Gwent Wildlife Trust Ymddiriedolaeth Natur Gwent

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Gwent Wildlife Trust Ymddiriedolaeth Natur Gwent Gwent Wildlife Trust Ymddiriedolaeth Natur Gwent 9th April 2018 Seddon House Dingestow Monmouth NP25 4DY Dear Sir/Madam, PINS ref – 16/3150137 Application for a DNS by Gwent Farmers' Community Solar Scheme Ltd at Land on the Caldicot Levels to the South of the Llanwern Steelworks site We are writing in response to the above application for a large Solar Scheme. We strongly object to the Gwent Farmers Community Solar Scheme Ltd proposed Solar Scheme at land on the Caldicot Levels SSSI. We outline our reasons for objecting to the scheme in the attached document. Yours Sincerely Lindi K Rich Conservation Officer 1 Gwent Wildlife Trust Response to the PINS ref – 16/3150137 Application for a DNS by Gwent Farmers' Community Solar Scheme Ltd Contents Page Section A General Comments 3 Section B Response to Environmental Statement 4 Sections refer to ES: Introduction 4 Ecological Designations 5 Gwent Levels Historic Landscape 5 Environmental Benefits 7 Energy Storage 8 Ecology and Nature Conservation 8 Introduction 8 Legislative context 10 Baseline environment 10 Otters 10 Assessment methodology 14 Impacts and Effects 14 Construction impacts 15 Operation Impacts 17 Invertebrates 20 Additional Mitigation... 22 Residual impacts and effects 23 Cumulative effects 23 Ornithology 25 Site Selection Sequential Test 28 Section C Scheme Impacts Discussion 29 1. Scheme Impacts - Wildlife and the Protected Sites 29 2. Scheme Impacts - Local Climate 32 3. Scheme Impacts - Pollution 34 4. Rampisham Down 35 Section D Summary of Objections 36 2 Gwent Wildlife Trust Response to the PINS ref – 16/315 0137 Application for a DNS by Gwent Farmers' Community Solar Scheme Ltd Section A General Comments 1. Document Provision We wish to highlight here that the confusing array of documents provided in an unstructured way for this application, has made it difficult to respond. A significant number of reports were labelled with names which did not inform us of their contents such as ‘Legend 1-3.pdf’, ‘Figures.pdf, Ecology.pdf’ or RPS Data.pdf’ and in addition documents were using terms such as ‘revised’ and ‘draft’ or even ‘draft final’. Not only did we have to download the documents in many cases to find out the content, we also found it hard to be sure we were reading the latest versions of documents. We consider this has significantly disadvantaged the public and respondents to the consultation. We therefore request that it should be drawn to their attention if respondents have commented on a draft or earlier version (including by mistake). They would then need to be given the opportunity to respond to the final documents and given an additional or extended consultation period. The alternative and more satisfactory way of dealing with this would be to ask the Gwent Farmers team to sort out the documents, rename when necessary and provide a structured set, removing drafts or earlier versions and re- consult. 2. Gwent Wildlife Trust Stance on Solar Power We wish to state here that Gwent Wildlife Trust is not against renewable energy development, if it is in the right place. Gwent Wildlife Trust recognises the need to develop renewable energy projects and has never been against solar energy development, but in this case we needed to speak up for such special sites, two legally and nationally protected Sites of Special Scientific Interest (SSSI). This proposed development site is also on the Gwent Levels grazing marshes, a Priority Habitat under section 7 of the Environment (Wales) Act 2016 and which supports a wide range of rare and scarce species. We also consider the scheme would have a significant impact on the Gwent Levels Landscape of Outstanding Historic Interest. We would be supportive of an alternative location being put forward, which does not impact on protected wildlife sites. 3 Section B Response to the Environmental Statement (ES) Please note: Section titles and numbers refer to those in the ES. 1.0 Introduction Section 1.1.2 states: ’The temporary development (30 years) requires a site of approximately 345 acres’. We take the view that there is no guarantee that this development will in reality be temporary as once in place it will be easier to obtain a renewal of permissions. It is highly likely in our view, that there will be an application for replacement of panels rather than removal of panels after the 30 year life of the development is reached. We note that this application uses this ‘temporary’ reasoning to justify its arguments that damage will not be long term. For example Appendix 9.2 Historic landscape Assessment summary states: ‘It is also important to note that the indirect visual effect of the development will be transitory in nature, with the majority of solar sites having an economic lifetime of less than 25 years.’ Section 3.1.5 of the ES states: ‘The proposals will be temporary for a period of 30 years after which the site could be returned to its current condition’ This statement and the inclusion of the word ‘could’ highlight the fact that the site may not actually be temporary as an application may be submitted for the panels to be refurbished or replaced and the developer is well aware it may not be temporary. We do not consider that this development should therefore simply be considered ‘temporary’. In addition, environmental changes on the sites which may be impossible to reverse, may well have already occurred before this end date is reached. We dispute that in ecological terms the site could simply be ‘returned to its current condition’ at that point, as complex ecological changes in the species present and therefore the ecosystems will have occurred. 4 2.2 Ecological Designations Section 2.2.5 Section 2.2.5 quotes the Newport Local Plan Policy GP5 and states: ‘Paragraph 3.24 of the supporting text to Local Plan Policy GP5 (General Development Principles – Nature Conservation) explains that SSSI sites “will require the fullest regard to the intrinsic value of the site and their nature conservation value. Development with the potential to affect a recognized site will be closely scrutinized for any direct or indirect effects. The developer must demonstrate the case for development and why it could not be located on a site of less significance for nature conservation”.’ We agree with the statement in the Newport Local Plan Policy GP5 that ‘The developer must demonstrate the case for development and why it could not be located on a site of less significance for nature conservation’. There are substantial areas of land in Gwent which are not designated as SSSI. We can see no satisfactory justification in these documents as to why the development could not be located on other non designated land. We therefore strongly object to the location of this proposal. 2.3 Gwent Levels Historic Landscape Section 2.3.1 of the ES states: ‘The site area also lies within the Gwent Levels Historic Landscape Area as shown on Figure 5 as designated under the Register of Landscapes, Parks and Gardens of Outstanding Historic Interest in Wales.’ Historic Landscape Assessment ES Appendix 9.2 We note that the Historic landscape Assessment (ASIDOHL2) carried out by The Glamorgan-Gwent Archaeological Trust Ltd provided in the ES appendix 9.2 states: Concluding Statement ‘The ASIDOHL2 process has assessed the impacts of the development as currently proposed on the historic landscapes as they presently stand, and based on existing knowledge. The overall significance of the impact of the Solar Site development on the Gwent Levels (HLW (Gt) 1) landscape of outstanding historic interest is considered to 5 be ‘Severe’. There will be a direct physical impact on six Historic Landscape Character Areas and an indirect, visual impact on eight HLCAs.’ The ASIDOHL2 stage 5 Summary of the overall significance of the impact of the development on the Gwent levels Landscape of outstanding Historic Interest (ASIDOHL 2 report Section 4.5 page 64, Appendix 9.2) states in the table: The value of combined character areas is ‘high’ scored 7. The impact caused by the development is ‘high’ scored 7 and the text states: ‘Substantial land loss and consequent fragmentation and/or visual intrusion causing key elements to be removed or changed so that group value and/or coherence and/or integrity are significantly diminished, and/or amenity value greatly reduced’. The reduction in value of historic landscape area on register is ‘high’ scored 7 and the text states: ‘Development impact on key elements is such that the overall value of the historic landscape area on the Register is significantly reduced.’ The table then states the overall impact is ‘severe’ as it scores 21 points in the ASIDOHL assessment. We consider that this impact of this proposed development on the Gwent Levels historic landscape is too great and the proposal should be refused on these grounds. We also wish to highlight that the Gwent levels are currently an area where people can enjoy peaceful countryside walks and cycle rides and enjoy seeing wildlife in rural and historic landscape surroundings. We consider that a ‘severe’ impact on this special historic landscape which will dramatically detract from the experience people would have if they visit the Gwent levels, is also too great. We have looked at the mitigation proposals but consider that they are insufficient and in any case additional hedges would potentially be at odds with the relatively open landscape for which this area is designated. The Historic landscape assessment goes on to say: ‘It is considered that the overall effect of the development can be mitigated by the use of appropriate screening measures to limit the visual impact of the development.
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