Below are the letters from the Llandovery and Llandeilo groups sent in response to the public consultations. (Jump to the Llandeilo response letter)
Transcription of the letter sent to Green GEN Cymru / Bute Energy by Llandovery Pylon Community Action Group:
19th April 2023
Dear Sirs
Introduction
We refer to the local public consultation (“the Consultation”) by Green GEN Cymru (“Green GEN”), part of the Bute Energy group, in respect of the proposal to erect 132KV pylons in the Towy valley to link the proposed (subject to planning permission) Nant Mithil Energy Park to the existing National Grid transmission line in Carmarthen (the “Pylons Proposal”).
The purpose of this letter is to provide an initial response to the Pylons Proposal by the Llandovery Pylon Community Action Group (“the Llandovery Community Group”). The Llandovery Community Group is a grouping comprising local businesses, farmers, landowners and residents in the Llandovery area who represent the views of the local community and have come together to oppose the proposal to construct a network of pylons through the 60 miles of the unspoilt Towy Valley.
The Llandovery Community Group is one of a number of community groups formed along the proposed route of the pylons who are united in their opposition to the Pylons Proposal. The community groups are not opposed to green energy but to the pylons and the significant harm they would do to the economy, visual landscape and cultural heritage of the Towy Valley.
This response, set out below, is at a high level and we reserve the right to make further comments and objections to the Pylons Proposal. Furthermore, it has only been possible to raise high level comments at this stage given the lack of detailed information and meaningful engagement by Green GEN in relation to the Pylons Proposal.
Our comments on the Consultation process and the overall Pylons Proposal are set out below. However, in summary, we consider the Consultation was flawed and biased and we are strongly opposed to the Proposal. We also consider this to be the overwhelming view of the approximately 700 people who attended the Consultation.
Comments
Defective Consultation Process
The Consultation process was flawed and biased. We took written feedback during the Consultation (which we are happy to produce to the planning inspector) from those attending and the overwhelming view expressed to us was that the Consultation process was defective and biased including for the following reasons:
For all the above reasons the consultation has failed to demonstrate that the Proposed Pylons would comply with the Holford Rules and national and local policy. It has failed to demonstrate that designated and non-designated heritage assets and their setting would not be harmed and no information has been provided for the community to understand any impacts on other matters such as ecology, economy and health.
Negative Visual and Landscape Impact
The Towy Valley is an important and valued landscape. It is defined as a Special Landscape area within the Carmarthenshire Local Development Plan (“LDP”), a Registered Historic Landscape by the Dyfed Archaeological Trust and is noted by Natural Resources Wales (“NRW”) as being both scenically and ecologically outstanding. Indeed, NRW considers the Middle Towy Valley in Llandovery is outstanding and could be considered important at a Wales level. This is due to the scale of the landscape and its juxtaposition between upland and lowland.
Pylons of 27m in height, as set out in the Pylons Proposal will have a devastating impact on Llandovery and the surrounding areas. They will also significantly affect the wider landscapes of the upper Towy Valley and Irfon Valley. The proposed route and Green GEN preferred alternatives follow and crisscross the Towy Valley, which is largely unspoilt, thereby increasing the visibility and negative impact of the Pylons Proposal. In addition, the Irfon is a narrow beautiful valley. The pylons will completely dominate these preserved landscapes appearing as an incongruous industrial addition to an area characterised by its unspoilt, rugged and open rural landscapes.
You have failed to produce any images of what the landscape would look like following implementation of the Pylons Proposal. You have not carried out a visual impact assessment. Therefore, we reserve the right to take part and comment on this in the future should your Pylons Proposal proceed.
The above clearly outlines that the landscapes around Llandovery and the wider Towy Valley are of high amenity value. The repeated criss crossing of the valley will necessitate larger more imposing angle towers adding to the already harmful impact that the pylons will have. This appears to go wholly against Rule 2 of the Holford Rules which states that when considering the routeing of new high voltage overhead transmission lines in areas of high amenity value or scenic interest, it should be avoided by deviation. This rule confirms that angled towers are ‘more massive structures’ which will destroy the unspoilt, scenic and rural landscape of the Towy Valley.
Material Impact on Llandovery
The proposed route almost encircles Llandovery. Llandovery is a small town of approx. 1500 people dating from Roman times with a preponderance of Georgian architecture. There are no buildings above 2 storeys. These pylons will therefore dwarf and overshadow this small town which is largely reliant on tourism. The pylons will be highly visible from critical local landmarks including The Castle, Llanfair-ar-y Bryn church and most of the town.
Cultural and Heritage Damage
Llandovery and the surrounding area has a large number of designated heritage assets which would be harmfully impacted upon by the Pylons Proposal. The following are an example of such assets but is not an exhaustive list:
Dolauhirion Bridge - Grade 1 listed single arch stone bridge. Your proposal is to place a pylon alongside it significantly threatens the visual integrity of this bridge.
Church of St Mary at Llanfair-ar-y Bryn – a Grade 1 listed 12 th century church with Grade II listed monument and memorial lynchgate within its grounds. Its elevated position over the valley contributes to its significance and the intrusion of pylons into this setting would harm this important group of listed buildings.
Church of St Dingat – Grade II* listed 14/15 th century church with Grade II listed lynchgate, tomb and grave enclosure within its grounds. The Proposed Pylons would be located within its setting and would be intervisible with the church and the surrounding area, harming the church and its setting.
Llandovery Roman Site – a Scheduled Ancient Monument (“SAM”) located at Llanfair-ar-y Bryn and comprises two overlapping Roman forts. These would have been built on a hill to offer enhanced and uninterrupted views of the surrounding area. Any intrusion into these views would have a harmful impact on the setting of this SAM.
Llandovery Castle – a SAM located in Llandovery on a rocky hillock. Originally it was constructed as a motte and bailey and its elevated position offered uninterrupted views of the surrounding area in order to aid its defence. Any intrusion into these views would detrimentally impact on the setting of this SAM.
Llandovery Conservation Area – much of Llandovery is covered by the Conservation Area which protects the historic and architectural nature of the town and its setting. Being a historic drovers town with strong agricultural links to the surrounding rural landscape is important to its setting. The industrialisation of the landscape through the introduction of pylons would harm the setting of the Conservation Area.
Significant Economic Impact on Tourism, Diversification and Local Service Provision
The Towy and Irfon Valleys are primarily agricultural areas, which have been encouraged by the Welsh Government to diversify. The main diversification has been into tourism because of the unspoilt, rugged, natural beauty of the area. Indeed, Llandovery is a main gateway into the Cambrian Mountains that has further tourism accommodation, ventures and businesses.
The proposed route goes straight through campsites, wedding venues, airbnbs and seasonal holiday accommodation. Clearly demand for these tourist destinations will be severely and negatively impacted when 27m pylons are installed and tourists have an option to stay somewhere where they don’t overlook pylons. These pylons will be seen the length and breadth of both valleys and the economic damage to this area is likely to be substantial.
Additionally, the proposed route will go over a number of rights of way. With regards to the Llandovery area, it will have an overbearing impact on the Cambrian Way and the Heart of Wales long distance routes that are widely advertised for their scenic qualities. This draws people to the area. Criss crossing pylons over these and other routes would detract from people wanting to visit the area to take part in outdoor activities.
In fact, anecdotal evidence suggests the Pylons Proposal is already having a chilling effect on domestic property transactions in the area. This has knock on economic repercussions on the area as it affects business and service providers who depend on these transactions. This will only get worse if the Pylons Proposal goes ahead as outlined.
Lack of Access/ Transportation Consideration
The majority of roads in the area are small and narrow and no serious consideration has been given to this aspect. We would want clarification as to how you intend to access pylon and other sites, were you to get planning permission. Will this further impact agricultural land and create yet greater visual and economic damage to the area?
Pylons
The proposed 27m pylons are inappropriate for the proposed Nant Mithil Energy Park – for which you do not have planning permission.
These pylons are being proposed to service the aspirational energy parks the Bute Group would like to establish in the future.
The status of these parks are completely uncertain. You have not produced evidence of funding, timescale or any certainty of planning permission.
We consider that these parks are too remote a possibility to be taken into account in respect of the Pylons Proposal, particularly given the significant harm the development will do. The pylons to be used should only relate to and be no larger than needed for a consented infrastructure. This case of need cannot be predicated on speculative schemes that are unfunded and without any of the necessary permissions.
Undergrounding and Future Technology
Technology will advance, particularly as green energy does, so these pylons will very shortly, or indeed are already, old technology and redundant. Indeed, contact has been made with pylon designers who consider such voltage lines will generally be underground in the future.
It is clear that undergrounding is the only acceptable option. However, you have sought to dismiss undergrounding as economically unviable. On what basis have you reached this conclusion and on the basis of what evidence and comparisons and over what period have you assessed viability? It is also clear that Green GEN in looking at economic viability has not taken into account the impact of wider economic or other considerations eg. taking account of the negative local impact of the Pylons Proposal. Nor is it clear over what period economic viability has been assessed and a whole life cost argument should be applied to assess viability.
Planning Policy Wales states that Welsh Government’s preferred position on new power lines is that, where possible, they should be laid underground. Future wales The National Plan 2040 states that new strategic grid infrastructure for the transmission and distribution of energy should be designed to minimise visual impact on nearby communities.
The Minister for Climate Change, Julie James MS has taken the view that undergrounding should be used wherever possible. We are strongly of the view it is possible in this case. As such, why have your proposals only dealt with an overhead line based on pylons?
Undergrounding would significantly lessen the economic impact on the local community which is already struggling economically.
Health Issues Ignored
Green GEN have not considered or taken into account health concerns, particularly cancer and mental health issues of those residents who have large pylons sited close to them.
No Community Benefit
We strongly object to your assertion that the Pylons Proposal will have community benefits.
The Bute group’s connection with Wales is tenuous at best and its interests in the long term wellbeing of the area seemingly non-existent. This is demonstrated by the Pylons Proposal. In fact, the founders and directors of the Green GEN parent group are all based in Scotland with no links to Wales. The investors, CIPartners are a Danish Investment company with no links to Wales or the UK.
We also consider that there be no significant local jobs or wealth creation and profits from the Pylons Proposal will flow in their entirety to Scotland and Denmark.
In this regard please provide details of the projected FTE jobs you believe will be created for Welsh residents for the construction phase of the Proposal and for future operations.
In addition, the advertised £7500 per MW appeared to diminish during the consultation process. There was confusion between Green GEN / Bute Energy representatives at the consultation events as to whether the £7500 would be per installed or generated MW. It is common knowledge that renewable energy installations do not perform to their installed capacity, as such if the community fund is based on generated MW this already diminishes the fund. Further, whilst marketed as £7500 per MW the majority of this would stay with the communities local to the energy parks, as such only a maximum of £600,00 would be available for some 60 miles of communities harmed by the Pylons Proposal. We believe, if necessary, this fund would be better spent going towards undergrounding the cables communities are not left with an unsightly scar on the landscape for decades to come.
As the Bute group is a private group of entities there is no certainty that it will be secured for the future.
Please provide full details of the proposed compensation arrangements and details of the Community Fund and how it will be divided amongst the communities impacted and how that Fund compares with the projected financial benefits to your shareholders
It is worth noting that the Welsh Government wish to promote a “circular economy” but there is no circularity in this Pylons Proposal for the reasons stated above.
Environmental Impact
There has been no provision of information by Green GEN relating to environmental impact and as such it is impossible to comment on the likely impact.
No Track Record or Experience
The Bute group has no previous experience in operating a distribution transmissions infrastructure of this sort. It is a start-up looking to carry out a huge infrastructure development that will significantly and negatively change the face of mid-Wales.
Without any track record, it seems an extraordinary and unreasonable risk to the communities, economy and landscape of mid Wales to permit an inexperienced start up venture to attempt to undertake this development.
For all the above reasons we are strongly opposed to the Pylons Proposal and any future application for planning permission based on that proposal
For and On Behalf of Llandovery Pylon Action Group
Transcription of the letter sent to Green GEN Cymru / Bute Energy by Llandeilo Community Group Against Pylons:
26th April 2023
For the attention of Bute Energy/Green Gen Directors
Dear Sirs
We refer to the local public consultation (“the Consultation”) by Green GEN Cymru (“Green GEN”), part of the Bute Energy group, in respect of the proposal to erect 132KV pylons in the Towy valley to link the proposed (subject to planning permission) Nant Mithil Energy Park to the existing National Grid transmission line in Carmarthen (the “Pylons Proposal”).
The purpose of this letter is to provide an initial response to the Pylons Proposal by the Llandeilo Community Group Against Pylons (“the Llandeilo Community Group”). The Llandeilo Community Group is a grouping comprising local businesses, farmers, landowners and residents in the Llandeilo area who represent the views of the local community and have come together to oppose the proposal to construct a network of pylons through the unspoilt Towy Valley.
The Llandeilo Community Group is one of a number of community groups formed along the proposed route of the pylons who are united in their opposition to the Pylons Proposal. The community groups are not opposed to green energy but to the pylons and the significant harm they would cause to the economy, visual landscape and cultural heritage of the Towy Valley.
This response, set out below, is at a high level and we reserve the right to make further comments and objections to the Pylons Proposal. Furthermore, it has only been possible to raise high level comments at this stage given the lack of detailed information and meaningful engagement by Green GEN in relation to the Pylons Proposal.
Our comments on the Consultation process and the overall Pylons Proposal are set out below. However, in summary, we consider the Consultation was flawed and biased and we are strongly opposed to the Proposal. We also consider this to be the overwhelming view of the 600 plus people who attended the Consultation at the Civic Hall in Llandeilo.
Key Issues
Defective Consultation Process
The Consultation process was flawed and biased. We took verbal and written feedback during the Consultation (which we are happy to produce to the planning inspector) from those attending and the overwhelming view expressed to us was that the Consultation process was defective and biased including for the following reasons:
For all the above reasons the consultation has failed to demonstrate that the Proposed Pylons would comply with the Holford Rules and national and local policy. It has failed to demonstrate that designated and non-designated heritage assets and their setting would not be harmed, and no information has been provided for the community to understand any impacts on other matters such as ecology, economy, and health.
Material Impact on Llandeilo
The proposed route sweeps along north and west of Llandeilo. Llandeilo is a small town of approx. 2000 people with small business and sits adjacent to the westernmost point of the Bannau Brycheiniog (Brecon Beacons) National Park. These pylons will therefore overshadow this small town which is largely reliant on tourism. The pylons will be highly visible from critical local landmarks.
Pylons: Impact on Visual Landscape
This landscape is unique, exceptional, and very beautiful. Designated a Special Landscape Area by Carmarthenshire County Council, Natural Resources Wales describes the meandering river and accompanying valley as “scenically and ecologically outstanding”. There are the ‘finest’ 360 degrees views from many sites within the Valley, including Merlin’s Hill, Paxton’s Tower, Dryslwyn Castle, Dinefwr Castle and the Iron Age Fort at Garn Goch. Pylons are a recognised environmental blot. They are being removed and undergrounded in nationally important landscapes in England and Wales under the Visual Impact Provision Project. The Towy Valley should be afforded the same protection, respect and reverence. The Welsh Government’s preferred position on new power lines is that “where possible, they should be laid underground”. This presumption should apply to the Towy-Usk plan. Green GEN’s negating of this presumption, on “viability” grounds, has not been evidenced in the informal consultation documents nor at the informal information events.
Pylons: Impact on Heritage and Historical Landscape
This valley’s heritage and cultural significance to Wales cannot be overstated. The history of the valley tells of some of the most important parts of the history of Wales. There are iron age hill forts and roman encampments. The Lord Rhys ruled Deheubarth from Grade 1 listed Dinefwr Castle; Owain Glyndwr battled against the English at Grade 1 listed Dryslwyn Castle; Grade II listed Paxton’s Tower has links to Lord Nelson. The Battle of Cadfan, which saw Prince Llewelyn (the Last) defeat the English forces, took place near Broad Oak in 1257. Other Grade II listed buildings include Golden Grove Park and Mansion, Aberglasney Mansion and walled Gardens, Cwrt Henri (Court Henry), Hafodneddyn, Llangathen Church and Llanarthne church. The Towy Valley is a ‘registered landscape of outstanding historic interest in Wales’. Painters and poets have been inspired by this landscape for centuries. John Dyer’s famous poem, “Grongar Hill” is set near Dryslwyn; JMW Turner produced watercolours of Llandeilo and Dinefwr; and contemporary artists like William Wilkins, Meiron and Joanna Jones continue the valley’s creative arts tradition. Many regard the proposal to place pylons in such an inspiring landscape to be nothing short of cultural vandalism.
Pylons: Impact on Economy (Tourism)
Plans to put pylons in an area which is being developed for tourism is at odds with National and County economic strategy. More than £19 million pounds, including Welsh Government money and £16.4 million UK Government levelling up funding, has been invested in the Towy Valley Path, a cycle trail from Carmarthen to Llandeilo. The Council hopes that the Towy Valley Path will help to decarbonise travel and expand tourism. According to Council projections, the Towy Valley Path has the “potential to generate £4.4 million a year for the local economy”. Tourism is worth approximately £412 million per year to Carmarthenshire as a whole. Pylons in the valley would have a detrimental impact on camping and caravan sites, visitor accommodation, holiday cottages, restaurants, pubs and cafés. There could be a significant impact on attractions like the National Botanic Garden of Wales, Abergasney Gardens, Dinefwr Park, Gelli Aur Arboretum, The British Bird of Prey Centre and Paxton’s Tower. Overhead lines would adversely affect tourism and visitor revenues. Green GEN’s proposal clashes with Carmarthenshire County Council’s strategic economic plan. The elected Councillors have unanimously voted on a motion which says ‘No’ to pylons. Green GEN to rethink the Towy-Usk plan.
Pylons: Impact on Economy/Welsh language (Agriculture)
The area is known for its fine quality alluvial soil, which is valuable for grazing and silage. Generations of farming families have deeply held attachments to the land here and are regarded as custodians of the valley. There is an agricultural college based at Gelli Aur / Golden Grove. Pylons and overhead cables could mean considerable disruption and land loss for farmers. Safety precautions to prevent flashover from lines may also mean changes to land use, possible changes to field access routes, and safety modifications regarding the use of high agricultural equipment. The Energy Network Association’s safety guidance advises farmers to establish six metre exclusion zones around 132kv lines. The top of the pylons’ concrete bases will be five metres square, so there will be a considerable adverse impact on useable land and agricultural yields. Diversity will be hampered, relevant to the sustainability of farms, impacting on the Welsh language if traditional farm holders have to relocate for work.
Pylons: Impact on Economy (Property Values)
Property values are bound to be affected by Pylons. There is no compensation for the owners of properties and farms and tourist/ visitor related businesses which will not carry pylons, but which are nearby or overlook pylons. Owners of land carrying pylons will receive some compensation, but the statutory compensation scheme is not expected to compensate for the real loss in value and already property owners have lost arranged sales confirming the likely effect on saleability as well as value.
Pylons: Impact on Ecology/Biodiversity
The valley is a nationally important breeding and feeding ground for some endangered and many protected birds, mammals, invertebrates, aquatic life and fungi. The River Towy is a site of special scientific Interest (SSSI) and the surrounding land is in a special conservation area (SAC). Waun Las (Llanarthne), and Dinefwr Park (Llandeilo), are National Nature Reserves. Parklands, meadows and ancient hedge networks form unique connected habitats which sustain biodiversity. The Towy boasts Wales’ largest breeding population of tree sparrows and is home to Hairstreak butterfly, Riffle beetles, water voles, otters, Plovers, Waxcap mushrooms and rare orchids. Pylons pose particular electrocution risk for water feeding birds with larger wing spans. Whooper and Mute Swans, Red Kites, Egrets and Herons are all present here.
Pylons: Impact on Health and Wellbeing
The precautionary principle should prevail. Pylons, and overhead wires should not be placed anywhere near homes, schools, or nurseries. The pylon route goes close to schools and nurseries. Research relating to power lines and human health is still being investigated. The International Agency for Research on Cancer (IARC) has classified power-frequency magnetic fields as “possibly carcinogenic”. Even the Energy Network Association, the body which represents operators of electricity wires in the UK, acknowledges that there is a statistical association between unusually high magnetic fields and childhood leukaemia. There is also a need to consider social wellbeing and mental health. Anecdotal reports confirm the proposals have caused considerable stress and anxiety.
Undergrounding
Technology will advance, particularly as green energy does, so pylons will very shortly, or indeed are already, old technology and redundant. Undergrounding is the only acceptable option. However, Green GEN has dismissed undergrounding as economically unviable. It is not clear on what basis this conclusion has been drawn with reference to time period and comparisons. No account has been taken of the impact pylons will have on wider economic and other considerations. Planning policy states that Welsh Government’s preferred position on new power lines is that, wherever possible, they should be laid underground. Future Wales The National Plan 2040 states that new strategic grid infrastructure for the transmission and distribution of energy should be designed to minimise visual impact on nearby communities. The Minister for Climate Change, Julie James MS, has taken the view that undergrounding should be used wherever possible. This is certainly possible and desirable in the case of the Towy Valley. The money currently allocated for community benefit would be better spent on undergrounding.
Summary
The Towy Valley holds a special place in the hearts of thousands of people living and working in the area. We want to protect, preserve and enhance, the outstanding beauty and features of landscape, the heritage and historical landscape, the unique identity of the Towy Valley , its biodiversity, and its economy based directly and indirectly on agriculture, tourism, visitor revenue and a healthy property market. Green GEN Cymru, we urge you to amend the Towy-Usk plan.
…………………………………………………………
Daljit Singh
For and On Behalf of Llandovery Pylon Action Group
We came together because of a shared concern: We worried that this pylon proposal is being created in haste, before a coherent national strategy for sustainable energy infrastructure has been consulted upon and with no apparent benefit to the people of Wales whose homes and livelihoods would be affected. As the plans were released and information about Bute Energy became available, we were increasingly concerned that this would be an exploitative and speculative development, purely for profit with no consideration for the environment or culture of Wales. We were even more worried about what the consequences might be of a firm with no track record, funded by overseas commercial investors, being permitted to undertake such a huge development.
The more we learned, the more worried we became. We were alarmed to learn that the proposals will in no way future-proof the Welsh distribution network. Any energy that moves through this new pylon superhighway will join the grid in the tiny hamlet of Llandyfaelog, but the limitations of the distribution network, which is already operating at or near full capacity, means that very little of this energy can be utilised in Wales. Nothing in these proposals will improve the capacity for local generation to connect to the grid, nor shore up existing infrastructure already at risk from overload as electric car technology becomes commonplace.
Recent experience with the water industry in the UK has demonstrated the consequences of a profit-before-people mentality when it comes to vital national infrastructure. We feel that it is our duty to vigorously question such proposals and defend our landscape, heritage, biodiversity and economy from firms whose track record and intent is unknown.
Instead, we will campaign for this proposal and developments like it to be stopped until policy makers are willing to consult on the national energy mix, and fight for the best compromise for our region and the future generations that will live and work here.
We don’t believe that this compromise needs to include pylons. If you agree with us, please JOIN US.