Environmental Assessment

In their environmental assessment for Rhyl Flats the developers acknowledge that the proposal would cause substantial or substantial/moderate magnitude of change in views in the coastal zone between Great Orme and Abergele,

According to their assessment there will be significant effects on views from many viewpoints and facilities along the coast from Great Orme to Llanddulas.

For landscape and seascape character they predict a significant effect on:

•   "The character of Llandudno Bay and Colwyn Bay

•   The character of the coastal slopes from Llandudno to Old Colwyn

•   The limestone farmlands from Old Colwyn to Abergele

•   The limestone escarpment and hills - Little Orme, Bryn Euryn and Cefn-Yr-Ogof

•   Views for residents and visitors in sea-front and hillside properties in Llandudno, Penrhyn Bay, Rhos-on-Sea, Colwyn Bay, Old Colwyn and Llandudno and sea-front properties in Rhyl.

•   Views for people on Llandudno and Colwyn Bay promenades and views for people on the closest beaches such as in Llandundo Bay and from the long stretch of beach from Penrhyn Bay to Rhyl.

•   Views for visitors to the Great Orme visitor attractions, Llandundo Pier and the Sky Tower; and views for visitors to three elevated vantage points -Great Orme, the Little Orme, Bryn Euryn and Moelfre Isaf.

•   Views for motorists on the A55.

•   Views for rail travellers on the coastal railway between Colwyn Bay and Towyn.

•   Views for cyclists on the Sustrans Route no 5 and walkers on the coastal section of the North Wales Path.

•   Views for marine-based receptors in Llandudno Bay and Colwyn Bay seascape marine zones, for example, people on the shipping and ferry routes, on fishing boats, yachts and those involved in in-shore water-based activities."

The developer for Gwynt-Y-Mor acknowledges "The potential for some significant effects on Llandudno Bay and Colwyn Bay seascapes. Significant visual effects are also predicted for people at Llandudno." They describe the effects on the seascape in Llandudno Bay under three headings: sensitivity of impact, magnitude of effects and significance.

Sensitivity of impact on Llandudno Bay is rated moderate/high. Magnitude of effects on Llandudno bay is described as medium and significance is described as moderate/substantial.

We believe this assessment consistently underestimates the impact and is misleading.

Additionally the Npower assessment does not take account of the impact of the Rhyl Flats development whose assessment is set out above, despite the fact that Npower will be the developer of both sites. This is doubly misleading.

It is a matter of grave concern that the proposal does not provide a combined environmental assessment of the impact of both developments and that the developer is proceeding on the basis of misleading information to secure public and DT1 planning approval.

We do not believe this provides the basis on which the public or the DTI can make an informed judgement.

Llandudno

It is generally accepted that Llandudno bay provides one of the most beautiful natural seascapes in the world.

"In any calculus of beauty the hills and coastline of Wales are worth any Turner." Simon Jenkins.

The planned Victorian resort of Llandudno sits in an open bay between two headlands, the Great and Little Orme.

According to George Miller, post-war Land Agent to Lord Mostyn, wrote: "Llandudno is as important to the Victorian Age as Bath is to the Georgian Age and should be considered as such. The town is almost the only Victorian resort remaining in Britain which still retains its original character."

The developer's application takes no account of this unique status and character and of the outstanding natural beauty of Llandudno and its bay.

The developer predicts "Significant effects on the character of Llandudno Bay."

In effect the planned development visually encloses the open bay aspect between the two headlands, destroying its natural beauty and replacing it with the closed aspect of a fence of steel and concrete.

The wind farm would not be "a feature in the seascape" as the developers claim.

It would be the seascape.

Site of Special Scientific interest

Under the provisions of the National Parks and Access to the Countryside Act 1949 the Little Orme's headland was designated a site of Special Scientific Interest in 1960.

The purpose of the Wildlife and Countryside Act, 1981, is to safeguard or enhance the features of special interest associated with this site.

The Little Orme's site is considered "a nationally important area" being a "limestone headland with impressive sea cliffs."

The sea cliffs and adjacent land of Forth Dyniewaid and Trwyn-Y-Fuwch on the Little Orme are also designated as a site of Special Geological Interest "affording superb sections cut through an Asbian Reef - the best example of its type in Wales. According to Dribble (Rhiwledyn and Little Orme) "this reef contains rich invertebrate faunas. Its structure in relation to the sea bed and depositional and tectonic slopes has not been studied, although it is believed this reef was one of a series of apron reef-structures stretching from here to Prestatyn, on the edge of a major basin to the north. An important site with considerable research potential in terms of carboniferous sedimentation and palaeoecology."

Visibility/photo montage

We challenge the visual impact assessments provided by Npower in their photo montages.

We are concerned that Npower have only shown the visual impact of Gwynt-Y-Mor in their presentations despite the fact that they will be the developer in respect of the Rhyl Flats wind farm.

"The Rhyl Flats wind farm would occupy 30^o-40^o (degrees) of the overall panorama from sites between Rhos-On-Sea and Llanddulas, 20^o-25^o of the overall panorama from the Great Orme, 20^o-35^o from the Little Orme and a quarter of the seaward horizon from Llandudno Bay." Dr M I Hill, Head of Maritime and Earth Science Group CCW.

The Gwynt-Y-Mor wind farm will occupy 100% of the seaward horizon from Llandudno Bay, Abergele, Pensarn. From Prestatyn almost 100% of the seaward horizon will be filled by Gwynt-Y-Mor, Rhyl Flats and North Hoyle.

The impact of the wind farms will destroy the views and panoramas from the North Wales coast.

The photo montages presented by the developers are unacceptably misleading, showing the wind farms much smaller than they will actually be. Where Npower has an opportunity to show an actual photograph, as is the case with North Hoyle, they have taken the photograph, not from the promenade but inland 10 kilometres from the wind farm.

In the photo montages shown to the public during the exhibitions, many of the turbines are virtually invisible. This is at complete variance with the textual information provided in the environmental assessments.

The environmental assessments were not available during the exhibition and the public will have been unable to compare photograph and text.

It is a matter of great regret that they have published misleading photo montage information in this way which is not in the interests of open access to clear and unambiguous information.

The developer argues in his prospectus that the cumulative effect of Gwynt-Y-Mor, together with Rhyl Flats and North Hoyle, will be to lessen the perception of their overall visual impact. By this logic the more wind turbines there are the less you see. This is a perverse justification for destroying an entire seascape.

Geomorphologic Impact

There are grave concerns regarding geomorphologic processes on the Rhyl Flats wind farm site. 

Dr M I Hill, Head of Maritime and Earth Science Group, CCW in a letter to the DTi asked that they seek to "clarify level of natural variability / sediment movement, movement and stability of sand waves / bed forms, independence / interference between turbines and possible influence of turbine alignment on effects at the coast.  Clarify 7% wave energy reduction at the coast from specific wave sectors."

There are additionally grave concerns regarding the stability and dynamics of the Constable Bank, most notably changes in its form over time.  It is a major weakness in the developer's proposals that this concern is not addressed.

It is a concern raised again by Dr Hill in her correspondence with the developer.  In a letter to the DTi she stated "Understanding the extent to which the site is an erosional or deposition environment is an important constraint on, for example, the depth of burial of the cable and presumably the design and construction methods for the project as a whole"

There are also concerns regarding the onshore elements of the Gwynt-Y-Mor proposal most notably in relation to the landing of cabling and breaching of existing coastal defences referred to in the developer's environmental assessment.