"Your Energy is a leading independent wind energy developer, constructor and operator working in the UK."

(Your Energy Ltd. Website -'Generating a fresh future', 2004-2005 )*

Your Energy Ltd./Mistral opened their first UK wind power station in 2005.

"This is a very proud moment for Your Energy and its shareholder, Mistral Invest, as it [Burton Wold turbine array] is the first project in the company's short history to begin construction.."
(Richard Mardon, YEL Press Release, 2 June 2005).

*Your Energy is now trying to rebrand itself and has toned down some of its more ridiculous claims. It now states:

"Your Energy is an independent UK based renewable energy company. It was established in 2001 and is owned by Mistral Invest Limited, the wind sector investment vehicle of an international shipping company." YEL, 'Generating a fresh future' (website , 2007).

They omit to mention that YEL, Mistral and CNC (the shipping company) are registered in such offshore tax havens as the Bahamas and the Marshall Islands.

"The Moorsyde Wind Farm proposal is sized to meet your local electricity needs, meeting the equivalent needs of every home in Berwick-upon-Tweed Borough as well as 69% of those in Alnwick District. ... We aim to see the energy from our projects making a real contribution locally and thereby enhancing the sustainability of your area.

"A project of up to 14 wind turbines makes a significant contribution to local energy supply, with enough electricity to meet the equivalent requirements of 16% of Northumberland County's domestic needs.² that is equivalent to providing almost 21,000 homes with electricity from clean, economic and renewable energy."
(Your Energy's 'Moorsyde' Brochure)

"the Proposal will generate on average 49,600 to 58,800 megawatt hours (MWh) of electricity annually, equivalent to the average annual needs of 10,500 to 12,500 households - between 91% and 107% of the total number of households in Berwick Borough."
(Revised ‘Moorsyde’ Environmental Statement, 21 December 2006)

The 'Moorsyde' power station proposal is sized to maximise Your Energy's profits.

It will not contribute to the ‘local’ power supply. Any power generated will be fed into the distribution system.  Although Your Energy constantly play this 'local' theme, power can not be targeted to the local area and will not benefit the Berwick area in any way. Indeed, the erratic nature of wind power generation means that very large sums of consumer's money are being spent to strengthen the grid to cope with its sudden fluctuations. According to power engineers, ‘Moorsyde’ is more likely to mean that local power supplies become less rather than more reliable. This is especially the case now that it appears that any power from the ‘Moorsyde’ turbines would be fed into the low voltage local network rather than into Scottish Power's high voltage grid hub.

Local consumers will not get a rebate on their electricity bills or any share in the large profits generated by the ‘Moorsyde’ power station (through the trade in Renewables Obligation Certificates rather than electricity sales - see 'Renewables Obligation, and Climate Change Levy' (REF - word doc.).

YEL produced yet another set of figures (this is the seventh revision, by our count) to go with their 7 turbine revision of the 'Moorsyde' scheme. As ever, their figures are wildly at variance with the facts on the ground. They claim that, "generation forecasts are based on actual field measurements from June 2003 to June 2005 correlated to long term data at Boulmer (30 miles away) by independent consultants, Garrad Hassan.".

‘Correlating’ figures to Boulmer is laughable, it is an exposed coastal site which, as YEL admit, is 30 miles from ‘Moorsyde’. We might point out that weather records at Letham Shank weather station, at a similar height to the ‘Moorsyde’ site and only 7 km. to the north show average wind speeds of under 6 metres per second for the years mentioned above. This figure correlates to the DTI wind speed database figure for ‘Moorsyde’ and is on the margin of what is normally regarded as viable for development.

Your Energy's consultants, Garrad Hassan, state that some of their favoured Repower MM82 2MW turbines would have to operate in Mode 6, the most noise constrained mode of operation in order to meet noise limits; but they do not disclose that operating in Mode 6 can reduce the output of the turbine to 1.4MW, a 30% reduction in capacity. The fact that these turbines have to be operated so much below their capacity in order to meet noise limits supports MAG’s view that the ‘Moorsyde’ site is wholly inappropriate for wind farm development due to its very close proximity to sensitive receptors.

Despite the significant reduction in capacity caused by the need to operate in the noise constrained Mode 6, the applicant still claims a 27.8% capacity factor for the MM82 turbine. This is greater than the 25.2% and 25.5% (Ofgem 2006 and 2007 figures) achieved at Crystal Rig, 150 metres higher than the ‘Moorsyde’ site on an exposed moor in the Lammermuir Hills, where the turbines are able to operate in unrestricted mode.

Crystal Rig, 330 metres above sea level on an exposed moorland site in the Lammermuirs had a recorded average capacity factor of 25.2% in 2006 and 25.5% in 2007 (see Data from Ofgem website.) Even Your Energy must agree that 'Moorsyde', on a lowland site only 60-80 metres above sea level, is not likely to outperform Crystal Rig!

At the time the ‘Moorsyde’ scheme was announced, in October 2004, the then Chairman of Your Energy Ltd admitted that, "The fact that Felkington is on a low lying plateau means the wind conditions are relatively low ..." (Berwick Advertiser, October 2004). Three years later, without providing any data to support their claim, the applicant now states that wind speeds at the proposed site are “excellent”.

The Environmental Statement submitted with the original application claimed that the development would offset 78,225 tonnes of CO2 per annum. Now, even with the exaggerated claims about performance, the applicant is only claiming a CO2 offset figure of 14,650 tonnes at best. This is less than 19% of the originally claimed figure.

YEL's figures do not recognise that significant wind power generation requires, according to National Grid and others, ca. 65% ‘hot’ backup from fossil fuelled plant and that any power saved will not substitute solely for coal-fired plant.

The DTI, Carbon Trust, DEFRA and Ofgem all state that any substitution should be based on a ‘grid average’ carbon saving. Nor is any calculation is made for the enormous amounts of concrete used in turbine foundations - cement production emits large amounts of CO₂ (this figure would be even worse for 'Moorsyde' with grouting of old mine workings in the attempt to provide secure foundations).

You might think that even 14,650 tonnes of CO₂ sounds like a lot. However, we each generate ca. 0.33 tonnes of CO₂ per year merely by breathing. A single jumbo jet, flying from London to Miami and back every day, releases the climate-change equivalent of 520,000 tonnes of carbon dioxide a year. 'Moorsyde', even accepting YEL's dodgy output figures and without making any allowance for 65% standby or building emissions, would save a maximum of 2.8% of the emissions of a single 747 jet (using DTI/Carbon Trust/DEFRA/Ofgem recommended figure of 0.43kg CO₂ per kWh saved).

Your Energy should produce evidenced figures for their application. There has to be a limit to playing games with the figures and the public.

From: Hugh Sharman's paper in Civil Engineering journal
Download pdf file

The small, intermittent and unreliable supply from wind power in the UK can at present be covered by the safety margin of generating capacity provided by coal, gas and nuclear plants. Electricity cannot, at present, be stored to any significant degree, so, if wind generation becomes a significant factor (i.e. if many thousands more 350-500 ft. turbines are built) they will increasingly need to be backed up by conventional, fossil fuel burning power stations running on standby because wind power production is inherently unstable and difficult to forecast. The greater the installed capacity of wind power stations the greater problems it will also create in managing the supply system, as Denmark and Germany know to their cost.

The UK National Grid quite clearly recognises that BWEA claims for wind are unrealistic and that the German and Danish experience of limited substitution for fossil fuelled plant will be replicated here:

'[...] for 8000MW of wind (e.g. in line with Government's 2010 target of 10% renewables), around 3000MW of conventional capacity (equivalent to some 37% of the wind capacity) can be retired without any increased probability that load reductions would be required due to generation shortages on cold days. However, as the amount of wind increases, the proportion of conventional capacity that can be displaced without eroding the level of security reduces. For example, for 25000MW of wind only 5000MW (i.e. 20% of the wind capacity) of conventional capacity can be retired. This implies that, for larger wind penetrations, the wind capacity that can be taken as firm is not proportional to the expected wind energy production. It follows that the electricity market will need to maintain in service a larger proportion of conventional generation capacity despite reduced load factors. Such plant is often referred to as "standby plant"'.
('Fluctuating Unpredictable Output and Standby Capacity' - National Grid, 'GB Seven Year Statement' 2006)

It is worth noting that the Scottish Borders and Lothians (into whose system power will be fed) will be hugely over-supplied with intermittent wind power - 215 turbines (570.25MW) have already been built or consented, plans for another 155 (438MW) have been submitted or appealed after refusal and another 151 turbines (327MW) are in pre-planning. One suspects that the last thing Scottish Power need is a small amount of additional wind power from south of the border feeding into their network. The grid operators have strengthened the infrastructure at huge expense to handle this. The speculative developers who are creating the problem ought to be paying for this work; needless to say it is the consumer who is paying.

Hugh Sharman has examined the problems of managing a large installed capacity:

It is clear that 5 GW, just two-thirds of what is already operating and planned [for Scotland], will be unmanageable unless turbines are shut down. Such ‘wind curtailment’ is already widely used by German utilities, which have great difficulty coping with a level of wind penetration that is only 0.2 kW per capita. Curtailment of output, as a policy, is a curious solution when wind power is already three to four times more expensive than conventionally produced energy. Furthermore, when its output is curtailed, no thermal MWh are displaced, so its value is further eroded.

Hugh Sharman - Download from Civil Engineering journal (pdf file).

Just to emphasise this point, it was recently revealed that some wind power station operators in Germany are suing the grid operators because they are being shut down so frequently in order to maintain the integrity of the grid that it is beginning to hit their profits. (See the story on our Wind Power page).

Wind power also generates least electricity at times of highest demand - during periods of extreme heat and cold experienced during settled high pressure weather systems (ironically, increasing in frequency with global warming).   Wind turbine generators also shut down (or are supposed to, see the story of the high speed break up of a 40 metre turbine blade at Crystal Rig) during very high wind speeds, also an increasingly common phenomenon.

If further evidence were needed, the Tyndall Centre for Climate Change Research concluded in a recent report:

The performed capacity adequacy studies for the mid-term future UK electricity scenarios clearly show that the capacity value of wind generation plant is limited. Analysis was carried out for a wide range of wind penetrations to examine the generating capacity of conventional plant that can be displaced by wind, while maintaining a specified security level. We observed that wind generation only displaces a relatively modest amount of conventional plant, which means that in order to maintain the same level of security, a significant capacity of conventional plant will still be required.

(Ensuring new and renewable energy can meet electricity demand: security of decarbonised electricity systems, Tyndall Centre Technical Report 30, 2005).

The Government's own Council for Science and Technology has identified the same problems with onshore wind power generation:

A22. Whilst wind generation has been successfully demonstrated in many locations in the UK, the issues of integrating wind power with existing generators have not been widely publicised. This may lead to unrealistic targets being set for new renewable energy sources or it may divert investment away from the energy infrastructure which is needed to fully exploit renewable energy sources. E.on (Germany), have published a report showing the contribution of wind power to the grid for a full 12 months in 2003. The maximum simultaneous wind power infeed from the windfarm was just under 80% of the installed capacity. The average annual infeed was less than one sixth of the installed capacity. In any year, for over 50% of the time, the wind power infeed was less than 11% of the installed capacity. This is why the provision of backup generation is important. If the backup generation uses fossil fuels, as is likely, then the reduction in carbon emissions achieved by the use of wind energy will be less than that commonly quoted.

CST. An electricity supply strategy for the UK (May, 2005).

In Denmark (as in Germany), a massive investment in onshore wind has created considerable problems for the electricity supply industry, especially for grid operators. Even with Denmark's large interconnects with Germany, Norway and Sweden, they have had considerable problems with the stability of supply, experiencing near 'brown-out's and having to dump very expensive wind-generated power to neighbouring countries at less than cost. Even with this wind turbine capacity, Denmark has not been able to close conventional plant and their huge wind power capacity has not solved the problem of carbon emissions, which are actually rising after briefly reducing between 1995 and 2000.
See 'The Dash for Wind - West Denmark’s Experience and UK’s Energy Aspirations' by Hugh Sharman, Incoteco (Denmark) ApS, (PDF file). Hugh Sharman, a consultant in the energy industry, presents a devastating analysis of the problems created by Denmark's huge investment in onshore wind power generating capacity. He forecasts that these problems will be even worse in the UK if we go ahead with the present massive unplanned expansion of onshore wind power stations.

The E.ON Netz Wind Report 2005 also reveals just how unreliable and problematic large scale wind power generation is in Germany. E.ON Netz, has over 40% of German wind power capacity, with 7,050 MW of installed wind power, in its distribution area. (E.ON group owns Powergen and is the second largest energy supplier in the UK, the second largest electricity generator in the UK and owns the second largest distribution network in the UK; they also, unlike Your Energy, build and operate wind turbine power stations).

As for 'economic':  profits from wind farms do not come from sales of electricity produced, which amounts to something in the region of 30p in every pound earned, they are accounted for by an indirect subsidy paid by electricity consumers which was originally designed to encourage all renewables (See NOWAP - How the Subsidy System Works), but which has been effectively hijacked by the onshore wind power industry with the collusion of their friends in the DTI.
Paul Golby, Chief Executive of E.ON UK (formerly Powergen), has written, "Without the renewable obligation certificates nobody would be building wind farms." Daily Telegraph (26/03/2005).

© Daily Telegraph.

The National Audit Office Report on Renewables by the Comptroller and Auditor General (11 February, 2005) - also explains the subsidy system in detail and explains how onshore wind farm developers are being paid 33% more than is needed to encourage development:

'3.17 Our consultants’ findings show that most renewable technologies continue to need public support to be commercially viable, but the level of support provided by the Obligation is greater than necessary to ensure that most new onshore wind and large landfill gas projects are developed.

3.19 The returns earned by most onshore wind projects commissioned in 2004-05 are likely to be well in excess of the hurdle rates [...] Our consultants have estimated that a buy-out price of £15 per megawatt hour would broadly be sufficient to bring forward the majority of onshore wind projects, although it might not be adequate to support the more expensive schemes which are not, for example, located on good sites due to planning problems. A higher buy-out price, possibly £20 per megawatt hour, would be required if in the future developers are required to meet all the costs of connecting new plant to the grid. It is, however, clear from our consultants’ work that, at the current buy-out price of £30, the level of support provided by consumers is in excess of that needed by many onshore wind schemes.'

Even Ofgem, the regulator, has admitted that the RO system rips off electricity customers and is a hugely inefficient mechanism for saving climate change gases. They note that developers of renewable energy schemes such as wind farms are profiteering from the Government’s drive to curb carbon emissions by making customers pay more for their electricity than is necessary. Ofgem calculates that the cost of the RO is at least eight times greater than other schemes designed to combat climate change, they have called for a wholesale shake-up of the current system.
(The full OFGEM submission on reform of the renewables Obligation is available as a PDF download from the OFGEM site).

The Carbon Trust has also submitted a paper criticising the RO as wasteful and tending to restrict the development of technologies where the UK has a technological lead and which will make a major contribution to reducing carbon emissions in the future.
(See the Carbon Trust's 'Policy frameworks for renewables' - available as downloadable PDF from Carbon Trust website).

The Irish, with a much better wind resource, came to the same conclusion: "The cost of CO2 abatement arising from using large levels of wind energy penetration appears high relative to other alternatives" (ESB National Grid, 'Impact of Wind Power Generation In Ireland'. February 2004).

The onshore Klondike created by these excessive subsidies is actually hampering development of more consistant, 'firm' renewables such as biomass or marine power generation. Even the Energy Minister has recognised the problem: "I agree that the renewables obligation, despite its strengths, which have brought forward much renewable energy, could appear to be a blunt instrument and certainly seems to be favouring one technology — the wind farm." (Malcolm Wicks, Oral Answers, Energy Supplies. 5 May 2006).

"We encourage local suppliers and contractors to bid for development and construction work, this can bring a real boost to the local economy."(Your Energy's 'Moorsyde' Brochure).

The major turbine suppliers provide a package which includes nearly all aspects of the construction process.  They use specialist contractors, none of which are located locally. For example, heavy haulage using multi-axle low-loaders, large crane hire, specialist track-laying etc. No local companies are big enough to even handle pouring the concrete for turbine bases.  The only work which might be locally contracted would be some low grade work constructing tracks, fencing work and a few days work for haulage companies moving aggregate for access roads and on-site concrete mixing.

Mr Andy Holcroft, the then Managing Director of Your Energy, publically admitted that it is unlikely that any local jobs would be created (Extraordinary Tripartite Meeting, Berwick, 17 January, 2005). Finally, the statement that "We encourage local suppliers and contractors to bid for development and construction work." is fairly meaningless.

Onshore Wind, Offshore Profits?

The turbine supplier would probably be the Danish Vestas company or the German owned, Danish Bonus company both of whom would undertake maintenance work.

And, of course, the huge profits from the site would go to Your Energy Ltd., a company that, while constantly talking about the local and national interest, would seem to have a strong corporate interest in offshore tax havens:

19.

Ultimate controlling party

The directors regard Mistral Invest Limited, a company incorporated in the Bahamas, as the immediate parent company by virtue of its 51% voting rights in the company.

The company's ultimate controlling party is CNC Investments Corporation, a company incorporated in the Bahamas, by virtue of its majority shareholding in Mistral Invest Limited.

The ultimate beneficial owner of CNC Investments Corporation is Consolidated Navigation Corporation, a company incorporated in the Marshall Islands. [Specialising in the very un-green sector of bulk carriers and tankers, we understand]

20. Post balance sheet event
During February 2004, the company sold its share in a joint venture project and thus generated its first significant revenues.

On 10 December 2004, the company became a wholly owned subsidiary of Mistral Invest Limited. [our emphasis]

Mistral Invest have obviously been as little impressed by the performance of Your Energy as we have - their Chairman, Managing Director and most other directors 'resigned' in 2004 and Mistral has subsequently taken direct control of the troubled company and has been hiring new development personnel.

Directors and advisors for year ending 31 December 2003

Directors
B N Richmond (resigned 28 October 2004)
A D Holdcroft (resigned 2 November 2004)
C E Sandham (resigned 28 October 2004)
T K-Y Hsu (resigned 14 August 2003)
T A Rottner
J Westad (appointed 14 August 2003) (resigned 26 January 2004)
R Mardon (appointed 26 January 2004)

Secretary
R D M Ward (resigned 2 November 2004)
R Mardon (appointed 2 November 2004)

(Your Energy Ltd, Annual report for year ended 31 December, 2003)

Community funds.

"In consultation with its members, BWEA has assumed that the average, annual community fund payment in 2006 equates to £1,500 per MW installed per year." (British Wind Energy Association, 'Onshore Wind: Powering Ahead', March 2006. p.23).

MAG learnt in December 2006 (from the case file, that had been 'unobtainable' until a matter of days before the abortive planning meeting), that YEL had very recently agreed some sort of community fund with the Council. This without any consultation with local people, as usual. We are told this will amount to "£750,000 over the lifetime of the scheme". This amounts to a paltry £30,000 per year and will be limited to 'energy efficiency and education' with funds for appropriate projects being administered by the Council, which is not encouraging! It should be noted that if YEL use 3MW turbines, as they claim they will, this figure amounts to only £1,000 per MW per annum which would be 33% less than the BWEA recommendation.

Your Energy are now almost unique in not offering an independent community trust fund. The Barmoor proposal developers, Catamount/Force 9 Energy, say that they are committed to setting up a community trust fund according to BWEA recommendations. NPower have also committed to offering an independent community fund for the Toft Hill proposal on the same terms.

Even this is widely regarded as a very poor trade off for the damage inflicted on local communities. There has been a wide-ranging debate in Scotland on the introduction of a statutory minimum of between £5,000 and £10,000 per MW per annum. On 13 November 2004, The Southern Uplands Partnership, Scottish Borders Community Councils’ Network and Scottish Borders Rural Partnership held a seminar on Community Benefits from Windfarms to help communities get maximum benefit from the wind farm developments in their locality. The seminar heard that The Highlands Council has Guidelines produced for developers which were adopted by the Council in April 2003:

• The guidance called for community benefit levels – or their equivalent in equity – to rise from the 1996 rate [£1,000/MW p.a.] to at least £4000 - £5000/MW p.a.
  Equity refers to any benefit that enables a community to buy into or take ownership of any part of a commercial development.

Powys county council has decided that communities that will be seriously affected by wind farm development should receive windfall payments from developers of £5,000 for every megawatt of energy produced. The county council’s board has given its blessing to this policy which would make this a condition of wind farm developments going ahead. (See Shropshire Star, 15 February 2006).

Landowners, of course, do rather better: "In consultation with its members, BWEA has assumed that average, annual landowner payments in 2006 equate to £4,500 per MW installed per year." (British Wind Energy Association, 'Onshore Wind: Powering Ahead', March 2006. p.23). This amounts to £13,500 per 3MW turbine. Landowners are also paid an annual 'exclusivity' fee which is paid from the initial agreement whether or not turbines are actually built. They also usually receive disturbance payments and, in some cases, production bonuses when the scheme is up and running. We have yet to hear of a single landowner being compensated with a fund for 'energy efficiency and education', although their need is probably greater than our's!

Neighbouring homeowners and businesses, on the other hand, are uniquely disadvantaged in being unable to claim compensation for damage caused to their businesses or the value of their homes by the building of a wind power station.

"We are committed to working together with the local community and ensure they are consulted and informed of developments."

(Your Energy's 'Moorsyde' Brochure)

A major Your Energy myth!

Your Energy Ltd. have failed to follow anything remotely akin to good practice in relation to consultation with the local community. They have also completely failed to follow planning guidance given in PPS 22, which states:

Developers of renewable energy projects should engage in active consultation and discussion with local communities at an early stage in the planning process and before any planning application is formally submitted

Nobody in the local community, apart from the landowners on whose land these turbines would be sited, has seen or heard from Your Energy since their charade of an exhibition at the Plough, West Allerdean on 21 October, 2004.  A few local people received letters advising them of this event 3 days beforehand, most local people did not. On the same day as the exhibition, a single, small advert was placed on an inside page of the Berwick Advertiser 'advertising' the event! The 'exhibition' was a confused affair with no Your Energy, Jacobs Babtie (Environmental Consultants) or Mistral (Investment Bankers/YE Owners) personnel present wearing ID badges and the 'information' presented was as blatantly distorted as the company's wide-angle photomontages!

At this exhibition, a book was available where requests for further, more detailed information could be entered. The writer was advised that his logged query about noise levels and measurement would be speedily answered.  It was not.  A follow up letter to Bill Richmond, Chairman of Your Energy Ltd. (resigned, 28 October 2004), has not even been acknowledged, never mind answered. This has been the general experience of Your Energy's 'consultation' process, even promises to supply information to local councillors have been broken.

Ironically, Mr Charles Sandham (resigned, 28 October 2004) was the author of a widely quoted paper on industry best practice in this area which was presented to a British Wind Energy regional conference. 'Consult Early, Consult Often' was the subtitle of this paper. This paper has been delivered more recently by Mr Bill Richmond (resigned 28 October 2004), who was a BWEA Board Member for Planning (now replaced at the BWEA by YEL's Mr Richard Mardon), repeating the same mantra. This conference paper was aimed at an audience of local councillors and planning officers in the South East.

We trust that our local Planning Officers and Councillors will compare Your Energy's definition of industry 'best practice' with their delivery.

Postscript

In June, 2005, Mr Richard Mardon of Your Energy surprised everybody by actually making a public offer to have "more discussions with protestors" (Berwick Advertiser, 2 June 2005). This was as much a surprise because we are not aware of Your Energy having had any discussions with local people, never mind protestors!
After 3 months of email correspondence, which was copied to local council officers, between MAG's Acting Chair and Mr Mardon, attempting to arrange a meeting and a long promised organised visit to Crystal Rig power station in the Lammermuirs, Mr Mardon failed to find time to talk to us. The sum total of Your Energy's 'consultation' with local people to date remains the single surprise 'exhibition' described above.

Postscript II

Your Energy carried out a bulk maildrop of 8,300 leaflets in July, 2006. This 'Community Update' amounted to knowingly issuing a false prospectus for the scheme because the company had delivered maps and photomontages to the planners showing a reduction of 4 turbines and a change in position of another at the same time as they were issuing this leaflet. This converted many of the 'facts' presented in the leaflet to demonstrable fictions.

The leaflet stated, "It's vital for everyone in the community to know the facts and to have their say." We would agree. It is a pity that the 'Moorsyde' proposal has seen very few verifiable facts and no genuine consultation.

"The site of the Moorsyde wind farm was identified as suitable for a medium development of up to 25 turbines".

(Your Energy's 'Moorsyde' Brochure)

"A year ago the North East Assembly published a paper entitled "Towards a Renewable Energy Strategy for the North East", this report identified a number of potential wind farm sites in the North East region, this scheme was one of them."

(Your Energy website)

Both these statements are untrue.

MAG, unlike Your Energy, took part in the Examination in Public on the Regional Spatial Strategy. The EIP Panel Report states:

'Small to medium scale development

8.40 The Panel considered whether there was a need for greater clarity in Policy 42 and supporting text concerning the use of the term `medium scale wind energy development’. Policy 42 b) confirms that the areas identified in the Policy have ‘potential for medium scale development’. It emerged from the debate at the EiP that the interpretation that should be put upon the potential of these areas is that they are suitable for small to medium scale wind energy development, [our emphasis] and that this description was intended to distinguish these areas from the potential for large scale wind energy development in the Kielder Forest. It was pointed out that some renewable energy companies believed that this policy implied that the designated areas could accommodate a number of ‘medium scale’ developments. It was established from the NEA in reply that the definition of medium scale set out in paragraph 3.141 (20 - 25 turbines) and carried forward into Policy 42 related to the total capacity of an area and should not be regarded as an appropriate scale for individual proposals. [our emphasis] It was also confirmed that work is on-going using landscape capacity techniques to better inform the carrying capacity of the designated areas. We note that this work will be of particular assistance in making judgements on cumulative impact.'

(EIP, Panel Report, 4 August 2006.)

The EiP Panel report is available as a PDF download from the NE Assembly Website.

Boscastle Picture

The use of a picture of the Boscastle flood damage in the 'Moorsyde' Brochure to represent global warming is typical of Your Energy's propaganda - it is a careless, some would say cynical, misrepresentation of the facts.

Most of us agree that there is overwhelming evidence of global warming, whether caused by carbon emissions, cyclical climate change or a combination of factors, but no reputable authority has suggested that the Boscastle floods are connected in any way with global warming.

The Boscastle floods were more to do with the coincidence of physical geography and extreme weather events to which some areas of Devon and Cornwall are susceptable. Your Energy would probably claim that the Lynmouth (North Devon) flood disaster of 1952, an event markedly similar to Boscastle (even to the coincidence of happening on the same day in August) was also down to global warming.

More misleading images.

The 'Moorsyde' brochure cover uses cut off images of small, outdated turbines.  Their use next to the words 'Moorsyde Wind Farm' is a classic case of implication by association - it implies that this is what 'Moorsyde' turbines would look like.  They would not!  The Nordex turbine, in their 'Turning Wind into Electricity' item in the Moorsyde brochure, is a more accurate picture of a modern turbine (though still not pictured in its entirity); we have used a modern turbine in the Berwick photomontage and 'Moorsyde Monsters' poster.

Should you think this is a trivial error by Your Energy, please note that they have managed to find full height pictures of modern turbines for other material that is not aimed at the public.  See: 'Planning for Wind Energy' (BWEA, with DTI, Regional Planning Workshop for Councillors and local authority Planning Officers; SE Region - pdf doc.).

SOME ANSWERS TO YOUR ENERGY'S FAQ's

"There are strict guidelines on noise, and it can be shown that people who thought there would be problems when a wind farm was built in their area, have found their fears to be unfounded once the wind farm was up and running. You can hold a conversation beside a wind turbine without raising your voice - don’t just take our word for it, find out for yourself and visit a modern wind farm."
(Your Energy's 'Moorsyde' Brochure)

A.

Another Your Energy quote:

"In accordance with our site selection philosophy we are looking for sites in the semi rural / industrial areas near towns and cities ….. near other infrastructure such as commercial or industrial developments, roads and railways to help mitigate the limited environmental impacts arising from the development. By focussing development near towns or cities or close to other infrastructure we intend to minimise the chance of any noise nuisance [our emphasis]."
(Your Energy Website. Now rewritten and this quotation removed!)

The section on noise in the Environmental Statement [ES] presents the layman with an impressive amount of technical jargon, interspersed with tables and formulae. This becomes somewhat less impressive when you realise that the applicants have, as elsewhere in the ES, chosen to present 'best case' rather than 'worst case' figures, which is normal practice in an Environmental Impact Assessment. We quote from the ES:

"5.3 Noise predictions have been based on sound power levels of a Vestas NEG-Micon NM80 2.75 MW wind turbine. This turbine can be configured to operate with varying levels of trade-off between noise and output power at sensitive wind speeds. This assessment was carried out with the turbine operating in 'Mode 4' which gives the lowest noise output [our emphasis]..."
(Appendix M, Moorsyde Environmental Statement)

It is exceedingly doubtful whether any operator would choose to operate a turbine at the lowest power output setting unless forced to do so by the courts. This also means that all of the ES graphs and tables which seek to show that the potential noise profile at various locations close to the site is within acceptable margins are totally meaningless and should be rejected.

This is before any further examination of the turbine noise figures in the light of recent research which claims that night time noise is likely to be understated by up to 15 decibels.

G. P. Van den Berg, a physicist at the University of Groningen in the Netherlands, has published a paper in which he sets out evidence explaining why modern onshore wind turbines can cause noise problems for residents at distances of a mile or more.

He measured sound around the Rhede array of 17 turbines on the Dutch/German border. “Residents living 500m and more from the park have reacted strongly to the noise; [and] residents up to 1900m distance expressed annoyance”, particularly at night. Yet wind industry calculations indicated that there would be no noise problem over 500m.

After extensive measurements, Van den Berg found that methods used by wind turbine developers, in the UK and elsewhere, to predict noise are seriously flawed because of their assumption that wind speeds at the datum height of 10 metres (see DTI ETSU-R-97) are representative of wind speed at the greater heights of modern turbines (often 80 metres plus).
[G. P. Van den Berg, 'Effects of the wind profile at night on wind turbine sound' (Journal of Sound and Vibration, 277 (2004), 955–970).

An abstract and pdf download are available from the REF (Renewable Energy Forum) website].

The experience of people living near wind turbine arrays also contradicts Your Energy's bland assurances. Visit the Marton, Askam & Ireleth Windfarm Action Group website which describes the grim reality of living with large turbine arrays.

New Noise research.

Many planners and noise experts consider that the present wind turbine noise guidelines - DTI, 'The Assessment and Rating of Noise from Wind Farms' ETSU-R-97 (in Scotland: 'A Planning Advice Note on Renewable Energy Technologies', PAN 45) - are not adequate. In fact they would seem to have been drawn up with an eye to making life as easy as possible for developers. This suspicion is supported by the fact that they do not follow the usual planning guidelines for industrial noise (See: Dick Bowdler,'ETSU-R-97 Why it is Wrong'. July 2005, PDF download). If you want to build any sort of industrial plant except wind turbines, you are constrained by regulations which state:

The assessment compares the noise source with existing background noise. A background noise survey must be performed during the proposed operating hours. The worst hour during day time is measured, and the worst 10 minutes at night. Following analysis and corrections to the data in accordance with BS4142 the difference between the source and existing noise level is determined. A difference of +10dB is a positive indication that complaints are likely. [our emphasis] A difference of -10dB is a positive indication that complaints are unlikely. A difference of +5dB is said to be of marginal significance.
(British Standard 4142, Method for rating industrial noise affecting mixed residential and industrial areas.)

In other words, the noise levels are not expected to reach decibels significantly above the background noise level. This is the policy that has been adopted by the Dutch province of Utrecht (actually a relatively urban area). Local authorities in Utrecht are required to go through detailed procedures to ensure that wind farm noise does not exceed the levels of background noise.

However, the present UK guidelines on wind farm noise give developers a much more forgiving framework for measuring possible noise nuisance, especially in the treatment of low background levels of noise in rural settings. The guidance subverts the usual protection framework in indicating a requirement for:

indicative noise levels to offer a reasonable degree of protection to wind farm neighbours, without placing unreasonable restrictions on wind farm development or adding unduly to the costs and administrative burdens on wind farm developers or planning authorities [our emphasis].

The guidelines achieve this by not taking actual background readings as a baseline against which turbine noise should be set, but by setting a mean threshold for quiet environments that was agreed with the industry. The DTI has recently touched upon the problems with ETSU-R-97 in recent research that was undertaken to look at low frequency noise. ¹

This new report was undertaken by the Hayes McKenzie Partnership, consultants who frequently act on behalf of wind farm developers and who were heavily implicated in devising the present developer-friendly noise guidance framework for the DTI.

The new report describes an investigation into low frequency noise at neighbouring properties to three different UK wind farms where noise complaints had been made. The authors discount low frequency noise as a significant problem. Though dismissive of people's subjective experience of disturbance, the authors admit that ‘audible modulation of aerodynamic noise’, commonly know as ‘blade swish’ noise, can be a problem. Their report concludes that, on occasion, blade swish is disturbing enough to prevent occupants of nearby dwellings from going to sleep although not sufficiently disturbing to wake them if already asleep.

The report authors found that even when the overall noise level inside a bedroom was less than the sleep disturbance threshold proposed in the WHO guidelines, the distinctive noise signature of the wind turbine blade swish attracted the attention of the listener and caused difficulty in getting to sleep or returning to sleep if awoken.

The report states that the blade swish noise is more extreme for some wind farms and at some properties and particularly at night time. Significantly, the report acknowledges that the magnitude of the ‘swish’ noise is greater than was anticipated in the ETSU-R-97 guidelines and recommends that the issue should be re-visited possibly with a view to including a penalty in any noise condition to take into account blade swish noise. This would effectively lower the permitted noise at neighbouring dwellings.

UK Noise Association report

A recent (July, 2006) report by the UK noise association (Location, Location, Location -PDF download) gives a very useful overview of the existing research into wind generator noise and its effects, it concludes:

1. Wind Farm noise, in common with noise generally, affects different people in different ways, but the evidence suggests there is rarely a problem for people living more than 1-1.5 miles from a turbine.

2. For many people living relatively close to turbines, the noise does not present a problem. For those who are annoyed by the noise, it is overwhelmingly the “swish, swish, swish” of the turbines which troubles them.

3. For people who are not able to shut out the noise, the problem can be exacerbated by the rotating blades and the dancing shadows of turbines. This can mean that the noise from turbines can be much more intrusive that other noises of a similar decibel level.

4. For some people the impact of turbines can be overwhelming.

5. The noise can be a particular problem in rural areas where background noise levels are low.

6. The infrasound content of wind turbine noise is too low to be heard by most people.

7. At times, low-frequency will form an audible, but not major part, of the “swish” sound of the turbines and can, for people sensitive to low-frequency noise, create additional problems. But the low frequency content of wind turbine noise is no greater than the low frequency component found in several other noise sources and can only usually be heard down wind of a turbine when there is a fair bit of turbulence.

8. However, low-frequency may be underestimated because of the persistent use of ‘A’ weighting in measuring the noise, rather taking ‘C’ weighted measurements.

9. Research by medical doctors has unearthed persistent complaints from people saying they not only hear the noise from wind turbines, but can “feel” disturbance in their bodies. This has lead to complaints of illness. The symptoms people are complaining about are very similar to those associated with vibroacoustic disease. The suggestion is that the unique combination of noise (containing an element of low-frequency) and the strobing effects of the flickering blades, is having a physical effect on some people.

10. Modern turbines are mechanically quieter, but there is convincing evidence that the noise they emit is being underestimated because measurements continue to be taken at a height of 10m from the ground, thereby underestimating the speed of the wind (particularly at night) at the top of the large, modern turbines, over 100 metres high.

The overall recommendations of the UK Noise association were that:

1. It would be prudent that no wind turbines should be sited closer than 1 mile away from the nearest dwellings. This is the distance the Academy of Medicine in Paris is recommending, certainly for the larger turbines and until further studies are carried out. There may even be occasions where a mile in insufficient depending on the scale and nature of the proposed development.

2. Wind farms should only be located in areas where the “swish, swish, swish” of the turbines will not cause noise problems for people.

3. There needs to be a clear and public recognition by the Wind Power Industry that wind turbines are causing significant noise problems for some people. This could open the door to constructive discussion.

4. The industry also should recognise that the evidence is persuasive that the noise problem can be exacerbated by the rotating blades and the dancing shadows of the turbine.

5. The official government guidelines for the siting of wind turbines need to be revised to take account of the more intrusive nature of the noise in areas where the overall background noise level is low.

6. The debate on wind farms would do well to recognise that the infrasound content of wind turbine noise is too low for most people to hear.

7. People need to be careful not to exaggerate the audibility of the low-frequency of the noise. It can be a problem at times, but over-emphasis on it can detract from the main noise problem: the ‘swish, swish, swish’ of the blades.

8. The guidelines should require the use of ‘C’ weighting (and ‘G’ weighting for infrasound) as well as ‘A’ weighting when measuring the noise from turbines in order to fully capture the low-frequency element.

9. Further work needs to be undertaken urgently to test the claims that the overall effect of turbines is having a physical effect on people to the detriment of their health.

10. There should be a short moratorium on the installation of the large, modern turbines until it is established, through trials, the amount of noise they actually emit.

Visit a modern wind power station

We would agree with Your Energy in asking people to visit a wind turbine site. Crystal Rig (built in 2003, near the Whiteadder Reservoir in the Lammermuirs north of Duns) is convenient for local people; it has turbines that are 14m. smaller than the proposed 'Moorsyde' variety but which have similar sound characteristics to current turbine models.

A constant whine from the generating gear is very audible in low-to-medium wind conditions at a mile from the turbines. The 'swish, swish' sound of the blades travels for much greater distances - it was clearly and annoyingly audible at 1.5 to 2 miles last time the writer visited. Wear and tear and poor maintenance leads other noises - MAG members have experienced a Crystal Rig turbine making loud screeching noises from badly lubricated or damaged bearings every time it rotated to face into the wind. Other turbines have been heard creaking and groaning as the headgear rotates.

But don't just stand 'beside' or 'underneath' the turbines during the day (which is where and when you will hear least noise), go up to a mile or two downwind at night in a light to medium breeze and listen with your eyes shut to the churning noise that is generated by the blades of these upwind turbines.

Subjectively, this sound seems to vary according to the cumulative interaction of numbers of turbines at varying wind speeds and the sound harmonics they generate. When you have heard this, ask yourself whether you would like to live - day in, day out, for many years - within 600 to 700 metres of them, as the 'Moorsyde' scheme envisages.

Conclusions

The DTI housing separation guideline for wind turbines is only 450 metres. This dates back to the mid-1990's when turbines were under half the size of current models. It is surely time the guidelines were uprated to take new turbine sizes and the latest noise research into account.

Cynics might suspect that this is unlikely to happen in the near future, because it would stop nearly all applications for lowland onshore sites like 'Moorsyde'.

Meanwhile, as the Klondike windrush exhausts the supply of upland sites, increasing numbers of lowland schemes are being proposed for marginal sites near housing. While government departments continue in their stately fashion to commission research and to write reports on possible responses to the research, large numbers of people are going to suffer because of the inadequate protection that is offered by existing noise guidelines that have been deliberately designed to ease the siting of turbines close to housing.

As an example, we have seen correspondence attesting to the misery suffered by one family in Lincolnshire (quoted from the Stop Cambridge Wind Farm website):

'We have been contacted by a farmer's wife, Jane Davis, who is at her wits end as a result of noise being generated by an eight turbine wind farm at Deeping St Nicholas in rural Lincolnshire. This wind farm commenced operations in mid summer [2006] and since then she has had her quality of life destroyed by night-time noise, even though the Environmental Statement said that there would be no noise. Her farmhouse is some 950m from the nearest turbine, ... and unexpected noise appears to be as a result of the constructive interference of the sound from a number of turbines in a row. She is keeping a log and it makes very disturbing reading with many sleepless nights and the resulting stress making normal life intolerable. The local Council have taken readings that confirm the problem and further investigations are in train.'

Barbara J Frey, BA, MA and Peter J Hadden, BSc, FRICS have published a paper on the subject: 'Noise radiation from wind turbines installed near homes: effects on health. With an annotated review of the research and related issues.' February, 2007. This presents an interesting survey of noise research and reports on the effects on health, wellbeing and property prices. (PDF download from website).

"Significant changes generally occur only in close proximity to the schemes, and even then direct views can often be limited. A significant change is not necessarily adverse. Many people consider wind turbines to be symbolic of a bright clean future, and think that they are graceful elegant structures. Surveys conducted across the country near existing wind farms consistently show that the majority of residents are in favour of the development. In fact, a 2003 MORI survey of residents living around Scotland’s 10 existing wind farms, found high levels of acceptance and overwhelming support for wind power, with support strongest amongst those who lived closest to the wind farms."

(Your Energy's 'Moorsyde' Brochure)

"Your windfarm has added interest to the landscape ..." ('Gerry', Burton Latimer, Northamptonshire - quoted in YEL PR leaflet).

"We hated the idea the idea to start with ... now they are here we love them" (Councillor Robina Herrington, Easington, Humberside - ibid.)

A.

MAG: We do not consider that our landscape needs the 'added interest' of 110 metre high industrial wind turbines! The Kettering Borough Planning Officer says of Burton Wold: "The site does not lie within an area defined as having particular landscape quality."
The other person they quote is from Easington at the mouth of the Humber. She neglects to mention the 2 gas terminals between Easington and the 7 small (80 metre) turbines at Out Newton. This bleak, industrialised landscape and the featureless sprawl of Northamptonshire do not compare in any way with the landscape of North Northumberland.

The fact that Your Energy pretend not see the difference between Humberside, Northamptonshire and our tourist landscape says much about the company and its approach to the 'Moorsyde' application. They have repeated this idiocy in the local press: "It [Burton Wold, Northamptonshire] is a similar landscape to what is being proposed at Moorsyde (Matt Kelly, Your Energy Ltd., reported in Berwick Advertiser, 8 June 2006).

The true value of our landscape is revealed by the fact that YEL have done everything they can to play down and conceal the visual impacts of the 'Moorsyde' scheme. The independent Audit Report on the 'Moorsyde' Environmental Statement criticised the "repeated displays of obscured views" and poor technical quality of photomontages which managed not only to render most of YEL's turbines invisible but also managed to lose the Cheviots in a haze!

The visual impacts of the 'Moorsyde' scheme would contravene the Local Plan which says:

"The Council will adopt a policy framework which acknowledges the important role the landscape plays in defining areas of open space in scale with the Cheviots, the North Sea and the mixed moorland ridges. In these areas the intention will be to ensure that development proposals will not have a detrimental impact on the long range views important to the character and quality of the Borough landscape."

Workers on turbine nacelle. They really are this big!

(Image courtesy of DART Dorset)

Another aspect of these 'graceful, elegant structures' is the amount of environmental damage caused in building them: including the excavation of 'borrow pits' (ie. quarries) for construction material and pits up to 20 metres across and 5 metres or more deep for foundations. Many wind power stations are built on peat moorland (eg. Bowbeat near Peebles) or on marshland (eg. Romney Marsh) which means that foundations may be much, much deeper than 5m. These pits are then filled with, normally, 750-1,000 cubic metres or more of concrete and steel reinforcement (see Powergen's PDF document on The Construction Story - High Volts, Hare Hill and Holmside Wind Farms).
This is before you begin to consider 'grouting' of old mine workings that are widespread on the 'Moorsyde' site [i.e. filling them with concrete slurry] and/or deep piling to overcome unstable ground conditions caused by old mine workings); pollution of watercourses with concrete leachates and water run-off from site workings; the excavation of 'borrow pits' (i.e. quarries) for aggregate and roadstone; the construction of several miles of access roads; the destruction of hedges and roadside verges to allow access by low-loaders carrying 40 metre long turbine blades and tower sections; the erection of machinery pounds, temporary buildings and concrete mixing plant; the laying of power lines, whether entrenched or on new pylons or masts.

It should be noted that concrete production is a major source of climate change gases. Calculations of wind turbine carbon savings figures almost always neglect to include the climate change gases produced in connection with the foundation works.

A recent New Scientist article (July 6, 2006) by Ed Douglas presents new calculations for the real carbon costs of constructing wind turbines. this shows that the payback time for turbines built on peat is likely to be 16 years.

Gentle Footprint?

Foundation Pit for a Vestas V90, 3MW turbine (Tararua III, New Zealand).
© 2006 Michael Feyen

'Borrow Pit' at Black Hill, nr. Duns, Sc. Borders.
© 2006 Don Brownlow Photography.

Each turbine will have about a one acre footprint if you include its access road, adjacent area of hard standing for cranes and all the ancillary works connected to the power station. Far from the 'gentle footprint' described by the wind power PR people, this often amounts to the jackboot industrialisation of the landscape. In some cases, especially on sensitive peatlands, it can mean considerable and permanent damage to a landscape. If you think this is an exaggeration, please have a look at the Cefn Croes Photo-Gallery which records what is described as 'the rape of an upland plateau'.

The concrete foundations are not removed if turbines are removed. Thus, the many thousands of tons of concrete will continue to affect the hydrology of the area and will mean that every wind power station site may be regarded as a brownfield site that is suitable for further industrial development.

Size Escalation

Hainsford Energy are reported to be scoping a re-powering of the Blyth Harbour turbines which, unusually, have been working since 1993. They propose replacing the present nine 42.5 metre turbines with six 150 metre (492 ft.) and one 163 metre (534 ft.) turbines. This latter monster would be a 5MW type that has so far only been talked of for offshore schemes. If ever built, it would be the biggest turbine in the UK.

Most people are under the misapprehension that turbines are built and that is it for 25 years with only the occasional repair of failed blades and burnt out generators.
Not so: Great Eppleton in County Durham was built in 1997, it has been closed for nearly 2 years awaiting 'repowering' [Update, 11/1/07: an application has now been received by Sunderland City Council from E.ON.UK to replace the four 232' (71m) turbines with four 377' (115m.) turbines].
The wind industry likes to claim that wind turbines are a 'mature' and 'proven' technology, but it seems that their actual generating life is usually well under half what the industry claims.

Once permission is granted, it seems that there is little to stop the industry 'repowering' and expanding a site. Visual amenity is a lost cause and developers argue that as the previous application was acceptable, there can be little objection to a few more turbines.

63 metre turbine towers

(with kind permission of the Cefn Croes campaign)

Your Energy's Favourite Opinion Poll

The MORI Scotland survey on attitudes to windfarms quoted by Your Energy and other developers was commissioned by the Scottish Executive in support of their alternative energy strategy. A total of 1,810 adults living up to 20km from windfarm sites in Scotland were interviewed. This survey has been widely criticised for its flawed methodology.

Comments on this survey from 'Who Surveys the Surveyors?' by the Scottish Wind Assessment Project (SWAP):

"After the collapse of the earlier survey (see p. 10), publication of a new study was promised for the spring of 2003, shortly after surveying finished in March. In the event, it took nearly six months to write the report but it remains difficult to accept its conclusions. (For example, neighbours of the ten sites did not ‘... often live in remote and widely-dispersed communities’. Around eight per cent of Scotland’s population lives within 20 km of the sites – interviewees included people living on the outskirts of Edinburgh.)

20 km away. As a result, responses reporting problems experienced by genuinely local residents were overwhelmed by those of more distant neighbours. Only 35 out of nearly 2,000 post-weighting interviews were conducted with residents living within five km of the 10 sites and none at all at three of them.

Other results further undermined sampling credibility. For example, 53 respondents reported noise problems 10 km or more from a site, only two reported them from 5 to 10 km away and none at all under five km. The probable explanation for this absurd finding is that, while most respondents lived in a cluster of adjacent sites, they were not assigned to the site they lived closest to, rendering distance-related data meaningless. A researcher who spotted these serious sampling discrepancies in what was a keynote report remains convinced that they had caused the publication delays and sought to discuss them with Scottish Executive officials. Pressed on the issue, however, the Executive terminated the dialogue and the report stood."

See also the Figures page which presents a detailed analysis of how Your Energy have exaggerated the power output and carbon saving figures in both the 'Moorsyde' Brochure and the planning application.