YMGYRCH DIOGELU CYMRU WLEDIG ---- CAMPAIGN FOR THE PROTECTION OF RURAL

Wentlooge - renewable energy hub Reference: DNS/3216558 ​

2nd RESPONSE BY CPRW : 7 DECEMBER 2020

Submitted by the National Executive of the Campaign for the Protection of Rural Wales

1. CPRW are writing to respond to the further documents submitted by the applicant at the request of the Inspectorate. We are also taking this opportunity to comment on two additional documents which have only been published since the original deadline of 31 August : the latest version of the Welsh Government NDF (“Future Wales”) issued on 25 September and the Local Impact Report (LIR) published by on the DNS website on 2 September.1

2. Having considered all the recent material, CPRW stands firmly behind our original objections submitted in August. The applicants' documents do not answer or really address our initial concerns which remain as follows :

(a) Non-conformity with WG policies (b) Non-conformity with the Local Development Plan (c) Non-conformity with the joint Newport-Torfaen Study (d) Site selection, including rejection of alternatives (e) Cumulative impact on landscapes (f) Flood risk

NON CONFORMITY WITH WG POLICIES IN REVISED NDF - “FUTURE WALES”

3. There is crucial new text in Future Wales (FW), now expressed as Policy 18, which provides stronger and clearer grounds to reject the application than the approach taken in the previous draft NDF, which was discussed in CPRW’s original submission in August. There are three critical conditions quoted in FW which all large scale (ie DNS) wind and solar farms must meet in future :

- The proposal is designed to minimise its visual impact on nearby communities and individual dwellings, and the cumulative impact of the proposal, with other existing or proposed development, is acceptable;

1 We also mention in footnotes 2 very recent documents submitted separately to PINS by Ian Cummings. ​

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- There are no adverse impacts on international and national statutory designated sites for nature conservation (and the features for which they have been designated), protected habitats and species;

- The proposal includes biodiversity enhancement measures to provide a net benefit for biodiversity;

The most significant of these in relation to St Brides is the condition that there must be “no adverse impacts on … national statutory designated sites for nature ​ conservation.” This is expressed quite intentionally in much stronger language than ​ the previous draft NDF. The previous version said that planning applications must demonstrate that “adverse impacts” on “protected ..nature conservation sites and ​ ​ species .. have been minimised” whereas the equivalent condition in the new text ​ ​ ​ above states that the criterion will now be “no adverse impacts”. The intention to set ​ ​ ​ the strictest standard of all for the protection of wildlife is also illustrated by the fact that the qualifying adjective of “unacceptable” in relation to “adverse impacts” on a range of other RE issues including the built heritage, shadow flicker, noise and air quality is deliberately not applied to adverse impacts on wildlife. The policy is absolutely consistent with the Welsh Government's declaration of a Biodiversity Emergency alongside the Climate Emergency in 2019. CPRW believe that failure to ​ meet this condition is, on its own, sufficient to refuse the St Brides solar farm application as it cannot be seriously argued that there will not be “adverse impacts” on wildlife by constructing solar panels on 12% of the area of such a sensitive and important SSSI. The application so far has been based on the ​ assumption that minimizing these impacts through mitigation is sufficient, but Future Wales has now raised the bar far higher for nationally designated wildlife sites, including SSSIs.

4. Perhaps understandably, Savills’ letter of 13 November 2020 entirely ignores the stricter new conditions for solar farms to be built on nationally designated wildlife sites, and indeed makes no mention of any of the conditions, including those on visual and cumulative impacts, and biodiversity enhancement, which are also stronger than previously expressed in the NDF. There is also a seriously inaccurate and misleading statement in Savills’ letter which claims (in boldface for greater impact) that “importantly the policy makes no spatial exemptions in its support for the principle of development based upon blanket based designations such as AONB or SSSI land”. In fact Policy 18 states in text which Savills omit to quote that ​ “ Applications for large-scale wind and solar will not be permitted in National Parks and Areas of Outstanding Natural Beauty ''. This should be read alongside ​ the very strict criterion stated later in Policy 18 for allowing such developments on nationally designated wildlife sites, as quoted in para 3 above,

ARCHAEOLOGY & HISTORY of THE LEVELS COUNTRYSIDE

5. The new documents from the developer continue to undervalue the unique national importance of the Gwent Levels as an historic landscape. This is illustrated by the

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Archaeological desk study2 . Whilst this reveals in detail the high potential of the site for the survival of historic artefacts, due to the wet conditions on the Levels, its conclusion that this should not stop development is at variance with the evidence actually presented in the main body of the text. Many archaeologists, influenced by the increasing discoveries of new historic features on the Levels revealed by modern aerial and other survey methods, would conclude instead that in such an outstanding, ancient landscape,3 the precautionary principle should be applied and any solar farm sited on more suitable land away from the Gwent Levels.We also note that in their comments 4 on the desk study GGAT point out that irrespective of mitigation measures, irreversible and permanent damage to buried archaeological deposits could result directly from the screws & piles need to install the solar panels and from the possible introduction of oxygen into the anaerobic conditions.

6. CPRW supports the view expressed by the NCC in their LIR that they conclude that the ​ impact of the solar farm would be negative on the historic landscape.See Para 7 below. ​

NCC LOCAL IMPACT REPORT

7. This is an important analysis and we were unable to find evidence that it had been fully addressed by the applicant either in the additional LVIA material submitted or elsewhere. It confirms our original view that the proposals is inconsistent with the LDP

8. NCC’s report lists a stream of negative impacts. It shows how the impact on landscape has been consistently underplayed in the application, noting that it “ contains no detail ​ of landscape mitigation measures”, that “landscape objectives are missing” and that ​ ​ “the mitigation is entirely ecological”. NCC concludes that the “the Landscape & Visual ​ ​ impact of the proposal would be negative”, and that “the impact on the ​ ​ Levels Special Landscape Area would also be negative”. 5

9. The NCC confirms( para 4.2) that the important planning designation of “Green Wedge” covers the entire solar farm site. CPRW did not mention this in our original submission as we were unaware of it. This is not surprising as it appears from our checks that the Developers’ original application makes no reference to Green Wedge status - we have checked key documents on the DNS site both from the original application and the more recent documents and cannot find the words “Green Wedge” in (eg) the 3-volume Environmental Statement, the LEMP or the LVIA documents, or on any of the developer’s submitted maps. We attach two maps we have now found showing (MAP A)

2https://dns.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/DNS/3216558/DNS-3216558-000280-APP%20Further%20Infor mation%20-%20Desk%20Based%20Heritage%20Assessment.pdf 3 The Gwent Levels is a registered Landscape of Outstanding Historic Interest 4 Submitted on 12 Nov 2020 5 On the same theme CPRW has just seen the Urbanists’ December 2020 review of the original LVIA whose detailed analysis echoes the NCC’s concerns. It highlights the “ fragmented “ methodology of the LVIA and its omissions, including deficient data to demonstrate how the LIVIA's assessments on the significance of landscape and visual impacts were actually reached. The review states that the developers’ LVIA has “ sufficient inconsistencies, omissions and inaccuracies to conclude that the LVIA is not a sufficiently robust document to accurately inform the determining authority of the likely effects of the proposals on landscape and visual receptors.”

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the location of the Newport and Green Wedge and (MAP B) the adjoining Green Belt which covers the remaining area up to the boundary with Cardiff (the solar farm would be next door on the edge of the Green Wedge). The Newport City Council's LIR states “Green Wedges have been identified in order to prevent coalescence between the following settlements: i) Newport and Cardiff; ii) and Risca; iii) Bettws, Malpas and Cwmbran; iv) and Cwmbran. Within these areas development ​ which prejudices the open nature of the land will not be permitted.” CPRW ​ believe that a large solar farm is incompatible with the need to retain an open undeveloped vista within a Green Wedge which is actually the largest in Wales, and designed to prevent the merger of two distinct Welsh cities.

10. On wildlife NCC is also very sceptical : “Planning Policy Wales requires that ​ “development should not cause significant loss of habitats or populations of species, locally or nationally and must provide a net benefit for biodiversity. The information provided to date does not provide certainty that suitable management can be enforced to guarantee that the development does not result in a loss for biodiversity.” Interestingly NCC reached this view before the publication of the revised NDF later in ​ September which set even more stringent standards for renewable energy proposals affecting designated national sites for nature conservation (ie SSSIs) - see para 3 above. 6

CUMULATIVE IMPACTS ON LANDSCAPE IN GWENT LEVELS

11. We note that proposals for a third large solar farm on SSSI land in the eastern Gwent Levels have been submitted for Pre-App assessment under the DNS rules, since the original St Brides application was made. CPRW understands that plans for a 4th solar farm of DNS proportions, also on the eastern Levels, may be at an advanced stage. We believe these unwelcome developments only strengthen the objections CPRW made in paras 10, 11, 16 and 17 of our original submission of 31 August. The risk of ​ irreparable harm to the unique Gwent Levels landscape increases with every application made.

12. CPRW would also like to support the further submissions made by Friends of the Gwent Levels and Gwent Wildlife Trust.

Campaign for the Protection of Rural Wales (CPRW), December 2020 CPRW is a charity registered in England and Wales, Charity NUmber 239899 Street, Welshpool, Powys, SY21 7YD

Please reply to Robert Hepworth, National Executive Committee Member

6 A consistent pattern of concern about the wildlife impacts has emerged from NRW, GWT, RSPB, GOS, NCC and was also reflected in CPRW’s earlier submission in August. Within the last few days CPRW has seen a further Ecological Impact Report dated 27 Nov 2020 by the “Just Mammals” consultancy. The latter (submitted separately to PINS) shows that ​“the development will compromise the SSSI’s ecological value” ​and identifies a number of specific risks including those to dormice which have not been adequately addressed by the developers

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