to meet domestic or community needs. These included small-scale hydro, domestic wind turbines, photovoltaics, biomass and landfill gas.

In its effects on both a fragile ecosystem and the local community the scale of this project is not small. The power produced is also not intended for “domestic or community needs “as Snowdonia is already a net power exporter and the power is to be sold to the grid by a multinational power company.

Conclusion:

On balance it is considered that the potential benefits in approving such an HEP scheme of this nature are not outweighed by the disbenefits of the scheme. The disbenefits are considered not to be long term and can adequately be mitigated against through conditions. In addition any short term disbenefits during the construction phase can also be managed to minimise disruption and harm to matters of environmental concern.

RWE’s own EIA submitted to the SNPA lists the benefits of the scheme as

‘minor contribution towards meeting the government’s regional and national targets for renewable energy.’ (EIA Vol 1 - 13.7.2).

And

‘The residual effects associated with the construction, operation and decommissioning phases of the Development have been identified as being overall negligible or of minor adverse significance with regards to socio-economic, land use and recreation effects. Whilst the Development will introduce a potential £12million project into the local area, and although the Applicant has historically demonstrated a commitment to procuring local services on projects through supply chain initiatives, there is uncertainty as to what proportion of the overall project costs would be spent in the local economy and therefore what level of benefits would arise.’ (EIA Vol 1 - 13.8.1)

With the obvious downsides of:

Loss of a very important recreational resource.

Risk of damage to unique and irreplaceable habitat.

Major disruption to local community and businesses.

I fail to see how this conclusion has been reached.

The Planning Officers report appears to have not fully investigated all aspects of the application (particularly that involved with construction traffic). Left a large number of concerns to be dealt with after planning permission has been granted (such as effect on kayaking and fisheries). Not fully considered expert opinion sent in objection letters (such as the Woodland Trust’s and Snowdonia Society’s concern over environmental damage and Save the Conwy expert’s information with regards to the danger posed by a new weir).

The Planning Officers report shows either a lack of thoroughness and use of a critical eye when assessing the application or a bias in favour of schemes of this nature.

NOTE: text in red is taken from the planning officer's report, text in blue from the Snowdonia National Park Development Plan.