Design and Access Statement

Home , Carno, Pontdolgoch

Carno III Access Modifications

15 October 2020

1236511

Amegni Renewables

Document history

Author Ffion Edwards, Principal Project 13.10.20 Manager Checked Sion Thomas 15.10.20 Approved John Woodruff 14.10.20

Client Details

Contact Sion Thomas Client Name Amegni Renewables Address Bron Haul Carno Powys SY17 5JY

Issue Date Revision Details A 15.10.20 First revision

NATURAL POWER CONSULTANTS LIMITED, THE NATURAL POWER CONSULTANTS LIMITED, NATURAL POWER SARL, NATURAL POWER CONSULTANTS (IRELAND) LIMITED, NATURAL POWER LLC, NATURAL POWER S.A, NATURAL POWER SERVICES LIMITED AND NATURAL POWER OPERATIONS LIMITED (collectively referred to as “NATURAL POWER”) accept no responsibility or liability for any use which is made of this document other than by the Client for the purpose for which it was originally commissioned and prepared. The Client shall treat all information in the document as confidential. No representation is made regarding the completeness, methodology or current status of any material referred to in this document. All facts and figures are correct at time of print. All rights reserved. VENTOS® is a registered trademark of NATURAL POWER. Melogale™, WindCentre™, ControlCentre™, ForeSite™, vuWind™, WindManager™ and OceanPod™ are trademarks of NATURAL POWER.

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Contents

1. Introduction ...... 1

1.1. Carno III background ...... 1 1.2. Legislative Context ...... 2 1.3. Aims ...... 2 1.4. The Applicant ...... 2 2. Site and Design Evolution ...... 2 2.1. Existing Access Track to Carno Wind Farm Modifications ...... 2 2.2. Pontdolgoch Alternative Access Track ...... 3 3. Environmental Considerations ...... 8 3.1. Public Access ...... 9 4. Policy Context ...... 10 5. Conclusions ...... 11

Figure 14.5: Pontdolgoch Access Track and Public Rights of Way

Figure 14.6: Access Modifications from Carno Village to Carno III Wind Farm and Public Rights of Way

Design and Access Statement

1. Introduction

1.1.1. This Design and Access Statement has been prepared by Natural Power Consultants Ltd. (Natural Power) on behalf of Amegni Renewables Ltd. (Amegni Renewables) (the applicant), to accompany the planning application for an alternative access track to avoid Pontdolgoch railway bridge and modifications to the access road from Carno village to Carno Wind Farm (the proposed development) for the transportation of turbine components, near the village of Carno, Powys.

1.2. Carno III background 1.2.1. Carno Wind Farm Extension - Phase III (known hereafter as Carno III) currently has planning permission for the construction and operation of 13 turbines at up to 126.5 metres (m) in maximum height to blade tip, and associated wind farm infrastructure. The consent was granted in May 2017 under the Town and Country Planning Act 1990 (planning reference: P/2010/0762).

1.2.2. A Further Environmental Information (FEI) document has been prepared by Natural Power in support of a Section 73 application to amend the existing consent to increase the tip height for all 13 turbines from 126.5 m to tip to a maximum of 149.9 m to tip to maximise the wind farm’s efficiency.

1.2.3. Since submission of the original application in 2010 there has been considerable change in the onshore wind market. Due to the removal of subsidies (Renewable Obligation Certificates and Contracts for Difference), it is now vital that onshore wind farms maximise their efficiency. Therefore larger, more productive turbines that can maximise energy yields must be considered. Turbine availability has also changed considerably as a reaction to the new commercial market conditions, with fewer turbine manufacturers providing turbines in the lower height ranges. Turbines in the height range upwards of 150 m to tip are now considered typical in today’s market.

1.2.4. As a result of the increase in turbine height proposed, this has resulted in the need to bring larger components to site and therefore further modifications are required to the consented access route from Carno village to Carno III, which follows sections of private and public road.

1.2.5. In addition, investigations to the access route from port to site has identified a pinch point at Pontdolgoch, along the A470 between Carno and Caersws, where the public road goes under Pontdolgoch railway bridge, which has a height and width restriction. An alternative access route corridor within agricultural land has been identified so that abnormal indivisible loads (AIL) would (on route to site) pull off the A470 onto adjacent private land (utilising temporary track system). Once given the all clear, the loads would cross the A470 and enter Wig Lane unclassified road, over Wig railway crossing and river bridge, before entering private land and follows a new route (with some existing track to be utilised) until reaching an existing junction north of the Pontdolgoch railway bridge at the A470. Once constructed the main access track would remain in situ during the operational period, to provide access should there be a need for replacement component such as a new blade needed to be transported to site. All other maintenance traffic would use the main road and this route would only be used for AIL (i.e. the loads carrying the wind turbine components).

1.2.6. The access modifications from Carno village to Carno III and alternative access at Pontdolgoch is being applied for as a separate Town and County Planning Act 1990 application as it is outside the current planning application area for the consented wind farm.

1.2.7. The proposed modifications to the consented access route is required to enable construction and optimisation of Carno III that would contribute to Wales’ target to generate 70% of its electricity consumption from renewable energy by 2030.

1.3. Legislative Context 1.3.1. As the proposed development will be on a site greater than 1 ha, it is considered a major development, as defined in the Town and Country Planning (Development Management Procedure) (Wales) Order 2012 (DMPWO), and therefore a Design and Access Statement must accompany the application.

1.4. Aims 1.4.1. The Design and Access Statement aims to illustrate the design principles and concepts of the proposed development, and how issues relating to access has been dealt with.

1.5. The Applicant 1.5.1. Amegni Renewables is a locally based renewable energy company and a local enterprise formed by farmers from Carno, Mid Wales, who teamed up with their neighbouring landowners to pursue the development, therefore supporting Welsh Government’s aspirations for local ownership of renewable energy projects in Wales.

1.5.2. Natural Power is acting as the main consultant in relation to this proposed development. Natural Power is an independent consultancy with expertise of the entire wind farm development and operations cycle spanning from site prospecting and resource assessment, through design and consent and on to construction an operational asset management. Natural Power’s Welsh team is based in Aberystwyth.

2. Site and Design Evolution

2.1.1. The planning application consists of access works at two areas: • modifications along consented access route from Carno village to Carno Wind Farm along sections of private and public road; and • creation of new access road through agricultural fields south of Pontdolgoch.

2.1.2. Section 13 of the FEI, including Section 13 figures and appendices provide detailed information relating the proposed work at both areas.

2.1.3. The following sections demonstrates how the proposed development aims to meet the five principles (where applicable) of good design listed in Planning Policy Wales.

2.2. Existing Access Track to Carno Wind Farm Modifications 2.2.1. The modifications to the existing access track from Carno village to Carno Wind Farm allows larger components to be delivered to Carno III safely. The modifications proposed are shown on the swept path analysis drawings included in Appendix 13A.9 of the FEI (pinch point 23 to 33) and are not repeated here.

2.2.2. Some of the works required to bring turbine components to Carno III were already covered by the existing consent, however due to the need to use larger turbine components some further modifications (greater widening etc.) is required which is outside the current consented planning application boundary.

2.2.3. Figure 2.1 below shows the current consented planning application boundary in blue and the proposed additional planning application area in red (where further modifications are required).

2.2.4. The proposed development is considered minor additional modifications to the already consented modifications to the access route for Carno III. The total area (as shown in red) applied for is approximately 0.45 ha. The proposed works to the pinch points along the public highway would be carried out under Section 278 of the Highways Act 1990 and agreed with the local authority.

Source: FEI

Figure 2.1: Planning application area for access modifications

2.3. Pontdolgoch Alternative Access Track 2.3.1. An additional pinch point for larger turbine components was identified at Pontdolgoch along the A470 between Carno and Caersws, where the public road goes under Pontdolgoch railway bridge, which has a height and width restriction. Alternative options for this bridge restriction were investigated which resulted in a viable alternative access route being identified.

2.3.2. The applicant underwent extensive liaison with the landowners around Pontdolgoch to understand the best route to safely deliver turbine components whilst minimising the environmental impact of the route.

2.3.3. A corridor within the agricultural land was firstly identified for an access route and was discussed as part of the scoping report submitted to consultees in September 2019.

Source: FEI

Figure 2.2: Scoping report figure showing access route corridor (available in Appendix 4A.1) 2.3.4. N.B. Additional figures from the FEI have been reproduced in this Design and Access Statement, however please refer to the FEI Volume 2 for full scaled figures.

2.3.5. As part of the scoping process, taking into consideration landowner comments, and further assessment by the specialists involved in the Environmental Impact Assessment, a route was defined within the corridor. The design philosophy behind the track layout took into account a number of factors including topography, hydrology, watercourse crossing, ground conditions and construction parameters and has been based on best practice methodology developed at other wind farm sites. The proposal uses existing tracks to limit the amount of new track which is required and using existing tracks will also further reduce the degree of disturbance to the local environment. The proposed track layout has been designed following an onsite review, has minimised the number of water crossings necessary and used, as far as possible, the existing infrastructure in place to minimise impacts on the environment. Loss of agricultural land and practicality to the landowner has also been minimised by placing the route at the outer field boundaries rather than cutting through the middle of the fields where possible. The final route is shown on Figure 2.3.

2.3.6. Under the management and escort of the Police, the AILs would (on route to site) pull off the A470 onto adjacent private land utilising a temporary track system, comprising an aluminium laydown track (which would be removed after construction, and temporarily replaced if and when any new components were required) shown in yellow and green outline in Figure 2.3. The aluminium temporary road surface would simply be placed on the ground with some modifications to the exit and entry point from the tarmacked A470. The convoy will be held on the temporary track, off the A470, whilst seeking clearance from the Network Rail at Machynlleth to cross the Wig railway crossing. Once given the all clear, the police escorting the convoy would manage the loads across the A470 and enter Wig Lane unclassified road, over Wig railway crossing and river bridge, before entering private land and following the new route (with some existing track to be utilised) until reaching an existing junction at the entrance to Petheirin farm north of the Pontdolgoch railway bridge at the A470. Again, at this point the Police escorting the convoy would manage the transition back onto the A470 and the journey on to Carno.

2.3.7. Please note that only the permanent access track (shown in red outline in Figure 2.3) is included as part of this planning application (other than the small exit point from the A470), however the temporary trackway is discussed to demonstrate the access for AILs to Carno III Wind Farm.

Source: FEI

Figure 2.3: Screenshot from Figure 12.38 in FEI showing proposed access route as red outline and temporary metal trackway in yellow and green outline

2.3.8. As noted, the abnormal indivisible loads would pull off the A470 onto adjacent private land utilising temporary track system, approximately 522 m in length on agricultural land opposite Wig Lane off the A470 North of Caersws to enable safe crossing of the A470 by AILs onto Wig Lane road.

2.3.9. The temporary track system would be removed at the end of the turbine delivery period and due to the temporary nature of the looped trackway this is not considered further in this design and access statement as it is not part of the planning application.

Source: FEI

Figure 2.4: Temporary trackway (Screenshot of Figure 13.5 of FEI)

2.3.10. After safely crossing the A470, the route will travel along Wig Lane, over the railway crossing and river bridge before exiting onto a new access track to be constructed within agricultural fields to the north of Wig Lane.

2.3.11. The new access track will be similar dimensions and material to the access tracks proposed at the wind farm (see Figure 4.5 and Section 4 of the original Environmental Statement for further information on access track construction). The track running width would generally be approximately 5 m wide, with the exact width depending on the local ground conditions, typically comprising of 300-400 mm depth of compacted stone, dependent on ground conditions. with vegetation and topsoil reinstated to the edge of the track.

Source: ES

Figure 2.5: Schematic cross- section of access track construction (screenshot of Figure 4.5 of ES)

2.3.12. The new access track will be approximately 1,546 m in length linking Wig Lane to the A470 north of Pontdolgoch railway bridge at the entrance to Pertheirin Farm (which also consists of upgrading of approximately 386 m of existing farm access track shown as black and white dash on Figure 2.6). The

use of this existing track infrastructure will limit unnecessary disturbance to soil and pollution risks arising from works.

2.3.13. This new access route will only be utilised for delivery of AIL (turbine components with delivery window assumed to be approximately 3 months) and the potential rare occurrence of any future need for component replacement etc. The construction of this new access track is expected to take approximately 1 month.

2.3.14. Following site investigation studies undertaken prior to construction the detail of the construction methods, including type and design of track, and reinstatement measures for the new access route will be agreed as part of a planning condition (e.g. within a Construction Method Statement) for the separate Town and Country planning application.

Source: FEI

Figure 2.6: Proposed new access route at Pontdolgoch (Figure 13.4 in FEI)

3. Environmental Considerations

3.1.1. The design of the access route took into consideration the environmental impact of the proposed new access route and is discussed in the individual sections of the FEI. The key conclusions are summarised in this section.

Hydrology 3.1.2. The hydrological impact of the new access route is discussed in Section 8 of the FEI.

3.1.3. One consideration for the track placement was proximity to the Afon Carno. Natural Power hydrological specialists considers that the proposed access track is situated with sufficient distance from the Afon Carno watercourse, except crossing of the two minor watercourses of field drains are intersected by the proposed access track. Having a buffer zone will assist in the mitigation of pollution risks arising from run- off, and the risk of flooding from the Afon Carno.

Ecology 3.1.4. The ecological impact of the new access route is discussed in Section 9 of the FEI.

3.1.5. An extended Phase 1 habitat survey was undertaken for the new access route and also considered otter, watervole and great crested newts. The assessment concluded that preconstruction checks should be undertaken no more than six weeks before the start of construction for otter and watervole but no further mitigation or changes to design were required. Ponds close to the access route were considered of poor potential to support great crested newt. Due to the careful design of the access route the loss of semi- natural broad-leaved woodland/planted coniferous woodland is restricted to hedgerow boundaries between fields and will not include any individual trees or the wooded bank of the Afon Carno. Loss of improved grassland (approx. 1 ha), which is not considered to be a valued ecological receptor, was not considered significant.

Noise 3.1.6. The noise impact of the new access route is discussed in Section 10 of the FEI.

3.1.7. Construction of the new access route will be a short-term activity carried out during normal working hours only, and predicted noise levels will be less than the significance thresholds for properties, except for the farm associated with the land in question Pertheirin/Dolerw. A short-term effect is not considered a significant impact in this context. Predicted noise levels from the abnormal movements themselves will be very low and therefore not assessed any further. Therefore, the design is considered acceptable from a noise perspective for both the construction and the delivery period.

Cultural Heritage 3.1.8. The cultural heritage impact of the new access route is discussed in Section 12 of the FEI.

3.1.9. A thorough examination of the historic environment record, allowed assessment of potential direct impacts and the potential for unknown buried archaeology within the route corridor prior to final decision on the route alignment within the option areas. Construction of the access track has a moderate to high probability of disturbance to any buried archaeological remains, however when mitigation is applied in the form of archaeological investigation and recording, it would adequately compensate for the potential harm to the assets as it provides an opportunity to learn more about their significance. In addition, indirect impacts were considered, including impact on listed buildings, which concluded that the construction and operation of the track would result in some change to the existing visual and acoustic baseline setting, but construction and initial use of this would be of a temporary nature so it would not be significant.

Landscape and Visual 3.1.10. The landscape and visual impact of the new access route is discussed in Section 6 of the FEI.

3.1.11. A high-level assessment of landscape and visual effects on the proposed access track was also undertaken to determine the final route. Although the new access track (with the exception of the temporary loop) would be long-term, the period of disturbance and most effects would be limited to the construction of the track and the delivery of turbines with traffic utilising the access track.

3.1.12. In terms of landscape effects, the assessment concluded that the magnitude of change to the local landscape was not significant. Mitigation by replanting lost vegetation and strengthening the existing field boundaries would help to reduce the impact in conjunction with natural weathering and grassland encroachment helping the stone track to merge into the adjacent grassland and landscape.

3.1.13. Visual effects are generally limited due to the presence of riparian vegetation and the railway line vegetation and embankment, but some significant effects would occur during the construction period due to vehicles using the track. These would occur particularly in winter when filtered views through the riparian vegetation would occur and from the two properties with open views (Pertheirin and Dolerw, the landowners of part of the access route). These effects would not occur within the operational period of the wind farm, except in the rare event of a replacement component being required to be delivered.

3.2. Public Access 3.2.1. The proposed new access at Pontdolgoch would cross and run alongside sections of Footpath Caersws 18. See Figure 14.5 found at the end of this document for location of access route in relation to public footpaths. Natural Power undertook consultation with Powys County Council on the access route and agreed that the footpath will be managed during construction based on the following principles (as discussed in Section 14 of the FEI): • Installation of barriers/fencing between the footpath and access track to segregate pedestrians from construction works and construction traffic where the access track runs parallel to the footpath. • Provide information signage on the footpath to warn members of the public to be aware of the construction works and traffic. • Brief site staff (via site induction, Risk Assessment Method Statement, and toolbox talks) on the interface with the footpath, and the need to be vigilant during works in this area and respect the segregation installed, and to adhere to site rules including speed limits. • Installation of signage to warn site personnel of the presence of the footpath and members of the public. • Where the access track is to cross the footpath , a temporary footpath closure may be required during construction of this section of access track (c. 1 day anticipated), which would be applied for via a Temporary Traffic Restriction Order. Closure time would be minimised as far as possible and works programmed to have as little impact on use of the footpath as possible. • The crossing point would be barriered and clearly signed to inform pedestrians that they are about to cross a live track used by construction vehicles, and to inform construction traffic that pedestrians may be crossing. A site wide speed limit for construction traffic will also be implemented and enforced, and this could be reduced in the vicinity of the crossing point if required. • During turbine deliveries, abnormal load vehicles would be escorted, and escort drivers briefed to be aware and manage the interface with the footpath and members of the public.

3.2.2. The same principles would apply for manging the public footpaths close or adjacent to the proposed modifications to the route from Carno village to the wind farm, where additional widening and road modifications are required to that consented already. See Figure 14.6 for location of access modifications in relation to public footpaths.

4. Policy Context

4.1.1. The Powys Local Development Plan (LDP) was adopted in April 2018 and lists key issues relevant to this application. • Key issue 11 recognises the importance of rural Powys for renewable energy generation and storage. The proposed development fits with this recognition to allow turbine components to be delivered safely to the wind farm. • Key issue 28 recognises that increasing energy bills and extreme weather are affecting fuel poverty. Delivering renewable power at market price and reducing emissions through this project also addresses this issue. • Key issue 44 supports utilisation of Powys’ renewable energy resource where the effects are acceptable. The project fits squarely within this consideration

4.1.2. Furthermore, the vision for Powys in 2026 highlights that;

‘As the ‘green heart of Wales’, Powys will be a place of vibrant and resilient communities providing sustainable development and economic opportunities set in a healthy, safe environment, whilst celebrating, protecting, enhancing and sustainably managing its natural resources, native wildlife and habitats, heritage, outstanding landscapes and distinctive characteristics.’

4.1.3. This vision is expanded upon through a series of more detailed objectives. These include Objective 1b which states; ‘Protecting, enhancing and making the most of natural resources including the open countryside, water and renewable energy resources.’ Objective 4 -Climate Change and Flooding also seeks ‘To support the transition to a low carbon and low waste Powys through all development, including the reduction of waste to landfill and by directing development away from high flood risk areas and, where possible, to reduce or better manage existing flood risk for communities, infrastructure and businesses.’ Whilst Objective 5 Energy and Water seeks ‘To support the conservation of energy and water and to generate energy from appropriately located renewable resources where acceptable in terms of the economic, social, environmental and cumulative impacts’.

4.1.4. Being able to construct the Carno III project through consenting of the proposed modifications to access route to allow larger turbines to be delivered to site will allow the vision, the relevant objectives and the growth strategy of the LDP, as set out above, to be realised.

4.1.5. When considering national policies, the application for the proposed modifications to access route will also support national policy. The Committee on Climate Change’s Net Zero Report in May 2019 recommends new emissions target of net-zero greenhouse gases by 2050 for the UK as a whole, and 95% reduction in greenhouse gases by 2050. The access route modifications will allow the construction of the Carno III Wind Farm which conforms to the vision set by national policies.

4.1.6. In response to the global Climate Emergency, the Welsh Government declared its own Climate Emergency in Wales in April 2019. This was swiftly followed by the publication in June 2019 of Prosperity for All: A Low Carbon Wales which in turn set out Wales’ commitment to tackling Climate Change, which includes 100 policies and proposals that directly reduce emissions and support the growth of the low carbon economy. This project would not only increase the contribution of the Carno III site to meeting Welsh targets, in line with Planning Policy Wales, but contribute to Welsh Government’s ambitions concerning locally owned projects.

4.1.7. In summary, the proposed development will contribute to the reduction of greenhouse gases by helping to facilitate the production of electricity from a renewable source and reducing the need for fuel from finite resources. It will contribute to the percentage of electricity supplied by renewable sources, the move towards having a low carbon economy and to reaching renewable energy generation targets.

5. Conclusions

5.1.1. Natural Power has prepared this document in support of an application for planning permission for an alternative access track at Pontdolgoch and further modifications to the consented route from Carno village to the wind farm to allow safe deliveries of AILs for the tip height extension sought for Carno III Wind Farm.

5.1.2. The applicant has assessed and sought to minimise the proposed development impact on the local environment through the careful design and siting of the track and through use of good practice and from detailed assessment and where necessary mitigation of the predicted impacts. Residual impacts of the developments are considered acceptable and therefore consent is sought from Powys County Council.

300500 301000 301500 302000 302500

Project: Carno III Tip Height Extension, Powys 0 0 0

4 Title: 9 2 Figure 14.5: Pontdolgoch Access Track and Public Rights of Way

Key

Planning application boundary

Proposed access route

Temporary access route

Public Right of Way 0 0 5 3 9 2 0 0 0 3 9 2

Scale @ A3: Coordinate System: British National Grid N

Date: 15-10-20 Prepared by: IW Checked by: : LF

Ref: GB200075_M_277_A 0

0 Drawing by:

5 The Natural Power Consultants Limited 2

9 Harbour House, 2 Y Lanfa, Aberystwyth, SY23 1AS, UK Tel: 01970 636869 Email: [email protected] www.naturalpower.com

Client: Amegni Renewables Ltd Bronhaul Carno Powys SY17 5JY Notes: a) Information on this plan is directly reproduced from digital and other material from different sources. Minor discrepancies may therefore occur. Where further clarification is considered necessary, this is noted through the use of text boxes on the plan itself. b) For the avoidance of doubt and unless otherwise stated: 1. this plan should be used for identification purposes only, unless otherwise stated in accompanying documentation. 2. The Natural Power Consultants Limited accepts no responsibility for the accuracy of data supplied by third parties. 3. The Natural Power Consultants Limited accepts no liability for any use which is made of this plan by a party other than its client. No third party who gains access to this plan shall have any claim against The Natural Power Consultants Limited in respect of its contents. 4. For the purposes of this plan, the boundary is the outside edge of the red line (Option Area) and the inside edge of the blue line (Landowner Property). 5. Where a line or feature recorded in the key of this plan is also shown as a line or feature by the Ordnance Survey, and that line or feature is located in a different position on the ground than shown by the Ordnance Survey, then the line or feature shall be deemed to follow the position as existing on the ground. 294000 294500 295000 295500

Project:

0 Carno III Tip Height 0 5 7

9 Extension, Powys 2 Title: Title: Figure 14.6: Access Modifications from Carno Village to Carno III Wind Farm and Public Rights of Way

Key

Existing planning application boundary

Proposed planning application boundary

Public Right of Way 0 0 0 7 9 2

Source: Powys County Council. Contains public sector information licensed under the Open Government Licence v3.0.

5 0100031673. 6 9 2 Scale @ A3: Coordinate System: British National Grid N

Date: 15-10-20 Prepared by: IW Checked by: LF

Ref: GB200075_M_278_A Drawing by: The Natural Power Consultants Limited Harbour House, Y Lanfa, Aberystwyth, SY23 1AS, UK Tel: 01970 636869 Email: [email protected] www.naturalpower.com