Our natural resources continue to be threatened by the growing energy needs of industry, agriculture and our population. Renewable energy targets to combat climate change also place increasing pressure on land use. How can we meet both energy and environmental needs?

WHS is facing this challenge with our renewable energy clients in Wales, Scotland and England. We are supporting their journey through planning by working hard to develop robust proposals to manage their water environments, as part of their environmental statements.

Our recent work supporting wind farm proposals in Welsh upland areas, areas that often include important peatlands, is a case in point.

The problem with peat

Peat is an important store and sequester of carbon. Proposals that involve disturbing even limited areas of peatland are controversial, but they inevitably arise, as areas of wind resource and peatlands often coincide.

So how do we meet our energy and environmental needs in combination?

As our environment changes, we will need to change with it, in order to manage the balance needed to create and maintain sustainable energy supplies that meet the future needs of our country and our planet.

Opportunities or threats?

Understanding the practical issues of wind farm developments is essential and no small task in itself. In considering any individual site decision makers must also weigh up a plethora of local and national policies, some of which may appear to be conflicting.

Nearly all peatlands in the UK are protected under local, national and/or international protected-area designations or related designations post-Brexit (eg. the IUCN UK Peatland Programme). Navigating these can leave developers with much uncertainty and the route to achieving a successful outcome can be very unclear.

Planning Policy Wales, Edition 12, February 2024 (PPW12) is at the heart of the matter in Wales and similar policies exist elsewhere in the UK.

PPW12 emphasises the ‘irreplaceable nature of peatlands’ and outlines a step-wise approach to delivering sustainable development in their vicinity.

PPW12 explicitly states that proposals in statutory designated sites are, as a matter of principle, unacceptable, but also states that it will be wholly exceptional for development to be justifiable in such locations. In other words, under wholly exceptional circumstances, development within designated sites may still be consented.

The decision as to what constitutes such circumstances rests with the planning authorities and recent decisions by Welsh ministers provide some clues as to a potential way forward.

Finding a way through

As the dilemma is how to meet energy and environmental needs in combination, it is perhaps not surprising that one of the answers emerging is more nuanced than a binary interpretation of policy.

Two recently consented wind farm proposals on peatlands are helpful to consider.

  • Garn Fach Wind Farm, south of Newport, Powys comprising 17 turbines with a generating capacity of 110 MW and for which WHS advised on the hydrology and peat topic on behalf of EDF Energy. Welsh Government Planning Casework Portal, Case Reference DNS3244499, Decision Date 22 October 2024.
  • Mynydd Fforch Dwm Wind Farm, east of Neath, Neath Port Talbot comprising six turbines and 10 ha of solar voltaic panels with a generating capacity of 35 MW on behalf of Mynydd Fforch Dwm Wind Energy 2021 Ltd. Welsh Government Planning Casework Portal, Case Reference DNS3255801, Decision date 23 December 2024.

In both cases, Welsh ministers considered the proposals to be Developments of National Significance (DNS).

In both cases, Welsh ministers also agreed that the circumstances of the proposals were wholly exceptional and satisfied the first step in the step-wise approach described in PPW12.

Welsh ministers agreed with their appointed inspectors that the benefits offered by the proposed windfarms outweighed the harm that might be caused to local peatland.

Much scrutiny and detail concerning the benefits to be achieved by the proposals, the degree of harm likely to be caused to the respective peatlands, and subsequent steps within the step-wise approach, was critical in enabling the ministers to give their consent.

Details concerning not only design, but also definitions and descriptions of the peatlands informed by detailed survey, analysis and assessment were necessary.

Peatlands are a complex product of many natural processes involving climatology, meteorology, ecology, hydrology, soils, and geology. Understanding what sustains them and how to protect them requires co-operation across a range of technical disciplines.

Development managers need to invest time and money in ensuring that relevant experts are engaged in the right way and at the right time.

Detailed investigation, thorough analysis and robust assessment reduce uncertainty and reduce risk. They enable the benefits of a proposal, in comparison to the degree of harm that it may cause, to be comprehensively and clearly explained.

Nothing will come of nothing

Doing nothing about climate change is a choice widely regarded as neglectful. It is likely to lead to ever increasing harm to our planet, our environment and our communities.

Doing something however, requires an understanding and acceptance of change, a change in approach and a change in delivery, changes that are unlikely to win universal acceptance and approval.

Change is not without consequence. As society comes to terms with the impact of climate change, governments have to make difficult decisions with moral, economic, social and environmental consequences.

In the case of wind farm developments on or near peatlands, much will depend on how relevant policies are interpreted, as well as the level of detail provided by developers and their consultants, to enable decision makers to navigate their way towards positive outcomes.

It is likely that the level of detail required in all respects will increase and experts across a range of skill sets will be required to work together in order to provide such detail.

The last word

Contact WHS for an initial no-obligation conversation if you would like to explore these issues further for your own business. We’d love to hear from you, to learn about what you do and discuss how we can help you.

Our unique, cutting-edge methods and software, widely used as best practice by regulators, and our depth of knowledge and experience in the water environment, are just a phone call away.

For more information please contact:

Duncan Russell, WHS Technical Director, Hydrology & Hydrogeology

Mobile: 07549 018136

Email: duncan.russell@hydrosolutions.co.uk