Support conversion not demolition of Bradley Lane

Friday 8th October saw the public release of the planning application for Bradley Lane in Newton Abbot (22/01500/MAJ), writes ACT Wildlife Warden Eloise Rokirilov.  Long pending, starting at 171 documents and growing, the expiry date for comments remains at 4th November. The application calls for wholesale demolition of all the buildings, the burial and diversion of the medieval leat, and the construction of 90 new residential properties.   

Why is Bradley Lane of interest or importance to anybody? 

Of environmental as well as historic and archaeological importance, Bradley Lane is a brownfield site containing a set of attractive mill buildings, and a medieval leat that runs through the valley and into the town, joining the River Lemon underground near the Jolly Farmer. Mills have been sited on or around the area since the 13th century. They were originally built to serve Bradley Manor, the nearby Grade I listed National Trust property.  

The buildings are a testament to the wealth and contribution of the Vicary family, who were key to the industrial prosperity of Newton Abbot. Employing around 700 people at its peak in the 1800’s, the family’s substantial business interests included wool milling, fellmongery (stripping wool from sheepskins) and tanneries. With the increasing use of synthetic rather than natural materials, among other things, the business finally closed in 1972. Bradley Lane cottages were, of course, workers cottages in their time, and there is a WW2 bunker between the mills and the old Benbows buildings.  

Suffering repeat destruction from fire and flood over the centuries, the mills were proudly rebuilt on each occasion. The current buildings display a family plaque, “JV & S Rebuilt 1883”, celebrating its reconstruction in this year before its penultimate catastrophe, there also being a fire in 1921. 

The mill buildings are far from the end of their life, being built of red brick, Devon limestone and local clay brick, some of the strongest material around. Historic England and the government themselves have started shouting more loudly about the need to avoid demolition, and instead retrofit and convert buildings as a way of meeting net zero. In a climate and ecological crisis, this makes sense. Demolition releases substantial carbon and other particles into the atmosphere.  

Purchased by Teignbridge District Council in 2010, the mills continued to be used for commercial purposes. The council profess a long term intention to develop the site, and is proud of championing social housing on a brownfield site. Councillors state the intention is for the proposed development to include 44% affordable housing. However, the Viability Assessment report indicates a flat refusal by the developer to provide affordable housing as it is not financially viable. Instead, the intention is to sell 18 of the 90 units (20%) to the Guinness Trust, which will provide social rent housing. Homes England have offered funding of £2,063,400. 

More crucially for the environment, the Waste Audit Statement shows striking, estimated figures:  

  • 14,000 tonnes of concrete, brick and stone to be demolished, and recycled on site. 
  • 240 tonnes of asbestos to be removed and transported to landfill. 
  • 5 tonnes of greenery to be cut down and recycled off site. 
  • 450 tonnes of tarmac to be recycled on site. 

The present site has young trees on the west side by the River Lemon, and semi mature trees at the base of Hunterswell Road, where the recent bus survey proposed to put a bus lane, but according to this application, will instead have one self build plot on it.  

The Ecological Mitigation report shows thorough work on bat surveys, although it does not mention the leat, which is known to contain European eels, a protected species. However, it has general ‘mitigation’ measures for amphibians and reptiles. There are more details in the 2019 survey report showing that the site is within the South Hams SAC for Greater Horseshoe bats, and located within a Devon Great Crested Newt consultation zone. Also that otters had been recorded within 1km of the survey area. Mitigation will involve staged cutting, in order to allow nature to escape.    

Arsenic is recorded at 15 times the acceptable level and “the results of the risk assessment have shown that the concentration of arsenic within the upper made ground and lower natural soils poses a potentially significant risk of causing harm to end users of the environment”.  The document nonetheless maintains that there are no concerns of contamination, danger or pollution to people or the water course. 

 Newton Abbot & District Civic Society applied to Historic England for listing for the buildings, as well as to TDC’s own Community Asset Register, which would also allow a Community Right to Bid should the owner decide to sell. The latter issued a flat rejection stating, “the buildings do not fulfil the requirements of the Localism Act 2011″. They also failed to meet the listing criteria for Historic England. They were noted for their strong local importance, but did not meet enough national criteria and had suffered too many changes over time. TDC did not respond to requests for  internal viewings of the buildings, so any internal features could not be noted in the application.  

Having evicted their last commercial tenant in March this year, TDC is presumably paying each month for the buildings, which could explain the determination to succeed with the current planning application, in an effort to recoup finance and resolve the future of the site. Of the evicted commercial tenants, at least two returned to Torquay, losing business for Newton Abbot. Benbow Interiors moved to the Brunel estate in 2019 in a deal that saw a new, funded site being built for them.

NADCS had already engaged a national charity, Save Britain’s Heritage, who took the time to visit Newton Abbot with an architect in tow, and were inspired to produce a 32 page report with architectural illustrations showing an entirely different vision for the site. They advised it is possible to accommodate 111 homes by way of conversion and some new build, including 28 affordable homes, which is more than the present application. The architect has worked on some major post-industrial sites including Heartlands in Cornwall and Sarsons Vinegar Factory in London. There are many examples around the country of successful conversions, including Digbeth in Birmingham and Finzels Reach in Bristol to name two more.  

We are in a time of mass development, and a common theme of lack of affordability. Cranbrook in Exeter is currently in the news with another 1,000 houses proposed on 220 hectares of former farmland. The question has to be asked, where does it end?

With a deadline of 4th November, we would urge readers to comment on the planning application, and support conversion instead of demolition.( and search reference 22/01500/MAJ).

Other links:

Power Allotments Devon

On Tuesday 13th September I attended a webinar to introduce Power Allotments Devon along with colleagues from TECs.

This Devon wide project hopes to encourage local communities to build, own and benefit from their own renewable energy power station projects across Devon, creating spaces for biodiversity net gain and generating an income for local people.

To find out more you can visit the Power Allotments Devon website, here you will find a toolkit which includes a handbook, interactive map, and submission form which enables you to identify and submit possible sites.

They are running a webinar on 27th September at 2pm to explain it in more detail.

Why are electricity prices rising?

We examine the reasons behind the dramatic rises in electricity prices following the unprecedented rises in fossil fuel prices, and why reductions in renewable prices have had no effect.

We examine the reasons behind the dramatic rises in electricity prices following the unprecedented rises in fossil fuel prices, and why reductions in renewable prices have had no effect.

Fossil fuel prices have risen dramatically since 2021 and particularly since May 2022. The price of gas and oil in particular has soared. Gas is still used for a large part of electricity generation, as well as directly for heating. Because of the way the wholesale electricity market works, the price of gas normally sets the price of electricity.

See Ofgem for current information on wholesale prices

How the wholesale electricity market works (simplified)

Electricity retailers pay the wholesale price for electricity they sell on to retail customers. The electricity demand in any period needs to be balanced to generation. This balancing is done by a bidding process where generators bid to generate in a period. The Electricity System Operator (ESO) ranks the bids in merit order with the lowest price first, and then adds up the generation capacity until a marginal generator is found. The price paid to all successful bidders is the price paid by the marginal generator. Recently the marginal bidder has often been a gas generator.

For a more detailed explanation

Forecasts for the price cap

Domestic customers on standard variable tariffs are protected from excessive charging by a price cap, which is calculated periodically by Ofgem based on predictions of market prices for the upcoming period. In April 2022 the price cap rose sharply to 28p per unit for electricity, and in October 2022 it will rise to 52p. Consultancy Cornwall Insight predicts that the cap will rise a further 51% at the start of January to about 80p per unit, and a further 13% in April to about 90p per unit.

Ofgem cap methodology change

Historically Ofgem calculated the cap six monthly, based on forward prices wholesale price estimates. Recently wholesale prices have been volatile, and suppliers have had to pay more for electricity than was predicted. In order to avoid further supplier failures, Ofgem have introduced some changes:

  • The cap will be recalculated at 3 monthly intervals from October onwards.
  • A backwardisation calculation has been introduced which introduces compensation for the excess of actual wholesale prices for the previous period over those predicted in advance of the period.

These changes compensate suppliers for additional costs they have incurred and have the effect of increasing the cap more than would otherwise have been the case.

Energy Price Guarantee

Since this post was written the government has announced an energy price guarantee, which replaces the energy cap. This means that effectively the cap on electricity prices will be 34p.

For further about this announcement are here.

Some help for businesses has also been promised.

You might have thought that the simple measure of boosting onshore renewables would have been an obvious step to shorten the period that the government had to finance this intervention. The government hasn’t done this, instead it is lifting the ban on fracking, launching a new round of oil and gas licencing, and carrying on with nuclear projects. None of these actions will make any difference in the next few years to energy prices, but they will certainly cause increased carbon emissions.


Most domestic electricity customers expect to buy electricity at a fixed price per unit, very few would accept a tariff which offered a different price for each half hour period (to the author’s knowledge there is only one such tariff). This means that electricity retailers need to find a means of fixing the price of the electricity they offer for the period of the contracts they offer, to do this they buy contracts to supply electricity at an agreed price at a future date. This practice is known as hedging. The failure of a many smaller suppliers to hedge adequately in 2021 lead to the large number of supplier failures last year.

The cost of renewables

Between 2009 and 2019 the price of electricity from solar generation dropped by 89%, and the price of on-shore wind dropped by 70%. A similar thing has happened with off-shore wind.

A similar thing has not happened with Nuclear.

Why did renewables come so cheap so fast? discusses the price drop in more detail.

This rapid cost reduction for renewables has resulted in electricity from gas costs roughly 4 times as much as from renewables.

Renewables have a high initial capital cost and low running costs. Initially subsidies were required to get the market established and get the benefits of scale. There is significant future price risk if renewables were to be funded based on future receipts, the cost of capital is substantially reduced if this risk is mitigated somehow.

Support methods for renewables

Early renewables were subsidised by the Renewables Obligation (RO) and Feed In Tariff (FIT), which are currently paid out of retail electricity bills. More recently renewables have been financed by Contracts for Difference (CfD), which now tend to reduce electricity prices. All domestic renewables are now privately funded. Given current prices some grid scale renewables are also being funded without subsidy.

Renewables Obligation

The RO requires electricity suppliers to buy a proportion of Renewables Obligation Certificates (ROCs) from generators registered with the RO scheme. ROCs are issued by Ofgem to registered generators. There is a monthly reconciliation to ensure that suppliers have either bought enough certificates or pay a penalty known as the buy-out price.

For further information see

RO closed to new generators in 2017, but will continue to operate until 2037.

Each year BEIS calculates the amount of ROCs that need to be issued to meet proportions of renewables fixed in the 2015 Renewables Obligation Order (ROO). For 2022-3 the number of ROCs is set at 124.5 million. From this a rate of 0.491 ROCs per MWh is set for GB, this is a drop from 0.492 in 2021-2.

Projects remain in the RO scheme for 20 years, the scheme started in 2002 and closed in 2017, so we expect to see the number of generators in the scheme falling from now on, so the number of ROCs required will also drop.

ROCs are traded in the market, and are normally sold above the buy-out price set by Ofgem. Suppliers are prepared to do this because they receive a share of the buy-out money in addition to meeting their obligation.

The buy-out price is set by Ofgem each year by rules determined by the ROO and is linked to RPI. For 2022/3 it is set at £52.88/MWh

Feed In Tariff

Feed in Tariff is paid to domestic generators and smaller grid scale generators. It is paid regardless of how the electricity generated is consumed. The rate paid depends on when the scheme was joined and is inflation linked. The last FIT installations were done in 2019, though the rate was far lower than early installations in 2011.

Electricity generated under FIT must be measured by a generation meter. In December 2021 Ofgem published rules that must be applied when FIT registered plant is replaced or modified, essentially:

  • If the generation capacity is increased, then the meter reading is adjusted pro-rata when calculating the amount of FIT payable.
  • If storage is installed behind the generation meter, then it must not be possible for electricity to pass from the grid side of the meter to the generator side of the meter. (Otherwise it would measure electricity that hadn’t been generated by the plant).

For further information see Ofgem ruling.

Contracts for Difference

New renewables are supported by Contracts for Difference (CfD). Periodically there is a CfD auction where generators bid a strike price for the period of the contract. For each technology the auction is for an amount of generation. The result of the auction is a strike price for each technology. If the wholesale price does not meet the strike price then generator is subsidised from electricity bills. If the wholesale price exceeds the strike price, then the generator compensates electricity bills.

This subsidy is managed by a government owned company—the Low Carbon Company. 

In recent CfD auctions prices have fallen, and record amounts of renewables have been contracted.

Since the end of 2021 the electricity wholesale price has mainly been above the strike price, so CfD has acted to reduce electricity bills. In a climate of higher wholesale prices this will continue.

See Low Carbon Contracts Company Historic Dashboard for payments for recent data.

Other electricity charges

As well as wholesale electricity costs, retail electricity bills also pay for network costs, social and environmental obligations, other direct costs, taxes and operator’s margin.

Environmental and Social costs aka Green Levies.

Environmental and Social costs are often referred to as ‘Green Levies’ and currently amount to about 12% of electricity bills. The breakdown of environmental and social charges is shown on the left.

RO and FIT schemes have now both ended, so the amount of generation in the scheme won’t increase and will start to fall, but payments are linked to RPI, so the costs will increase. These are both contractual agreements.

ECO and WHD assist those in fuel poverty to improve the insulation standards of their dwellings.

Figures derived from Energy bills: getting the balance right

Cost of failed suppliers

When a supplier fails another supplier is found to continue their supply. Other costs associated with the failure are shared between the remaining suppliers, who pass this on via electricity bills. This has resulted in a near doubling of standing charges for electricity this year. According to this article the cost of failed suppliers is estimated at more than £2.7bn.


The electricity market has grown to be very complex, this brief note doesn’t touch on many aspects of it. As with many things that have grown complex there is a temptation to think that it would be simpler to start again, if this is done it should be done with care.

BEIS has launched a consultation Review of Electricity Market Arrangements (REMA), which runs until October. This is far reaching, recognises some of the current problems, and could eventually achieve a more workable market, however, it is unlikely there would be any change from this for several years.

Council’s carbon reduction targets won’t do the job

Following its Climate Emergency declaration three years ago, Teignbridge District Council has published and adopted Part 1 of its Climate Action Plan. Part 2 is expected later this year.

Action on Climate in Teignbridge (ACT) welcomes the long-awaited plan, believing it is an essential first step in delivering on the council’s commitment to be a carbon neutral district by 2025. It is excellent to see standards set, but ACT has concerns that the emission reduction targets included in the plan are based on outdated data and will not make the difference we need to see.

Part 1 of the plan sets out how the council expects to reduce carbon emissions in its own sphere, in things it owns, purchases, funds and supplies. Part 2 will cover the wider district, including transport, housing, businesses, land use, energy and infrastructure.

The plan includes 39 actions, four policies and 11 targets. ACT has no major problem with the actions or policies. It is primarily the targets that need further work.

Carbon emission targets are set by reference to a carbon budget. The budget sets a limit on the cumulative amount of greenhouse gases an organisation, a country or the world can emit that gives a significant chance of limiting global warming to 1.5C above pre-industrial temperatures. It is like a financial budget, where you set yourself weekly or monthly spending limits so you don’t go overdrawn.

In the case of carbon budgets, the limits are how much carbon can be emitted over a time period, to make sure we don’t trigger runaway climate change. We can’t afford the equivalent of an overdraft when it comes to the climate!

Carbon budgets have to be adjusted as the average global temperature rises and to take account of whether targeted emission reductions have been achieved. Global warming has now reached 1.2C and we are on track to reach 1.5C by the early 2030s, if not earlier. The tighter the budget, the more likely we are to limit global warming.

The Teignbridge plan states that the council aims to limit its cumulative emissions “to levels consistent with 1.5°C and well below 2.0°C of global warming”. This needs revising as, at the COP26 climate meeting held in Glasgow last year, governments agreed to make 1.5C the firm limit to aim for, due to the risks of allowing any further warming.

The basis for setting the council’s carbon budget also needs revision, as the budget calculation uses data from a 2018 study. That doesn’t sound too out of date, but there has been a significant rise in average global temperature since then. Moreover, setting targets for emission reductions based on this budget means they fall well below the UK government’s legal requirements.

ACT believes the council should use the government’s statutory carbon budget to set its targets. It would be even better if it used the Paris Agreement targets, as ACT has proposed.

There is a big difference between these various targets. The annual emission reductions required under the Paris Agreement (for a likely, or 67% chance of staying within 1.5C) are 10.4% year on year. To meet the UK’s statutory requirements (for a 50/50 chance), they are 7.9% year on year. The Teignbridge plan targets are based on a study that recommends a minimum carbon reduction of 4.2% flat rate.

There is another issue: the targets only include the council’s direct emissions. These are mainly from heating council buildings and fuel used in the council vehicle fleet. These are known as scope 1 and scope 2 emissions, and only account for about one-third of the council’s annual emissions. The bulk of the emissions, known as scope 3, are indirect, from stuff the council buys, mainly for building work and services they buy in.

The plan does have ambitions to influence the council’s suppliers with regard to scope 3 emissions, but they are not included in the targets.

Finally, while most of the 39 actions in the plan are good, some excellent, there is no indication of the expected emissions reduction for each action, or the timescale involved. ACT believes this should be addressed as soon as possible, and that a regular review of progress against the expected reduction for each action should also be part of the plan.

Teignbridge District Council still has work to do on its Carbon Action Plan.

We need more renewable energy and a new pricing system

The jolting rise in the price of energy should help focus minds on the urgent need to speed up the transition to renewable energy sources. We need to make that switch to reduce greenhouse gas emissions, but it would be good if it also helped reduce and stabilise energy prices. 

That’s not guaranteed under the current pricing system for electricity, where the price we pay is mostly set by the market price of fossil fuels, even though these only generate around 40% of the energy we use each year. Renewables are now the cheapest source of energy and supply more than 40% of the UK’s annual electricity consumption. But some gas generation is needed most of the time. So electricity prices are still tied to oil and gas prices. That’s why they are currently so high, and set to rise further.

It looks like we need more renewable generation and a new pricing system, especially as electricity consumption is set to rise significantly as we seek to decarbonise our heating and transport. The government’s target is for the electricity supply to be net zero by 2035. This can only be achieved by a major increase in renewables and nuclear power, along with a big reduction in the energy we use. We need to cut out unnecessary consumption and retrofit our housing stock.

Onshore wind turbines and large solar farms are the cheapest ways of creating energy, green or otherwise. Wind has the advantage, though, of using far less land than solar and is more efficient. It also has the lowest ‘embodied energy’ per unit of energy generated– the energy required during manufacture– of any form of energy production.

The first wind farm in the UK was opened at Delabole in Cornwall in 1991. Between 2009 and 2020 wind energy in the UK grew by 715%, but most of that generation is onshore in Scotland and offshore, mainly along the east coast of England. Onshore wind was effectively blocked in 2015 when the government banned public subsidies for onshore wind farms. The ban was dropped in 2020, but there are still tough planning requirements. 

The history of wind energy means existing sources are a long way from Teignbridge, involving electricity transmission losses. You may have noticed it can be pretty windy in Devon. Indeed, the South West is second only to western Scotland as the most exposed part of the UK. We should make the most of our natural advantages! 

Teignbridge District Council agrees and recently consulted on potential sites for wind turbines in the district. Action on Climate in Teignbridge put in a response to the consultation supporting the creation of onshore wind sites, provided they minimise adverse effects on the environment. Badly designed wind farms can damage bird and bat populations in particular. 

They can also be unpopular with residents. That’s partly why there was an effective ban for several years – wind turbines were regarded by some as a blight on the landscape, and noisy as well. On the noise front, wind turbines are now remarkably quiet. For planning purposes, noise from turbines must be shown not to add to the constant background noise levels for no further work to be required. 

There is not much to be done about the visual impact of most wind turbines. Like electricity pylons, roads and housing developments, they are man made structures in the natural environment.

It seems we are more likely to accept new structures that are familiar to us, like roads and housing. This is despite them having a greater detrimental impact than wind turbines both visually and ecologically, not to mention their high greenhouse gas emissions. Roads and housing are also more likely to persist for a lot longer than wind turbines, if eventually we are able to generate our energy from other low carbon technologies. We could also limit wind turbine deployment if we become more careful about how much energy we consume and distribute energy better.

But even if we build wind farms wherever we can in Devon, taking into account factors such as whether there is enough wind, the proximity to the grid and protected nature areas, less than 2% of the county’s total land area would be occupied by wind turbines. That compares to 5% of land in Teignbridge that has been built on. That doesn’t sound too bad for a technology that will help meet our carbon emission reduction targets and potentially be a source of cheap energy.

ACT’s response to Part 3 of the Local Plan consultation

Teignbridge District Council’s current Local Plan, which runs from 2013-2033, is being revised and extended to cover the period 2020-2040.  Part 1,  which specifies the policies associated with new developments including renewable energy, was consulted on in 2020. The result of the consultation and any changes coming out of it are as yet unpublished.  Part 2, consulted on in mid 2021, covered what TDC describes as major sites for housing and employment.

The current consultation is on Part 3, covering sites for renewables (wind and solar), small scale housing and travellers. The consultation closes on 24th January 2022.

ACT is not responding to specific sites, where these are listed, unless we have identified a particular concern in relation to climate change or ecological impacts.  Instead, our response is to the broader aspects of these proposed sites and the associated policies/criteria that govern their selection.

We encourage everyone to respond individually, especially regarding specific sites they are familiar with.  It is important to include comments that address the criteria identified by the council in the consultation.  Not doing so may result in the comment not being given the weight it may otherwise deserve.

Although you are strongly encouraged to respond online, ACT’s response will be sent by email to This is because there is no facility to do this using the online facility other than for solar PV where there are no individual sites identified. 

Responding to part 3 of the local plan consultation- sites for renewable energy

ACT plans to respond to the wind and solar energy section of TDC’s third part of its consultation on the local plan. We encourage you to do the same. To find out more about these proposals, how to respond and how to share your views

oOn 15th November Teignbridge District Council launched the third part of its consultation on the Local Plan. This third part of the consultation covers Renewable Energy, Gypsy and Travellers and Residential Sites Options.  The consultation closes on 24th January 2022.  The renewable energy part of the consultation covers site options for wind energy as well as policies in respect of wind and solar energy.

ACT plans to respond to the sites and policies for wind and solar energy.  We encourage you to do this direct to TDC.  We also welcome your views and comments, so we have included a facility for you to do this. 

We believe that renewables are an essential part of the overall effort to remain below the climate tipping point, caused by temperature rise of more than 1.5oC.  For more information on Climate Change please refer to Why this is an Emergency.  To read about actions needed, please see our Energy & Built Environment webpage.

When responding to the TDC online consultation, each wind site has a number of criteria against which free text can be entered.  You can also comment on policies associated with the potential solar areas identified for Teignbridge.

To help you see all the information provided by the consultation, as well as other related information, we have extended our Local Plan mapping data web page to cover proposed wind sites. Please read the instructions first to learn about how to use this data and how to enter comments you’d like to share with ACT against each site.

Although solar PV, especially with Li Ion battery storage has its part to play, this is mainly for smaller behind-the-meter applications.  Ideally rooftops or ground mounted close to buildings.  The following headings therefore represent our current views on the Part 3 consultation for wind.  We welcome your input on this.

Why we need local wind

In order to stand any chance of restricting global temperature rise to 1.5˚C above pre-industrial levels everyone needs to cut their greenhouse gas emissions as fast as possible. According to Our World in Data 73.2% of global greenhouse gas emissions are attributable to burning fossil fuels to generate energy.  To rapidly reduce emissions from energy production we all need to:

  • Reduce energy consumption, i.e. cut out waste and reduce non-essential consumption.
  • Increase the efficiency of the devices/processes that use this energy, e.g. A rated or higher.
  • Electrify transport, heating and industrial processes as these are the main consumers of fossil fuels.  Electrification is currently the most effective way to decarbonise energy as renewables become more widely deployed.

Electrification of transport and heat will increase electricity demand, if sufficient low carbon generation isn’t added, this could cause the Carbon Intensity of grid electricity to increase, the opposite of what is needed.  This is because more gas will be used to supply the additional energy needed.

The first wind farm in the UK was opened at Delabole in Cornwall in 1991. Between 2009 and 2020 wind energy in the UK grew by 715% , but most of that generation is on-shore in Scotland and off-shore, mainly the east coast of England. These are a long way from Teignbridge involving electricity transmission losses.

On-shore wind is a mature technology, which is also currently the cheapest source of electricity and has one of the lowest Carbon Intensities.  It is needed as part of the energy mix and can be deployed now.

Teignbridge currently has negligible wind generation, but has significant solar generation in the sunnier summer months. In winter, just as energy is needed for electrified heating (e.g. heat pumps), the local Carbon Intensity of the electricity supply is at its highest. If supply and demand were better matched for more of the time, Teignbridge’s Carbon Footprint would be reduced.  Wind generation is highest during the colder months.

How much of Teignbridge’s demand could be generated

The consultation estimates that an additional 10,000 homes would require 66GWh of electricity per year, so each home is estimated to consume 6.6MWh of electricity per year. If this level of consumption were repeated across all homes in Teignbridge after full electrification of heating and transport, then annual demand would be in the region of 462GWh.

The University of Exeter has estimated the generation from the sites identified in the consultation would be 217GWh using a mix of 1MW and 2MW wind turbines, this would be 47% of Teignbridge’s estimated electricity demand.

Wind turbines are designed for an IEC wind class from I for the strongest winds through to IV for the lowest wind speeds. The site with the strongest winds in Teignbridge has class II winds, most are III or IV. Turbines designed for class I winds have much smaller rotors and towers than those designed for class IV for the same power rating.

We believe that it would be more effective to place higher rated turbines at sites with the strongest wind classification.  This is not only more cost effective but also minimizes some of the potential adverse impacts of having wind turbines in Teignbridge.  We believe such an approach would probably meet or exceed all of Teignbridge’s estimated electricity demand.

We have placed turbines in line with the consultation to illustrate their potential impacts.  Using Local Plan mapping data web page, you can see the example turbines placed to comply with various restrictions.  Two example scenarios can be selected, those specified by the consultation (default scenario) and fewer higher rated turbines.  We have done this to illustrate the reduced noise impact of these higher rated turbines.

Proximity to Housing- Noise from wind turbines

Modern wind turbines are remarkably quiet compared to a decade or more ago. We have provided visual outlines where the sound power from the turbines is just lower than 45dBA, 40dBA and 35dBA.  The noise level inside a quiet library is 35dBA, 40dBA is the level in a quiet rural area when the wind is not blowing. When placing turbines on the maps, the default noise level at neighbouring properties is set to be less than 40dBA.

Many of the proposed sites have a relatively high ambient noise level, often from road traffic and proximity to built up areas.  While an ambient day time noise level in some location may well be 35dBA or less, this is quite unusual in the vicinity of the proposed sites and would need to be considered if and when these sites are developed.

Noise from wind turbines is site and wind speed/direction dependant, so the mapping circles we have provided are only indicative.  More detailed and specific measurements will be made as part of any and every turbine application, so the local community will have the ability to comment.

The UK comprehensive guidelines for Assessment & Rating of Noise from Wind Farms quotes the following from the WHO:

Few people are seriously annoyed during the daytime at noise levels below around 55dB(A)Leq outdoors. Noise levels during the evening and night should be 5 to 10dB lower than during the day

Ecological and Land Use Impacts

The main ecological concern of wind turbines relates to bats and birds. For both bats and birds there are mitigation solutions, which suggests that a strategy of monitoring and mitigation is likely to be effective.

Apart from the relatively small loss of land needed to support a wind turbine and gain maintenance access, there are no other significant impacts to land use or its ecological value.


Exeter University undertook research on the interaction between bats and wind turbines for DEFRA by monitoring a number of wind sites, a range of wind conditions and recording bat fatalities.  More accessible references, are:

It seems that some relatively simple mitigation measures can allow wind turbines to generate most of the time:

  • Turbines only turned off when there is a high risk to bats (example low wind, summer evenings), turbines can now have this automated.
  • Ongoing monitoring to refine the circumstances when turning off needs to occur.
  • Absence of bats at the pre-construction stage is not a good indicator of their absence during turbine operation.  Subsequent mitigation is more likely to be effective than pre-construction surveys.
  • There are devices that emit an ultrasonic signal, which effectively blocks the bat’s radar, so they do not approach the turbine. This is mounted on the turbine


Several references suggest there are much higher numbers of bird deaths in general from cats, collision with windows and traffic compared to deaths from wind turbines.

This reference discusses both bats and birds. It suggests that large birds are more at risk than smaller ones.  It reports Norwegian research where turbines with one blade painted in a contrasting colour has dramatically reduced fatalities.

Infrastructure and Highways Impacts

These include site access during construction, especially for larger turbines.  The consultation states that these will be considered on a case by case.

Connection to the electricity network is a key factor.  There does not appear to be much consideration for this in terms of site selection.  We have included mapping information on current electricity distribution/transmission lines and sub-station.

The distribution network operator Western Power Distribution (WPD) has been made aware of these potential sites.  This information should allow them to better consider strategic network reinforcement, something they are not currently required to do by the regulator Ofgem.

Landscape and Heritage Impacts

Undoubtedly most wind turbines will have a visual impact.  Like electricity pylons, roads and housing developments, they are manmade structures in the natural environment.  The question we need to answer is what the balance is between the benefits and the detriments.

To minimise their visual impact, wind turbines are painted white or grey to blend into the sky when viewed from the ground.  The lower part of the mast can be painted to allow this to blend into the surrounding’s natural structures.  For safety reasons wind turbines need to be visible from overhead low flying aircraft.

We are more likely to accept new structures that are familiar to us, like roads and housing.  This despite them having a greater detrimental visual, ecological and of course greenhouse gas emission impact compared to wind turbines.  Road and housing are also more likely to persist for a lot longer than wind turbines, if eventually we are able to generate our energy from other low Carbon technologies.  We could also limit wind turbine deployment if we become more careful about how much energy we consume and distribute energy better.

Other Notes

This space is made available in the on-line consultation for making comments on the benefit and impact of wind turbines not covered above.

We believe that if we are to avoid the existential threats resulting from Climate Change, on-shore wind turbines will be necessary.  They are by far the most effective renewable technology available to us now.  Nothing comes without a degree of negative impact, we need to minimise the impact of wind turbines.  The consultation materials list many of these safeguards, you can also read general references to these on the internet, e.g. for on-shore wind.

Government releases its Hydrogen Strategy

Number 2 of the Government’s 10 Point Plan:

“Working with industry aiming to generate 5GW of low carbon hydrogen production capacity by 2030 for industry, transport, power and homes, and aiming to develop the first town heated entirely by hydrogen by the end of the decade”

On 17 August 2021 the department for Business, Energy and Industrial Strategy (BEIS) released its Hydrogen Strategy announcing, in the press release:

  • A ‘twin track’ approach to supporting multiple technologies including ‘green’ electrolytic and ‘blue’ carbon capture-enabled hydrogen production.
  • A UK hydrogen economy could be worth £900 million and create over 9,000 high-quality jobs by 2030, potentially rising to 100,000 jobs and worth up to £13 billion by 2050
  • Hydrogen could play an important role in decarbonising polluting, energy-intensive industries like chemicals, oil refineries, power and heavy transport like shipping, HGV lorries and trains
  • By 2050 20-35% of the UK’s energy consumption could be hydrogen-based.
  • A consultation to be launched, based on offshore wind, to look at ways to overcome the cost gap between low carbon hydrogen and fossil fuels, plus a consultation on a £240 million Net Zero Hydrogen Fund, to support the commercial deployment of new low carbon hydrogen production plants.
  • Working with industry to assess the safety, technical feasibility, and cost effectiveness of mixing 20% hydrogen into the existing gas supply.
  • £105 million in UK government funding provided to support polluting industries to significantly slash their emissions

In the original press release, and elsewhere, it was mentioned that 3 million homes would be powered by hydrogen by 2030 but BEIS have now amended the press release and confirmed that this was an equivalent illustration and that hydrogen will predominantly be used in heavy industry.

As stated in the strategy, with currently almost no low carbon production of hydrogen in the UK or globally, meeting the 2030 target will require rapid and significant scale up over coming years. It then describes where Hydrogen comes from:

“There are almost no abundant natural sources of pure hydrogen, which means that it has to be manufactured. The most common production route is steam methane reformation (SMR), where natural gas is reacted with steam to form hydrogen. This is a carbon-intensive process, but one which can be made low carbon through the addition of carbon capture, usage and storage (CCUS) – to produce a gas often called ‘blue hydrogen’. Hydrogen can also be produced through electrolysis, where electricity is used to split water into hydrogen and oxygen – gas from this process is often referred to as ‘green hydrogen’ or zero carbon hydrogen when the electricity comes from renewable sources. Today most hydrogen produced and used in the UK and globally is high carbon, coming from fossil fuels with no carbon capture; less than 1% can be called low carbon. For hydrogen to play a part in our journey to net zero, all current and future production will need to be low carbon.”

So in following its “twin track” approach the government assumes that blue hydrogen will initially start the strategy going with green hydrogen becoming more abundant (and cheap) in later decades. Without specifying proportions however, it seems that in both mix and, as shown below, use, the government is relying on the market to find the best combination.

Some key points:

Here is a graph from the report showing the estimated hydrogen demand in various sectors, in Terawatt Hours (TWh) (one Trillion Kilowatt hours), in 2030 & 2035.

Note in particular the 0-45 estimate for heating, this reflects the uncertainty about the lesser priority of hydrogen for domestic use and the availability today of alternatives, eg Heat Pumps. To put this into perspective the anticipated <1 TWh in 2030 and up to 45 TWh in 2035 represents about 0.2% and 10% respectively of the UK’s current energy demand for space and water heating.

It’s likely therefore that, as mentioned in the Climate Change Committee’s (CCC’s) balanced pathway to Net Zero, hydrogen may play a part in heating where the housing is near to the hydrogen production and electrification is not possible or where there is stored hydrogen created from surplus renewable energy.

Unless using this stored hydrogen however, it makes little sense to use green hydrogen for heating when the renewable energy used to create it would be better used to provide the heating directly and so save the wasted energy from conversion.

It’s often quoted that “the only waste from using hydrogen is water”.  This is true when hydrogen is used in “fuel cells”, where a chemical reaction takes place, or where hydrogen is burned in pure oxygen but it is not true when, as would be the case with heating, it is burned in air. Air’s main constituent is Nitrogen and burning hydrogen in it produces other pollutants, known as NOx. The strategy considers these and how industry must ensure they are kept within emission limits, opponents however consider that, along with the infrastructure changes needed, it’s unacceptable to plan for any such emissions.

As explained in an Annex, with an established battery electric vehicle industry now well established, cars and vans do not feature in transport assumptions, leaving the use of hydrogen for haulage, busses, rail, shipping and aviation however, given the rapid development in battery technology, the annex casts doubt over the likelihood of the first three. Consequently, as mentioned above, it seems the government will wait and see what the markets come up with.

In 2050 the strategy estimates somewhere between 20% to 35% of the UK’s total energy demand being provided by hydrogen.  In the CCC’s 6th Carbon Budget report last year, its balanced pathway relied upon a maximum of about 20%. Until the government releases its own energy pathway it’s not possible to reconcile the two.

As blue hydrogen relies on a supply of natural gas there’s suspicion outside government over its promotion as an energy source by the fossil fuel industry and studies, including this one in the USA, indicate that current production methods, including carbon capture and storage, result in significant CO2 and Methane (CH4) emissions, both in the extraction of the gas in the first place and then leakage in the capture and storage processes. 

This view was reinforced by reports that Chris Jackson, the chair of the UK Hydrogen and Fuel Cell Association resigned in advance of the government’s strategy saying he could no longer lead an industry association that included oil companies backing blue hydrogen projects, because the schemes were “not sustainable” and “make no sense at all”.

As mentioned above, in its twin track approach, the government sees blue hydrogen as useful in creating a path to green hydrogen but, with BEIS talking about up to 15 year contracts, concern has been voiced among climate groups that over-reliance on blue could lock the UK into decades of North Sea gas production, fossil-fuel imports and millions of tonnes of carbon emissions. 

ACT’s view is that there will be a place for hydrogen in providing energy where electrification is not possible and in some industrial and chemical processes. With the uncertainties over the impacts of its production however and without scaled-up and effective capture and storage, blue hydrogen is wholly inappropriate as a solution and so efforts are better directed towards immediate reductions in the use of fossil fuels with any hydrogen pathway being primarily towards green hydrogen.

Other relevant links:

ACT’s Technologies to support Net Zero Section 3 Hydrogen

The Telegraph Billions to be funnelled into hydrogen subsidies as UK races to hit net zero

The Guardian Government reveals plans for £4bn hydrogen investment by 2030 

BBC News Hydrogen power offers jobs boost, says government

UKERC Pathway to net zero heating in the UK

The Climate Change Committee Hydrogen in a low-carbon economy

Last Chance to Influence Where New Housing is Built

You have until noon on Monday August 9th to give Teignbridge District Council (TDC) your views on the 100 plus sites around Teignbridge proposed for new development. If you don’t respond to this consultation you won’t get another opportunity. It is difficult, if not impossible, for plans to be changed further down the line.

Government proposals for a new approach to planning rules will prevent even the local authority from making adjustments in response to changing circumstances in the future. It’s our last chance to influence where new homes are built. You may think your views won’t count. They definitely won’t if you don’t make them known. The more people who respond the better.

The current Local Plan Part 2 consultation follows on from Part 1 in 2020, which focused on the policies that guide developments. The two parts will together form the Local Plan 2020-2040, which will replace the current Local Plan adopted in 2014.

How to respond

The consultation is online at and is available chapter by chapter. You can comment using the online survey or the downloadable response form. The survey looks technical, but if you have local knowledge about particular sites it’s vital you share it. You can only comment on one site at a time and give comments in relation to eight criteria, although there is an opportunity to comment on “anything else”. You may want to prepare your comments before you go online and then copy and paste them in. Make sure you go all the way to the end of the survey, even if you don’t give all the personal information requested, and press the Submit button.

The printable pdf form only asks for comments, with no prompts for specific criteria, but you have to print it out to use it or convert it from a pdf to a word document or similar.

It is also possible to download the questions and send your comments by email to or by letter to Spatial Planning & Delivery, Teignbridge District Council, Forde House, Newton Abbot Devon TQ12 4XX. All comments made in writing will be considered. 

What to say 

The number of homes proposed for each town or village is stated at the beginning of each ‘Housing Site Options’ chapter. If a town or village has several sites on offer, which together are able to more than cover TDC’s suggested housing numbers for the settlement, then stating in your comments which site/sites would be better is helpful. The suggested general comments below may be useful here.

If you think your village has no allocated sites, make sure it hasn’t been included in Chapter 4 of the consultation, the Heart of Teignbridge. This is true for several proposed sites in Ogwell and Kingskerswell, for example. Check this map to see where all the proposed sites are. You will also need to look at Chapter 9, Employment Site Options, for land which may be developed for employment.

If you have local knowledge of a proposed site, check the information given about it in the relevant consultation chapter for accuracy and omissions. If you have the time and inclination, it is also worth looking at TDC’s assessment of the sites in the appendices to the consultation. Appendix D(a) is for town sites while Appendix D(b) is for villages. To understand the scoring and colour coding for the sites, you will need to go to page 14 of the Stage B Report – Sustainability Appraisal (SA) and Strategic Environmental Assessment (SEA). To dig further into the scoring assumptions, check out Appendix A. You might need a stiff drink or two to see you through all this!

Here are some examples of the sort of comments you could make on issues relating to wildlife:

  • It is essential that mitigation measures taken to protect wildlife habitats and avoid extinction of local species are completed before site clearance and building starts.
  • All the hedges around this site are biodiverse and should be protected and buffered.
  • A wide buffer strip is needed alongside the public footpath beside the stream, to ensure habitats are connected’.
  • Protect Greater Horseshoe Bat flyways and ensure there is no artificial lighting on the development.
  • Protect the nearby SSSI/ CWS (Site of Special Scientific Interest/County Wildlife Site) from polluted run-off from the new estate.

These are more general comments you could make on the subject of climate change and greenhouse gas emissions:

  • New developments should be about meeting local needs in the most sustainable way. Delivering a pre-set number of housing units to boost the economy should NOT be the driver. 
  • Many of us nowadays live in one or two-person households, so the need is for smaller homes than the three to five bedroom houses typical of new developments. Building on a smaller scale would deliver lower greenhouse gas emissions as well as the housing numbers required. 
  • Greenhouse gas emissions for people living in urban areas in Teignbridge are typically 30% lower than for those who live in rural ones, as is true throughout the UK. The benefits of housing people within, or close to, urban areas are clear. The emissions associated with the provision of goods and services, as well as travel, can be minimised.

You can find more information here.

Site options for the Teignbridge local plan to be consulted on

A meeting of the council executive on 1st June passed a motion to run a public consultation on site options for the local plan from 14th June to 9th August.

Executive Committee meeting

You can watch the proceedings of the executive committee here , this gives access to a recording of the whole meeting, the local plan is item 6 on the agenda, which you can select from the menu on the right.

Jackie Hook said “We will have to choose some sites, help us to choose the least damaging. This isn’t however about who can gather the biggest petition against a site, this is about bringing to the council’s attention additional planning related information and knowledge.”

Local plan consultation on sites

Part 2 of the local plan has now been published and can be found here.

Housing Numbers

As you may know, the Government has told Teignbridge it must build 751 houses a year (they had planned to order 1,532 houses a year!). The council therefore has to identify the sites where the houses can be built. If we do not do this the Government will take over planning at Teignbridge and increase the numbers by 20%.

This consultation asks that members of the public help by:

  1. Checking through the sites and see what may be proposed in your community and commenting about the sites.
  2. Sharing the consultation with your friends and family living in Teignbridge. It’s really important as many people as possible know about the proposals and say what they think to Teignbridge.

This could well be the last time local people are given a say in major planning decisions like this.
The Government is proposing to bring in a new system under which land will be zoned. Anything designated for ‘growth’ will be deemed to have ‘planning permission in principle’.
Government ministers claim their plan will eliminate ‘red tape’ but many fear that it abolishes any meaningful involvement of residents and local councils in planning matters.
The consultation on the possible housing sites ends at 12 Noon on Monday 9th August 2021. Do please have your say 

Low Carbon

Chapter 11 states Teignbridge’s 2018 carbon footprint and analyses emissions trends over the period 2008-2018, showing that the transport, buildings, agriculture and waste sectors have not reduced over that period.

Electricity consumption is estimated to grow from 468GWh to 940GWh (101%) as a result of electrification of heat and transport, as well as growth associated with growth mandated by the plan.

The report doesn’t give any detail of how this electrification will be achieved, but the proposed increase in electricity consumption is close to our own estimates based on widespread EV take-up and retrofitting the existing housing stock to near Passiv Haus standards. Indeed the growth in electricity demand is slightly lower than we estimated, so some other demand reduction must be assumed.

Possible sites are identified for 217GWh of wind and 726GWh of solar, totalling 953GWh. So on a whole year basis enough to meet demand. The report identifies a number of constraints, which mean that this much renewable generation is unlikely to be buildable.

Peak demand occurs in the winter, when solar generation is producing least. We see already that in the recent sunny period that grid carbon intensity for the South West can get as low as 30g/kWh when most energy comes from solar and nuclear. Contrast this with winter when on a calm day most of our electricity in the South West comes from gas when grid carbon intensity can exceed 400g/kWh.

The report identifies an increase of 201GWh of demand from heating, which will mainly be needed in the winter months. It also identifies 49 GWh from additional housing, if we assume that this will also be biased towards winter, the additional winter demand could increase to 230GWh. This is more than could be supplied by the identified wind resource. So Teignbridge will need to import more renewable energy from elsewhere during the winter.

A large amount of land is identified as suitable for solar development. Here there is also scope for a significant contribution from rooftop PV, however, this is limited in practice by the ability of local substations to deal with local generation.