Why peatlands are unsuited to windfarm developments

Douglas Lloyd’s explanation of why peatlands need to be protected in his objection to the proposed Lluest y Gwynt wind farm and grid connection.
I have a BSc (Hons) in Environmental Earth Science and have worked in nature conservation and land management for wildlife for over 25 years. I currently work as a Wildlife Trust Officer (Ceredigion) for the Wildlife Trust of South and West Wales.
During this time, I have worked for local authority planning departments, a utilities company and various wildlife trusts. Also, during this time, it has always been presumed that areas containing such quantities of peat and priority habitats would be avoided by developers, as these sorts of developments would never have been approved on such sites, unless they absolutely had to use a specific location.
Sadly, I find myself in the position where there is no choice but to comment on this and other poorly thought through projects in relation to their specific siting.
Developers tend to state that they look at four major aspects when choosing a potential site. These are landowner/land availability, wind availability, grid connection, and highways connections.
Whilst the first two of these are always going to be met in the uplands, and by offering the landowner sufficient money for such a scheme, the remaining two, grid and highways connectivity, can only be met by yet more upland development, in an area unsuited to such major works due to peatland, landscape and ecological constraints.
To put this into context, in a worldwide setting, peat only covers 3-4% of the land surface. In Wales we are lucky to have 11-12% of our land covered with peat and peat soils. But this peat is unevenly distributed, and the most important area is in the Cambrian Mountains.
Despite the National Park status of Bannau Brycheiniog and Eryri, they do NOT contain such an important resource as that in the Elenydd; this is largely due to the greater depths of the Elenydd peatlands on flatter uplands with high rainfall.
Unfathomable
The focus of wind farm developers on the very areas that contain the most peat, a resource of huge importance for CO2 storage, is unfathomable if one accepts the argument that the developers of wind farms are building them to stop dangerous levels of CO2 and excess warming being generated. This simply isn’t borne out by the evidence of their actions. Or to state it simply, there are other suitable areas for wind power that do not contain Wales’ greatest peatland and therefore CO2 storage resource.
The Cambrian Mountains are the largest continuous upland peat massif in Wales. This is important in the context of proposed developments; we are not talking of small, isolated peat sites that can be built between with no damage but a large and continuous area.
A further analysis shows the Elenydd to contain peat deposits that are within the top five in the UK (all sources show that outside of Scotland, the Cambrian Mountains area has the largest peat deposits by volume in Wales and the second largest in England and Wales, second only to the North Pennines).
Peatland backbone of Wales
Yet the Elenydd, unlike all the other areas, has no landscape protection and so is targeted for damage and fragmentation. This is the core peatland backbone of Wales and is irreplaceable. While there has been damage to it from various sources in the past, including drainage for afforestation, attempts at agricultural improvement, and damming for reservoirs, it is still notably more intact than anywhere else in the country.
Further to this, it is unjustified to talk of “damaged” or “modified” peat as if it has a low status and is therefore suitable for development; this is not true from a legal, planning, or ecological perspective and when it is noted that 80-90% of all peatlands in the UK are damaged or degraded then this argument looks even weaker.
In many cases, the applicant’s own evidence confirms that peat is widespread across the site. These are not proposals with minor or incidental peat constraints. Any peat over 50cm is classified as deep peat. Degraded or modified peatland should not be treated as expendable, particularly where it retains restoration potential.
Planning Policy Wales gives considerable weight to the protection of peat resources and requires development to follow the step-wise approach: first avoid harm, then minimise, mitigate, restore and compensate only where appropriate. Where irreplaceable habitats are affected, the policy position is especially stringent.
The issue is therefore not simply whether the applicant can calculate and manage excavated peat volumes, but whether harm to peatland and the natural resources it supports has genuinely been avoided.
Priority ecological networks
It is also worth mentioning that many windfarm proposals are sited within PENs (priority ecological networks) for heathlands and bog. These are regarded as areas with the highest likelihood of achieving quality priority linkages and existing features.
Future Wales Policy 9 identifies national natural resources, including soil carbon, biodiversity networks, upland habitats, and natural flood management. Peat is a key component underpinning all of those resources. Damage to peat therefore has implications beyond the immediate construction footprint.
Future Wales Policy 17 supports renewable and low-carbon energy, but not at any environmental cost. Renewable energy proposals must still demonstrate that they would not have unacceptable adverse environmental impacts.
Peatland habitats are also Section 7 habitats under the Environment (Wales) Act 2016, meaning they are habitats of principal importance for maintaining and enhancing biodiversity in Wales. This reinforces the need for a precautionary approach where peatland resources, peat-forming vegetation or peatland hydrological function may be affected.
Carbon payback is not the same as peatland protection. A wind farm may generate renewable electricity while still causing unacceptable harm to peatland habitat, soil carbon, hydrological function and ecological resilience.
Such developments can be positioned on sites that are not underlain by peat, on better strata for the installation of turbines (non-friable rock types) and without the need for kilometres of access tracks, further damaging our irreplaceable peatlands and their equally irreplaceable habitats and species.
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