E-mail received by the Planning Inspectorate from Mrs Linda Dawes below:
This scheme is the wrong scheme and in the wrong location and objections to it are legitimate and substantial. It will not deliver any benefits to the area in terms of either jobs or cheaper electricity but will be of serious detriment to the tourist industry, which does provide local employment. It has adverse environmental, social and economic effects which will be irreversible. To date Wrexham Power Limited?s initial consultation has been woefully inadequate and the information they have put into the public domain has been such that there are many, significant even at this stage, questions unanswered by them.
I apologise if the points I have made below have been made by others or seem lengthy although I do intend to make a more detailed submission to you and all other concerned bodies at the time of formal consultation. However, I hope this summary will serve to indicate my strong opposition to this scheme.
1. The argument that the power station is necessary to meet a demand for local electricity is simply not true. The lights are not in danger of ?going out? in North Wales. Indeed, the power stations at Connah?s Quay 12 miles from Wrexham, supplies half Wales? needs and is, currently, an underused facility. The 'need' referred to by Wrexham Power Limited as one of its rationales in support of its application doesn?t exist. They are proposing 1200w Power Station which could supply 1.25 million homes! In addition Wales is an exporter of the energy it produces. It is reasonable, therefore, to assume that whoever owns and runs the power station will have no choice but to feed its electricity into the National Grid, to supply areas of the U.K where there is a need e.g the South East. If this doesn't happen then what will be done with the surplus power generated ? Or is this a power station that will operate below capacity, at little profit, because there is no demand for its output The notion that it will be transmitted to the Industrial Estate is another that is challenged below.
2. Are the lights really going to go out? I would also challenge the rather alarmist view current in the media that the lights are ever going to go out given the number of power stations which at the time of writing are either approved , about to upgraded, replaced or built. The Planning Inspectorate know better than I the list of approved or awaiting approval power stations and schemes but a list of these is available by reference to the Friends of the Earth website.
3. Have the National Grid or Scottish Power been consulted as to what will be done with the excess of power which this scheme will produce? Has either made any expression of doubt that they are not able to continue to provide energy to the Wrexham area sufficient to meet demand? Perhaps demonstrating their own inexperience WPL originally were rather cavalier in their assertion that the existing power lines would be adequate to cope with the electricity generated by the new power station. It is now revealed that connection to the National Grid will require the erection of an extensive 400kv connection line carried by 50m pylons across unspoilt countryside. Given that Wrexham Power Limited does not seem to have any track record in this field who will maintain the pylons and guarantee the lines remain in working order? No information is forthcoming as to the expertise of Wrexham Power Limited in this field are so it is reasonable to question their credentials with regard to a project of this size.
4. Where is the evidence that this company, which incorporates Wrexham into its name only for local credibility, looked at other sites, where the infrastructure in already in place and where there is immediate access to the National Grid? Have these been considered and if they have why have they been.
5. WPL themselves have now admitted that their scheme is not CHP, as was initially promised but will be a standard Power Station unable to claim either green credentials or an efficiency greater than some older power stations still in use.
6. Yet again Wrexham Power Limited must be challenged about their justification for their scheme as one of answering a ?need?. It is glib to say that the Industrial Estate ?needs? more power but on what data do they base their assertion? They have themselves admitted that without the building of a costly infrastructure on the estate that the most they can guarantee is a supply of hot water which will not even be pumped to the individual businesses. Nor, without costly updating of the power lines, will energy from the proposed power station be transmitted directly to businesses on the Industrial Estate. Instead, there will be a potentially ludicrous situation whereby energy from the power station will be fed into the National Grid and returned into the Industrial Estate by the existing power lines. Electricity is currently supplied, to the Industrial Estate by Scottish Power. Is Wrexham Power Limited planning to set themselves up as a rival energy supplier offering cheaper rates with an independent electricity distribution system to that of Scottish Power?
7. There are better options for Wrexham, which would accord more with the Welsh Assembly pledge for a greener Wales which seem not to have been considered. The Industrial Estate is ideal for a genuine CHP plant as is common in Scandinavia. This could be a more modest scheme but could be genuinely low carbon, highly efficient and possibly fuelled by biomass or biogas from an anaerobic digester. This would make a positive contribution to the obligations of the UK in C02 reduction.
8. Much has been made by WPL of the economic advantages the building of the scheme will bring to Wrexham but this shows no understanding of the area which is not surprising given Wrexham Power Limited does not have any meaningful connection with either Wrexham or Clwyd. Any construction works will, it is reasonable to assume, be done by a contractor who will bring in a skilled work force from out of area which will be transitory. The 'gang' will be moved on to the next project when building is complete leaving the Power Station to be run by a small, already skilled, technical team recruited from other power stations.
9. The tourist industry is healthy, sustainable and making a positive contribution to the regeneration of this part of North Wales and this scheme will be detrimental to further development. People are keen to visit this rural and unspoilt area, close to Chester and accessible from Liverpool, by successful businesses such as The Plassey, modern hotels, for instance Holt Lodge, unique landmarks of which the Postcysyllte Aqueduct (a World heritage Site), National Trust at Chirk Castle and Erdigg, Bangor-on-Dee Racecourse are just a few examples. By contrast the Power Station and the associated pylons and transmission lines will have no mitigating social or economic benefits as I have already argued. It is on the edge of farmland, in open country side, adjacent to a Primary School and will be a blight on the lives of all who live and work within its shadow and deter those who would visit the area for its unspoilt beauty.
10. Given that the public has been told that ?we are running out of gas? how sustainable is a gas fired power station? I think we, the residents of this area, could be forgiven for suspecting that this scheme is merely a ?front? for another company, as yet unknown, to begin ?fracking? in the area. Planning permission is still in place for investigations to begin not five miles from the Bryn Lane site so my misgivings as to a possible hidden agenda are not misplaced.
11. WPL have made claims about Carbon Capture to create an impression that their proposal will reduce the carbon footprint of the Power Station, the most effective way of effecting a reduction is for the Power Station not to be built in which case there would be no carbon footprint. As yet WPL has not made it clear what technology is to be used to capture the carbon and it has remained silent, to date, on something which is clearly going to be yet another consequence of this scheme. i.e the need to lay a huge pipeline between Wrexham and the coast, a distance of 15 to 20 miles. This will involve more disruption to more communities who may put up as strong an objection to pipelines across their properties as communities affected by the power scheme are doing now. Have Wrexham Power Limited got sufficient funds for what could be a substantial bill for compensation payments?
12. The lack of published consideration given to the management of the inevitable increase in CO2 emissions is of enormous concern. The area over which the smoke from the chimney stacks is largely agricultural and natural country side and we who live here have understood that preserving the environment and following a Green Agenda has been a priority for those who represent us at both local and national levels. This has been a significant first step to reverting the image, and reality, of Wales as a ?dirty part of Europe?. This image will once again be tarnished by an additional CO2 emission 5 million kilograms a day released into the atmosphere. Will this not affect any grants that may be forthcoming from the EEC for Rural Development?
13. Wrexham Power Limited has no record in completing a project of this magnitude. Indeed, it is hard to find any evidence that it exists as an entity at all. Despite its name this scheme is actually being put forward by property developers in London and Birmingham with shareholdings from offshore ?shell? companies in Bermuda and Luxembourg. These are companies whose portfolios do not include the completion of projects of this magnitude. If Wrexham Power?s application is successful is there anything to prevent them selling on the approved plan to another company, as yet unnamed or unknown, to build the power scheme and profit by it? This is germane to my opposition to this scheme as it is hard to be less than cynical about a company whose only link with the area is to adopt its name on the basis that this lends it application sufficient credibility when discussing local needs. I would urge that there is some scrutiny of the companies involved in this scheme as it does have bearing on the possible integrity of the project.
14. WPL has justified the ?southern route? as the one most likely to be used for the transmission lines and pylons because there is already an electrical connection. This is true but the pylons which exist, and which are small enough and well sited enough to blend into the countryside, will have to be replaced by far bigger ones which will make more impact on the landscape than those already there. How does the existence of smaller pylons justify their replacement by bigger ones?
15. Consultation has been limited and superficial. Letters to Wrexham Power Limited do not get a response and questions remain unanswered. Only diligent research by those who have access to computers and time to use them has revealed the sketchy details that Wrexham Power Limited have been prepared to put into the public domain. There has also been a misrepresentation of the number of landowners consulted with regard to access to their land for the purposes of surveying the proposed 'corridor' along which the pylons are to be erected. At the time of writing to you I know of one landowner, whose land is crucially placed on the route apparently favoured for pylons, has had no contact from Wrexham Power Limited
16. The effect of a power station and pylons on wild life close to the River Dee could be devastating. The area is a habitat for swans and geese who follow the same line every year. This pattern, essential to their survival, will be impossible to sustain given the huge obstruction of the power station, chimneys, pylons and power cables that this scheme will impose.
In conclusion I am confident that you are giving the close scrutiny I, and others, have asked you to give to this application. I am disappointed that Wrexham Power Limited has, apparently, been given permission to go on the land which will be built on by pylons against the wishes, in some cases, of the landowners. Perhaps you could advise us how best to focus our opposition so that this unnecessary scheme is not allowed to proceed. I am sure there will be other, more worthy applications such as warehousing or distribution centres for the proposed site that will make full use of the new road system and offer genuine economic potential for the area.
Response from the Planning Inspectorate:
We appreciate being informed about Nationally Significant Infrastructure Projects (NSIPs); however as you are aware the pre-application stage of the process is mainly driven by the applicant. We will keep your correspondence in relation to Wrexham Energy Centre application on record at this stage.
I understand from your email that your comments relate to the project as a whole as well as the non-statutory consultation currently carried out by the applicant.
Firstly, please may I advise you that if you feel that consultation carried out is in any way inadequate , or should you have any other concerns about consultation, that you raise them with your local planning authority/ies.
Once the application is formally submitted, the Planning Inspectorate will then request comments on the applicant?s adequacy of consultation from the local planning authorities in the surrounding area regarding the proposal. As you know local planning authorities play an important role within the planning processes by representing their local communities. If the application is accepted for examination, you will have an opportunity to raise your comments directly to the appointed Examining Authority (the Planning Inspectorate). In order to be involved in the examination, you will be invited to make your comments by submitting a relevant representation that will give you a status of an Interested Party 'IP'.
If the application reaches the stage of the examination the appointed Examining Authority 'ExA' will invite the relevant local planning authorities to submit a Local Impact Report (LIR). The purpose of such a document is to explain the views of the planning authorities on whether the proposed development would have a positive or negative impact on their area. I suggest that in the meantime your concerns in relation to the proposed application are raised with the local planning authority that can potentially be included by the local authority in such a report.
As you may know, the examination stage takes a form of consideration by the ExA of written representations as well as oral representations raised at the hearings. Please note that ExA considers the application as a whole as well as comments raised to the applicant at the pre-application stage and submissions made by IPs at the pre-examination and examination stage of the application. Moreover before the application is formally submitted for consideration, the applicant must be fully satisfied that application meets the satisfactory standards; that includes compliance by the applicant with the provisions of Chapter 2 of Part 5 (pre-application procedure) of the Planning Act 2008 and any applicable Regulations. It also means having regard by the applicant to any consultation responses and issues raised during applicant's pre-application consultation. More importantly the applicant must ensure that their application is consistent with the guidance contained in the National Policy Statements (NPS).
You may wish to look at the National Policy Statements (NPSs) such as EN-1; EN-2; EN4 and EN5 that are relevant to specific types of NSIP projects. Individual NPS sets out government?s objectives for the development of nationally significant infrastructure.
National Policy Statements are available from:
Advice Note 8.1 on how the process works available from link below:
May I also suggest that you continue to contact the developer directly in order to raise your specific comments about that application. I am including the applicant's details below: