£13bn £124bn Technical Objections: Is the proposed technology ‘Fit for Purpose’? Contents: Objection statement Supporting documents: Information Event Facts & Stats slides Achilles Heel JChahal query applicant docs 080514 JRust 020414 UB objection doc based on technical JRust 030414 these are the facts JRust wind turbine performance calculations 210414 OSVAT BULLETIN No 12 0314 information bulletin 310314 facts stats & money press release 120514 facts stats & money Introduction. Objectors to this proposal fully support the need to put effective measures in place to tackle climate change and to create opportunities for the production of renewable and low-carbon energy; many local residents have their own self-sufficiency measures in place and it is this passion and commitment which has led them to explore this particular proposal in so much detail. Tackling climate change involves an extraordinarily complex jigsaw of measures which also exist within a wider context of the environment as a whole and the demands of modern society. This is why planning guidelines and changing Government policies have evolved to a point where each proposal has to be judged on a case-by-case basis; the ‘green’ benefits of the proposal need to be effectively quantified and then weighed against the negative impacts – the final decision seeks to achieve a balance which is acceptable to the local community and society as a whole. Inherent in this calculation is an understanding that there are: good/viable/effective green technologies & poor/non-viable/ineffective green technologies It is our belief that the technology being proposed in this particular application is not ‘fit for purpose’ in terms of the ‘green’ benefits which it can offer. When weighed against the significant negative impacts we believe that there is sufficient evidence to recommend the refusal of this application. Context: Planning Guidance & recent decisions (full information & additional examples in separate sections, attached) The National Planning Policy Framework: Includes a ‘presumption in favour of sustainable development’ o Unless (p4) ‘any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole’ ‘Sustainability’ falls into 3 broad areas – economic, social & environmental o A renewable energy proposal is therefore considered within a wider context of the economic and social needs of the area to be developed as well as wider environmental concerns such as landscape, heritage and wildlife and the consideration of whether there are other alternative renewable projects which could deliver more effective green energy returns without any of the identified negative impacts. (p23) “approve the application if its impacts are (or can be made) acceptable.” Planning practice guidance for renewable and low carbon energy (DCLG July 2013) “Increasing the amount of energy from renewable and low carbon technologies will help to make sure the UK has a secure energy supply, reduce greenhouse gas emissions to slow down climate change and stimulate investment in new jobs and businesses. Planning has an important role in the delivery of new renewable and low carbon energy infrastructure in locations where the local environmental impact is acceptable.” o In this way, there is an inherent responsibility to be sure that the green benefits of any specific project are properly evaluated on a case-by-case basis. o In this case, for example, the applicant appears to have chosen a 900kw machine but de-rated it to 500kw; this increases the financial profitability of the project but reduces its green energy effectiveness and bringing in to question the ‘green’ motivation behind the project. (… additional points in relation to weighing ‘green’ benefits against negative impacts.) (p5) “considerations for particular renewable energy technologies that can affect their siting include … for wind turbines, predicted wind resource …” o In this case, the wind speed is of a relatively low quality (p12) “As with any form of energy generation this can vary and for a number of reasons. With wind turbines the mean wind speed at hub height (along with the statistical distribution of predicted wind speeds about this mean and the wind turbines used) will determine the energy captured at a site. The simplest way of expressing the energy capture at a site is by use of the ‘capacity factor’. This though will vary with location and even by turbine in an individual wind farm. This can be useful information in considering the energy contribution to be made by a proposal, particularly when a decision is finely balanced.” o Capacity Factors are essentially a theoretical exercise in combination with manufacturer’s technical data. More accurate figures can be achieved by combining this data with research captured from actual performance of existing turbines (for example, the Scientific Alliance took readings over a two-year period (Derek Partington)). More detail on this, below & in supporting documents. o Implicit in this guidance is the need to quantify the ‘green’ benefits before weighing benefits against impacts. o The use of this capacity factor information is described as ‘can be useful’ and is neither a requirement, an end in itself nor does it exclude the application of alternative data and research. (Judgement) Gedling Borough Council – May 2014 (Woodborough, Notts) This judgement includes an important ruling to the effect that a turbine’s volume & efficiency should be a consideration in the planning decision and opening the door for objectors to debate whether specific projects are ‘fit for purpose’ in terms of quantifying the ‘green’ benefits on a case-by-case basis. “I believe Mr Kimblin to be simply wrong in his submission that, having regard to the full range of applicable policy, matters such as volume and efficiency are irrelevant ...” an applicant cannot rely on a national need for increased renewables to justify an individual application; the applicant must also demonstrate the proposed technology is fit for purpose at an individual level. It is fair to put forward the view that the applicant could have considered alternative, more effective ways of generating the same or better green benefits with fewer negative impacts. “It cannot be the case that a very large but unproductive and inefficient installation ranks equally with a small but extremely efficient one when it comes to evaluating “very special circumstances”. Size, efficiency and ability to meet need are all considerations relevant to the issue of “very special circumstances” The Technical Facts & Stats We have been fortunate in the last 6 months to have access to research and data put together by other campaign groups locally and nationally who have been keeping abreast with new developments and changes of opinion in this sector. Most particularly we have been fortunate to be able to draw on the skills and knowledge of two local engineers (Mr J Rust and Mr J Chahal) who have been able to collate this data and research and put together a summary relevant to this particular application – 14/00497/FUL. Whilst inhibited by the limited technical data made available by the applicant they have been able to: Raise significant queries and questions about data which is either missing or appears to be inaccurate in the application documents Put forward a robust case demonstrating the limited ‘green’ benefits offered by this particular proposal Put forward a robust case arguing that the financial costs of the proposed 500kw turbine make it unaffordable as a viable source of energy Suggest with certainty that there are much more effective and viable alternative ‘green’ energy options which the applicant could and should have pursued instead of taking this particular route. Their reports are attached as supplementary documents. Also attached are the information slides from a recent Information Event which summarise many of the technical and viability issues. Extracts from the attached Information Bulletin (technical issues) In summary: Whilst a number of the following points are not material planning considerations in their own right, they do demonstrate some of the ways in which the proposed turbine should not be viewed as ‘fit for purpose’. In this way, it is reasonable to predict that it will not deliver the ‘green’ benefits needed to make the project effective. In their press release of March 13th 2014, the applicant explains that their proposed turbine will “Generat(e) about 1,809 megawatt hours of electricity every year, the turbine would be able to power about 497* homes per annum for at least 20 years.” which sounds very attractive. (*NB this figure appears as 478 in the Planning Statement) Outstanding query: the exact machine proposed by the applicant (J Chahal letter to Rushcliffe BC, attached) o (this information is necessary to evaluate the efficiency/performance of the proposed turbine as accurately as possible). As we understand it: o A 900kw machine with a load factor of 23% gives an output of 1,809 mWh o The output for a true 500kw machine would only be 1,005 mWh o A true 500kw machine would not be capable of producing 1,809 mWh. Energy Savings Trust. Using their ‘wind speed prediction tool’ they predict the quality of wind at any given site by postcode and its suitability for generating energy from wind power: Below 5 metres per second = not viable Above 5 metres per second = may be viable Turbine manufacturer’s specifications 3.5 m/s Postcode of proposed site (LE14 3BQ)* Diocese confirm they are predicting Turbine manufacturer’s specifications 5.1 metres per second 6.5 metres per second 13.5 m/s ‘cut-in speed’ – the speed at which a turbine begins to work (may be viable) (calculated to the height of the proposed turbine) optimum windspeed for a 500kw turbine Such low predicted wind speeds (5.1 &/or 6.5) introduce doubts about the potential for producing viable energy; ie. whether this is an effective site. Note: - *The prediction tool doesn’t factor in the height of the turbine - We haven’t been able to verify at what speed ‘may be viable’ becomes ‘viable’. Derek Partington (www.scientificalliance.org.uk): “It was noted that whilst the installed capacity of wind turbines had increased during the 2 years of the study, the load factor (which is the average actual output of the turbines compared to their continuous rated output) in 2011 which was 27.2% had dropped to 25.6% in 2012. The reason for this is thought to be that the best sites for on-shore turbines have been taken up and that future turbines will generate even less power due to the inadequacy of the sites remaining.” OFGEM. Give figures to indicate the average fuel usage by households and by area: The East Midlands average for a 3 bedroom house: (electricity @ 20% of total fuel usage) = 3,300 units/kw hrs The East Midlands average for a 3 bedroom house (to fully fuel) = 16,500 units/kw hrs Consequently, if the machine which the applicant is proposing can produce electricity at a rate of 1,809 MWh per annum: This would provide 20% of the total fuel needs for 497 (average 3-bedroom) houses But it would only provide 100% of the total fuel needs for 100 (average 3bedroom) houses. Added to this; the electricity being supplied to these 100 houses would have cost up to 4 times more than current fossil-fuel sourced energy because of subsidies, constraint payments (etc) being paid to the developer, making this type of energy a significant contributor to fuel poverty. Therefore, if we want to keep the cost per household at today’s levels, does this reduce to 25 homes? (These calculations are based on the capacity figures submitted by the applicant and manufacturer: these are theoretical/based on computer modelling.) THE VARIABILITY AND UNPREDICTABILITY OF WIND - THE ACHILLES HEEL OF WIND TURBINES (J Chahal April 2014) To achieve a more realistic view of the actual performance of wind turbines evidence should also be taken in to account through data collected from working turbines. The Scientific Alliance (authored by Derek Partington) conducted real-time measurements of energy produced by wind turbines in the UK over a 2-year period: http://www.voicesagainstturbines.co.uk/facts-stats/ http://www.scientificalliance.org/sites/default/files/Partington%20wind%20generation%20analysi s.pdf http://www.scientificalliance.org/sites/default/files/Wind%20Power%20Generation%202011_201 2%20Appendix.pdf “The assumption that the wind is blowing somewhere in the UK at any given time is, in practical terms, false: there are regular periods when there is not enough wind to contribute to any meaningful power generation.” “Periods of low wind are so frequent that wind turbines cannot be relied on as a steady source of power … Wind turbines must be backed up by the equivalent capacity of conventional fossil-fired power stations, thus largely negating any fuel savings or reductions in CO2 emissions.” The report shows that, in practice, in the East Midlands, a wind turbine is likely to perform at 23% of its capacity. To summarise; wind power cannot be stored and is incredibly unreliable. This means that it requires alternative sources of energy to back it up at all times (&, therefore, does not reduce the need for energy generation from other sources) and is incredibly time consuming and complicated to manage for the National Grid. (see reports, attached) “The real Achilles Heel of wind turbines is in the intermittency of wind. Derek Partington’s 2-year study (www.scientificalliance,org.uk) has scuppered the notion that wind is always blowing somewhere. The results from the metered outputs of wind turbines (on-shore & off-) from across the UK have shown that during 2011 and 2012, there were 132 days when the turbines produced less than 10% of their rating, and 50 days of less than 5% of their full rated output. This is why not a single power station will close due to the use of land-based wind turbines.” (J Chahal) East Midlands averages: Available wind: Electricity usage by an average 3bedroom household: Predicted load factor (500kw turbine): Number of houses that could be powered (assuming an output of 1,005MWh pa): Number of houses that could be powered (assuming an output of 1,005MWh pa): Cost of turbine over 20 years per benefitting household (£5m subsidies/number of houses): Cost of turbine per annum for 20 years per benefitting household (£5m subsidies/number of houses): Our estimates for the proposed site; LE14 3BQ 5.2 Figures based on info put forward by the applicant (*1) 6.5 metres per second (but turbine height not factored in to Energy savings Trust figure) (factoring in height of turbine) 3,300 (annual usage per house in kw/hrs) 3,640 units/kw hrs – based on the quoted 1,809 mwh figure for 497 houses 41% (*2) 23% 23% Based on 20% of a home’s total fuel bill being for electricity usage: 277 497? If fully fuelling the same 3bedroom average house: 55 497? £18,070 per house £5m/277 £90,909 per house £5m/55 £10,060 per house £5m/497 £903.50 per house £5m/277/20 £4,545.45 per house £5m/55/20 £503 per house £5m/497/20 (based on information produced by JChahal, Proviser.com & OSVAT Bulletin 12) (*1) Figures for Diocese of Southwell are estimated as there continues to be limited detail about the basis of their calculations, to date. (*2) At no time in the 13 years of DECC records has any month shown more than approx. 29% for a full year and this was only achieved once, in 2008, which was an exceptionally windy year. OR: East Midlands averages: Cost of energy produced to the end-user: Gov’t figures show: On-shore wind: £100 per MWh Current average (coal/gas): c. £50 per MWh Our estimates for the proposed site; LE14 3QB The proposal seems to be for a de-rated turbine (*2) which maximises subsidies & would cost: x4 (current average cost): £195 per MWh Electricity usage by 3,300 an average 3(annual usage per bedroom household: house in kw/hrs) Number of houses that could be powered (assuming an output of 1,809MWh pa): Number of houses that could be powered (assuming an output of 1,809MWh pa): Cost of turbine per benefitting household (£5m subsidies/number of houses) Figures based on info put forward by the applicant (*1) Not quoted Based on 20% of a home’s total fuel bill being for electricity usage: 497 3,640 units/kw hrs – based on the quoted 1,809 mwh figure for 497 houses 497 If fully fuelling the same 3bedroom average house: 100 497? £10,060 per house £5m/497 £50,000 per house £5m/100 £10,060 per house £5m/497 (based on reports produced by JRust) (*2) through de-rating “… this turbine wastes 481,000 kwh of potential electrical energy per year for its physical size this is enough renewable electrical energy to supply electrical energy to 134 homes.” 1) How Much Does A Wind Turbine Cost? Estimates of capital costs incurred by the developer vary from £1m upwards (this does not include de-commissioning costs at the end of the turbine’s life); in return this investment is estimated to return upwards of £5million – index-linked, guaranteed, risk-free. o Subsidies payable approx. £5million o Additional constraint payments claimed when the turbine is not working or not required by the National Grid o Subsidies and constraint payments are paid for through the end-users energy bill o The energy produced by the proposed 500kw turbine is estimated (see John Rust reports) to cost the end-user approximately 4 times more than energy currently produced from conventional sources and is twice the average cost of wind energy produced from on-shore wind turbines in general. o John Rust also explores, in detail, the issue of ‘de-rating’ where a 900kw turbine machine is de-rated to 500kw (as would appear to be the case in this application) in order to maximise the subsidies payable to the developer but at the same time reducing the amount of green energy produced. (Figures shown represent the DECC estimates of the cost of electricity from different sources to the endenergy user; energy produced by a 500kw wind turbine (as proposed in this application & because of the subsidies available on this size of turbine) = £195 per kwh ie. 4x the cost of current conventional energy sources) The environmental costs of an industrial-scale wind turbine: In this case, for example; it can be argued that the overall carbon footprint involved in sourcing components (especially metals from China), manufacturing (outside the UK), transportation, construction, maintenance, de-commissioning, the full restoration of the site and the disposal of turbine parts (much of which can’t be recycled and ends up in landfill) could fully negate the benefits of any green energy produced during the lifetime of the turbine (particularly at a relatively poor wind speed site such as this one). Evidence supporting the view that a wind turbine project on this scale de-values the area around it: According to the London School of Economics house prices within 2.5km of a wind turbine fall by 11%; o this distance includes all properties in Upper Broughton and many in Hickling Pastures, Hickling and Nether Broughton o if we roughly estimate that 300 houses are affected & use the Rushcliffe average house price of £236,000 (see references, below) o the turbine would cost each of these 300 houses an average £26,000 each o & in total, would cost the community; 300 x £26,000 = £7.8million. o This is a low estimate as the average house price for the affected postcodes is likely to be rather higher than £260,000. 2) What Does It Give Back? Very expensive energy which is unreliable, requires back-up from alternatives at all times & is difficult for the National Grid to handle. Very high subsidies going into the pockets of a few individuals instead of being shared more widely and benefitting those actually suffering the effects of fuel poverty. Negligible (if any) reductions in overall CO2 emissions when the manufacturing, maintenance and de-commissioning of the turbine is balanced against the amount of usable energy it produces during its lifetime. Significant negative impacts on the health & well-being of those living within 2km. Negative economic impact on the value of houses within 2.5km & negative impact on small local businesses and tourism, adversely affecting the rural economy. Negative impacts on the landscape & the environment. WIND = GREEN = MYTH 3) Could This Money Be Better Spent? If we remove the extras from these calculations, ie: Constraint payments etc claimed by the developer when the turbine isn’t working and/or isn’t needed. Cost to the community in terms of lost value to property and local businesses. Environmental costs in terms of manufacturing, erecting, de-commissioning & disposing of the machine itself. We are then left with the basic cost of the subsidies: Current lowest estimates are that the developer will be paid (by the end energy user) approx. £5,000,000 (£5million) in subsidies during the 20 year lifetime of the turbine, index-linked, guaranteed, risk-free. Instead, this £5million could be spent on: Photo Voltaic solar panels for 1,000 houses (at a cost of £5,000 per household for a system which would reliably generate 4kw of electricity): o Instead of one person/company receiving all the money o 1,000 households benefit – giving them self-sufficiency & control o & spreading the benefits widely o & tackling the issue of fuel poverty o & no negative impacts on health or landscape! o This is a relatively new technology which has potential for improvement, will reduce in cost and needs research investment to develop further. This is just one of several alternative scenarios which the applicant could have pursued instead of this current proposal: The applicant as an extensive landowner across the Diocese of Southwell has access to many alternative sites which would be better suited to effective ‘green’ energy production. Some local churches within the Diocese (Cropwell Bishop, we understand) are already moving towards self-sufficiency through the installation of solar panels on the church roof. Such projects give direct and immediate benefits to mitigating the Church’s overall carbon footprint, reducing their overall reliance on fossil fuels; furthermore, they are both cost and energy-effective (if less profitable than 500kw wind turbines as an investment opportunity). Note: £5million is a low estimate of the actual costs of a turbine of this kind the higher the costs, the more benefits could be shared out elsewhere. Finally: In a message from the Chief Executive of the Diocese of Southwell (1/4/14) in response to a request for clarification of the calculations: It has been predicted that the wind speed at this location at the proposed hub height should be 6.5m/s. This is based on DECC wind speed data base value of 6.6m/s at 45m adjusted down for hub height. We have found that the database provides good assessment of wind speeds in such locations as that off Melton Road. Using the power curve of the proposed turbine (i.e. how wind energy converts to power energy), the wind should generate 1,809 megawatt hours of electricity per annum. Again our experience with the proposed turbine is that the published power curve has proven to be achieved in practice. According to the average energy usage figures published in the Energy Saving Trust report 'Powering the Nation' in June 2012, an average UK property consumes 3,638 kWh per annum. The Energy Saving Trust calculated this figure as a weighted average of the annual average energy consumption for all dwelling types in the UK. Based on the wind turbine generating 1,809 megawatt hours of electricity per annum and the average UK property consumes 3,638 kWh per annum, the turbine is predicted to produce enough electricity for 497 homes for the whole of the year.