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Cambrian Mountains Society

Press Release

Date: 4th January 2012

Public Consultation Responses on the draft TAN8
Analysed by the Cambrian Mountains Society

1. The Cambrian Mountains Society has announced the results of its comprehensive analysis of
the responses to the Welsh Government's public consultation on the draft Technical Advice
Note 8 (TAN 8). The final version of this controversial document led to the proposals for the
establishment on the uplands of Wales of what Welsh Government consultants called
'turbine landscapes'. As a result of their analysis the Society is calling for a new review of
TAN 8.

2. Only 10% of respondents supported the draft TAN 8 in what is thought to be the largest
number of responses to any Welsh Government consultation. 90% of the close to 1700
responders were against the whole or part of TAN 8. The responses were notable for the
number of individuals who responded, rather than organizations. 94% of these responses
were against TAN 8 in whole or part. Their views were almost wholly ignored in the final

3. Despite the overwhelming opposition to the draft document the final TAN 8 was if anything
strengthened further in favour of turbine development on the Welsh uplands.

4. Many responders criticised the timing of the Consultation and local community councils who
responded complained that they were left out of the formal arrangements. The draft was
published just days before, under the Welsh Government's own regulations, the need for a
Strategic Environmental Assessment of such a policy came into effect on 21st July 2004. Calls
for TAN 8 to be the subject of a Strategic Environmental Assessment owing to its nature and
scale were not answered by the Welsh Government.

5. Despite the views of the vast majority of responders to the Consultation, landscape quality
was not considered in the selection of areas for turbine development other than to rule out
National Parks and AONBs. Remarkably the Countryside Council for Wales (CCW) was not
involved until the public consultation stage. Thus areas which CCW as the Welsh
Government's statutory adviser on landscape classifies as of outstanding landscape quality
are categorized in TAN8 for turbine developments and a future as 'turbine landscapes'. Even
a prospective wind turbine developer's response was to express unease about turbines
being proposed 'very close to the nationally acclaimed Pumlumon range'. This has caused a
great deal of public anxiety about the policy.

6. On the important issue of grid transmission National Grid Transco expressed particular
concern that it had not been considered in the planning. The Welsh Government's response
was that the issue had to be considered outside TAN 8. This is analogous to constructing a
reservoir without any consideration of where the main water pipes have to go. It has a direct
relevance to the problems in Mid Wales to-day and which contributed to the largest ever
demonstration outside the Welsh Assembly in Cardiff last summer.

7. Other problems arising from the current application of TAN 8 were envisaged by many of the
responders. In their responses turbine developers referred to problems of transmission and
difficulties of access on public roads.

8. The work underpinning the document was undertaken by international consultants Arup
who considered it would apply for 5-7 years. Since that report turbine heights have
increased from around 160 feet to around 450 feet, public perceptions have developed on
the issue and other technologies have developed too as well as the UK government's energy
policy. Problems have arisen on transmission and other issues. The Cambrian Mountains
Society therefore calls for the Welsh Government to instigate a formal review of the
application of TAN 8 and to apply to it the Strategic Environmental Assessment which its
own regulations would normally require.

1. The controversial policy on establishing wind turbines and associated transmission lines in
the Welsh uplands is based on the Welsh Government's TAN 8 (Technical Advice Note 8) the
basis of which has been recently the subject of criticism in the Welsh Assembly, in Parliament
and was the cause of this summer's largest demonstration ever outside the Welsh Assembly
in Cardiff

2. The Cambrian Mountains Society have analysed the responses to the public consultation on
the draft Tan8 circulated in July 2004 and have produced the only numerical analysis of the
responses. The analysis was carried out by 8 analysts from the Cambrian Mountains

Society who between them examined each of close to 1700 responses to the

3. The results of the analysis show the overwhelming opposition to TAN8 expressed in the
consultation responses. Responders' comments are as relevant to-day as at the draft stage
of Tan8.

4. Further detail on the Cambrian Mountain Society's analysis and pdf files containing the
responses can be viewed at