BUTE REFUSES TO ADDRESS MAJOR PLANNING CONCERNS ABOUT NANT MITHIL

Bute’s Further Information is now open for consultation until 26/6/26 on the PEDW website. Responses must be limited to addressing the Further Information. You can’t introduce new points about other aspects of the Application but you can point out any failure to acknowledge or answer concerns raised in the responses to the first round of PEDW consultation in the Report or new Appendices, including Appx 18 Public Comments Review.

PEDW requested Further Information before continuing their examination of the planning application. BUTE’s response is in a 225 page report named Regulation 15(2) Further Information Main Response Report and in 19 separate Appendices.

There is some new information among the Appendices which was lacking from the original application:

• Screening for Listed Buildings
• Existing peat map displayed at required resolution
• 10 new viewpoint wireline visualisations
• Missing forestry map
• Groundwater monitoring November 2025 – Feb 2026 adjacent to SSSI
• Technical Note on Hydrology of Great Rhos

In the remainder of the response, BUTE defends the Application as submitted, dismissing requests and concerns from PEDW, NRW, PowysCC, Bannau Brecheiniog NP, CPRW-ReThink & the general public on landscape and visual impact, ecology, hydrology, traffic, residential living conditions and local communities. BUTE provides “outline” legal and regulatory compliance documents, draft planning conditions and planning policy justification to support their application as it stands.

In particular BUTE doubles down on FOUR MAJOR PUBLIC CONCERNS about the planning process:

• refuses to expand cumulative assessment to other BUTE projects (Aberedw Hill, Bryn Gilwern, Rhiwlas and Banc Ddu)
• refuses to include environmental assessment of GREENGEN CYMRU’S Towi-Usk export powerline
• refuses to address the viability of the turbine transport route from either Birkenhead or Swansea
• continues to insist that any further information on protective measures can be reserved for post consent plans covered by planning conditions

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FURTHER INFORMATION REPORT BY TOPIC

Topics in the response letter (FIR) with some key points below are:

• Landscape and Visual Impact
• Cumulative Projects
• Ecology and Ornithology
• Peat and soils
• Geology and hydrology
• Cultural Heritage and Historic Assets
• Highways and transport (including PROW)
• Access to the site and public rights of way (PRoW)
• Noise
• Common land
• Planning conditions

Landscape and Visual

• Bute relies heavily on own “professional judgment”
• The non-negotiable position of turbines on the top Radnor Forest, public “expectation” that hills will have windfarms on top, and highlighting alternative views in other directions repeatedly downgrades judgement of significant impacts.
• Bute relies on screening from trees etc. obscuring turbine views but this will change over project lifetime.
• The FI appeals to the Pre-assessed Area defined in 2021 when turbines were much under 150m.
• Tabled differences (in Appx 4) between Bute (LUC), Powys CC (Enplan) and CPRW-Rethink (Munro) assessments are individually small but nevertheless add up to very different overall conclusions about the significance of impact on the local landscape and visual amenity. This is particularly where the Bute assessment applies to smaller radii and the result falls below the threshold of significance
• Landscape Character Areas (ES figs.5.09 & 5.11e) are critical examples. The discussions of LCA 50 (2.31-3) and of many specific viewpoints ignore the fact that Aberedw Hill Energy Park is proposed within LCA 50.
• Munro considers that impacts on Property 20, The Mountain, cross the threshold of making a residence “unpleasant to live in” due to the WF
• Bute disputes significance of impacts on BBNP.
• Bute disputes impact on Presteigne and Norton Dark Skies Community on the basis of one night view from Knighton observatory already in ES ( Figure 5.57d) and mitigation for obligatory aviation lighting on 14 outer turbines, defending photomontages showing dimmed lighting. The impact on dark skies within RDNRVS 108 and the consequences for biodiversity is not mentioned.

Cumulative Effects with other Projects

There are 6 key projects:

• Aberedw Hill Energy Park
• Bryn Gilwern Energy Park
• Rhiwlas Energy Park
• Banc Ddu Energy Park
• GreenGen Towi-Usk Project
• GreenGen Bryn Gilwern Overhead line

• These are all Bute or sister-company GreenGen projects about which Bute is fully informed.
• Bute has revised the cut-off date to 2/3/26 and the cut-off project stage to post-Statutory Public Consltations bringing Aberedw Hill, Rhiwlas and Banc Ddu under consideration
• The FI refuses to include these in the cumulative assessment because it is for each of these to include the consented Nant Mithil in their forthcoming applications.
• Bute has removed the draft consultation applications from Rhiwlas and Banc Ddu from their own websites but none of the Full Application documents submitted to PEDW on 23/12/25 are on the PEDW website.
• Bute refuses to consider the cumulative impacts of the GreenGen Towi-Usk line, upon which its energy production depends, in spite of a recent Scottish judgement on the similar Raeshaw case suggesting that environmental assessment of the export line should be included in the PEDW decision for Nant Mithil.
• Adjacent Hendy wind farm was approved without a grid connection and has been inoperative for 5 years during which Powys considered it “not expedient” to enforce the Condition designed to prevent this. There must be no risk of this happening with a project of some 13 times the capacity and corresponding environmental impacts.
• In stark contradiction to the remainder of the FI, and in response to NRW, the Shadow Habitats Regulations Assessment (sHRA) for the Wye SAC (FI Appx.6) does consider the GreenGen Towi-Usk Project and mentions other wind projects, including Banc y Celin, but does not mention the other three more advanced Bute/GreenGen developments in the SAC catchment.

Ecology and Ornithology

• The FI has not addressed the new addition of Starling to the Section 7 list of species – of particular significance because nearby Hendy windfarm is built around a major roost and when operative Hendy turbines will pose a cumulative risk with Nant Mithil.
• Bute challenges NatureScot advice on risk to Golden Plover and dismisses concerns about curlew and nightjar.
• Bute says the impact assessments in the ES determine the need for mitigation and the different purpose of the (unaltered) OHMP is to set out the measures “capable” of delivering Net Biodiversity Benefit, but without definitive details until post-consent.
• Responses querying whether the OHMP is capable of delivering NBB are ignored
• Insects including those on the Section 7 list have not been considered in the ES (apart from contradictory statements in the OHMP). While absence of evidence is not evidence of absence concerning impacts on insect populations, there is some evidence that windfarms risk strike mortality and habitat loss (for examples, see Voigt, Weschler & Tronstad).

Peat/soils

• FI argues that there are no irreplaceable habitats, including peat, at risk on site and FI Appendix 8 Technical note on Great Rhos Soil and Hydrology establishes no hydrological connection between infrastructure sites and the peat environment of RWT SSSI.
• FI Appx 9, an improved resolution version of ES Peat Depth Plan , shows that Phase 1 probes, covering most of the site, do not distinguish whether soils <30cm deep are peat, peaty loam and organic mineral soil and there is peat >30cm within 50m of cut and fill sites.
• There is no further discussion of soil impacts of cut and fill and construction over steep gradients, areas of disturbance alongside tracks and other infrastructure as highlighted by CPRW.
• There can be no micro-siting mitigation for any type of soil impact given a Condition specifying “peat” and also that the impact should be no worse than from the ES layout.

HydroGeology

• The new sHRA dismisses impacts of the export line because it does not share any watercourse crossings with Nant Mithil although it does share the major risk of sediment from earthworks entering the Wye rivers and it straddles water courses at many locations upstream.
• sHRA promises mitigation for fish in the Habitat Management Plan (HMP) but the exiting Outline HMP has not been altered accordingly.
• sHRA has replaced a defined working period from mid-June to September with “drier periods where possible’, also repeated in FI Appx.7.
• The new Water Framework Directive Assessment (FI Appx.7) is not updated for the interim 2024 WFD results available on WaterWatchWales.
• Potential impacts of water-crossings on fish are treated in new detail but illustrations are not provided and the exhaustive analysis of potential impacts is made redundant by the blanket conclusion that all can be fully mitigated by generic standard measures. The mitigation embedded in water-crossing design offers “as far as possible natural channel conditions, sediment regime and free fish movement”.
• LIR: “The Applicant has engaged with the SAB and the pre-application response will inform the detailed drainage strategy that is secured by planning condition”. Powys LIR Appx 5: SAB letter 27/3/26 is not available. Any information about drainage and infrastructure design which is not already included in the ES should have been in the FIR.

Cultural Heritage and Historic Assets

• The FI new Listed Building assessment (FI Appx 11) relies on description of “settings” of key listed buildings as independent of the Radnor Forest landscape. This technical matter of definitions downgrades the impacts, with The Pales Quaker Meeting House building as the key example.
• Bute insists that noise and shadow flicker impacts are irrelevant to “settings” of Listed buildings, in which case they should have been assessed as cumulative impacts.
• Bute says arguments that assessments of heritage impacts at Hendy used a higher bar are irrelevant but the public expects a higher, not a lower, bar for Nant Mithil turbines twice the size

Highways and transport (including PROW)

• The FIR maintains that any further information, including chosen route and site entrance, can be delayed until post-consent.
• FI Appx 14 is identical to ES Appx 4.6 with omitted page LUC 16 (p1 of Table 1) now included.
• Bute’s commitment to seek a condition satisfying WGTD and work with Hfs Council post determination if the Southern route is selected adds nothing because these are unavoidable.
• Bute ignores responses questioning the viability of the described transport routes at particular locations, including Eardisley, Glasbury (where Powys CC considers the bridge would need replacement) and the Heart of Wales railway bridge at Crossgates.
• Layby availability, the traffic impacts on the A44 close to the site, and the impacts in combination with those of other Mid-Wales infrastructure projects are not explored further.
• For PROWs, FI Appx 13 considers “oversail” instead of “topple-distance”, because a topple-distance buffer in BHS and Powys requests is unachievable.
• In FI Appx. 13, ES Fig 4.13 is revised with poor quality but correct oversail areas some of which still impinge on PROWS.
• FI Appx. 13 has 3 examples of potential PROW diversions (T13 is the worst) highlighting how avoidance and minimisation of impacts on PROWS was given little weight in the infrastructure layout.
• There is no further information about closure of PROWS during construction.

Noise

• No further public information is offered
• To justify a higher noise allowance at the closest property (the Warren) , the FIR claims that the tourist accommodation does not require the same protection as any other tourist accommodation.
• The FIR dismisses the impacts of low frequency noise, ultrasound and vibrations with references to research studies but without reference to evidence presented in public responses.

Common Land

• The FIR does not address the fact that replacement land is already open-access with the further disadvantage of being in three discrete pieces.
• “Amenity gain” of the replacement land, does not offset the amenity loss of transforming an extensive wild hill landscape into industrial development of unprecedented size .
• The inevitable extent of heavy PROW use and protective fencing-off, particularly the main BOAT haulage route during the 2 years of construction, is not addressed by the general description: “on a rolling basis”, “in the interests of health and safety”.

Planning Conditions

• The conditions are improved but still push to extend established constraints
• C8. Construction hours. Applicant’s position vs Powys position adds 11 hours/week which is an unacceptable increase in disturbance during leisure hours for local communities and road-users
• C11. At least items e.,f.,g,h.and k. and C12 should be Prior to commencement to avoid any environmental destruction on site before establishing the viability of AIL access. This should be reflected in C14.
• C16. HMP circumstances where HMP updates would operate should have been specified in the OHMP
• C19. Should be Prior to commencement to avoid any environmental destruction on site before there is certainty about the mitigation obtained by the specific crossing designs. “Prior to commencement” should specifically include “prior to vegetation clearance” to prevent invalidation of ecological surveys.
• C32 & N/A Aviation Charting and Safety Management. There is no reason to deviate from MoD Position (REP103). “Prior to commencing construction of any wind turbine etc.”, “should be approved by the WG and MoD etc.”.
• C39. 6 months instead of 12 months. Hendy had a condition requiring removal of turbines inoperative for 6 months which was not enforced and therefore a similar Condition allowing 12 months of idleness offers no reassurance.
• C41. There is no reason to deviate from LIR position specifying the structure of the plan and including restoration
• C42. 10 years interval too long in view of declining efficiency of turbines over 15 years old and unpredictable wind energy markets.

SELECTION OF OTHER THEMES RAISED BY RESPONDENTS WHICH HAVE NOT BEEN ADDRESSED IN LIR AND APPENDICES

1. Dimensions and number of turbines: FI Appx 19 does not specify maximum hub height therefore any environmental information derived from blade length cannot be relied upon. The majority of responses pointed out that Mid-Wales Radnorshire Hills is an inappropriate area to act as guineapig for the first Wind project of this scale in the UK. The FIR report avoids any comparative evidence about existing turbines over 200m.
2. Facts about infrastructure: FIR and Appendices ignore CPRW-ReThink request for clear information, eliminating inconsistencies, about areas of permanent land-take and surface area and soil disturbance with arrangements for cables and drainage and protecting PROWs, and construction on steep inclines. The lack of previous experience of this size and number of turbines to draw on makes this all the more important.
3. Onsite portion of GGTU OHL: FIR and Appendices ignore CPRW-ReThink request for a full description of the onsite elements with environmental impacts, including on the site access points and A44 approaches.
4. Adjoining Land use: No information about impacts on Ravenscar (Radnor Range), an approved MoD Test and Evaluation (T&E) range, has been supplied (2025-12-08 – REPS135 – Gary Burton).
5. Surveys in Applicant’s Environmental Statement: Neither Section 7 nor Red-listed Birds of Conservation Concern have been adequately covered in survey data.
6. The Stepwise Approach: The first step, Avoidance, has not been sufficiently applied. Bute has proposed wind farms on nearby “alternative sites” which are thereby disqualified from consideration.
7. Increased flooding downstream: “The Applicant has engaged with the SAB and the pre-application response will inform the detailed drainage strategy that is secured by planning condition”. If information not included in the ES, FIR or Appendices is included, this should be open to further public consultation.
8. Shadow-flicker: A better estimation of shadow flicker impacts is possible. The applicant will not have land rights to plant off site vegetation. It should not be a resident’s responsibility to seek shadow-flicker mitigation.
9. Impacts on Tourism: Existing evidence is not tailored to the cumulative impacts of five large scale Bute/GreenGen projects in close proximity, with the notorious Hendy windfarm included in the cluster. LIR Appx 17 statement that the project “could help broaden the economic base of the area surrounding the site by creating income generating opportunities” ignores the many responses from tourist operators on the risk to their farm diversification businesses.
10. Community Investment: The agreed £7,500 per megawatt of installed capacity for community investment (approx. £1.5million) should be assessed against the distribution of £58 million to Bute Energy directors before Bute has permission for Nant Mithil or constructed any windfarms. (see Nation Cymru articles)
11. Outline Habitat Management Plan: No further information about need to ensure delivery of HMP as in CPRW-Rethink and Powys LIR responses or the queries about evidence for Net Benefit for Biodiversity.
12. Outline Construction Environmental Management Plan: FIR and Appendices ignore CPRW-ReThink comments on the lack of opportunity for the public to express their views on a post-consent plan with far-reaching implications for the environmental impact of the development.
13. Well-being of Future Generations: FIR Appx 17. fails to understand the WBFGA which obliges decision-makers to consider all 7 goals. The “Resilience” goal is about healthy ecosystems, about which there are numerous responses emphasising ecological benefits.