www.renplan.co.uk
Consultation Report
Development of National Significance
Application Ref. DNS/3227364
Proposed installation of a ground mounted Photo Voltaic (PV) solar farm development
Land to the east of the A48 (Coordinates E257386, N 209389)
And
Land to the south west of Tycroes (coordinates E259219, N209551; & E259904, N209590)
______Prepared for
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
1
Report prepared for Spring Dev 02 Ltd.
Version 1 Date: 29.04.2020
Ben Lewis BA(Hons) MTP MRTPI
Previous Versions
None
Author:
Ben Lewis MRTPI
Director of Renplan Ltd.
This report has been prepared for the exclusive use of the client. No other party may copy, reproduce, distribute, make use of, or rely on the contents of the report without first obtaining permission in writing from a Director of Renplan Ltd.
Renplan Ltd. assumes no responsibility to any other party in respect of or arising out of or in connection with this document and / or its content.
© Renplan Ltd.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
EXECUTIVE SUMMARY
This report provides an overview of the statutory pre-application consultation process undertaken in accordance with The Developments of National Significance (Procedure) (Wales) Order 2016 (as amended). It discusses the issues raised and how these issues have been addressed as part of the formal Application for a Development of National Significance (DNS).
In accordance with Part 2 Article 8 and 9 of The DNS (Procedure) (Wales) Order 2016, a Statutory Pre- Application Consultation exercise was carried out on a draft DNS application. The Draft Application was available for reading on a purpose webpage www.springche.com/tycroes where consultees were directed to view and comment on the draft application.
The Consultation period commenced on 17th March 2020 and ended on 2nd March 2020. During this period, a Community Consultation Event took place on 24th February 2020 at the Local Village Hall of Tycroes where members of the local community were invited view exhibition boards displaying proposal information, and to meet the Applicant to discuss the proposal and leave feedback.
Responses have been received from 8 statutory / specialist consultees to Statutory Consultation. Feedback comments were also received from 8 community consultees attending the Community Consultation Event.
Consultation responses were favourable of the proposal with statutory / specialist consultees commenting more specifically on the requirement for additional / amended work and clarification on various mitigatable concerns.
Only 2 objections to the proposal were received from local residents during the consultation exercise.
The pre-application consultation exercise allowed the Applicant to finalise their proposals in anticipation of making a formal DNS application. Amendments to the proposals and the supporting survey work that accompany the application provide the requested further information and clarifications sought by consultees to ensure that the application being made is a comprehensive DNS submission.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
EXECUTIVE SUMMARY (Ctrl + Click Page Number to follow Link)
CONTENTS Page
Report Chapters: 1 Context 5 2 Statutory Consultees 11 3 Statutory Publicity 17 4 Number of responses, by type 24 5 Responses from statutory consultees and consequent actions 28 6 Main issues 63
Appendices Appendix 1: Declarations of compliance with the Act/Order Appendix 2: Copies of notices, publicity and letters Appendix 3: List of addresses of those consulted Appendix 4: Original copies of responses from statutory consultees Appendix 5: Copy of Display Boards from the Public Engagement Event Appendix 6: Copies of ‘preliminary’ pre-application comments provided for information
List of Figures: Figure 1a – General Site Location Map Figure 1a – Site Location Map of Areas 1, 2 and 3 Figure 2a – Areas 1 and 2: Site Location Map identifying adjoining properties consulted Figure 2b – Area 3: Site Location Map identifying adjoining properties consulted
List of Tables Table 1 - Responses from statutory consultees and consequent actions
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
1. Context
1.1 Introduction
1.1.1 This Report relates to an application for a Development of National Significance (DNS) (ref. DNS/3227364) to the Welsh Government for a proposed solar (PV) development on Land to the east of the A48 (Coordinates E257386, N 209389) and Land to the south west of Tycroes (coordinates E259219, N209551& E259904, N209590).
1.1.2 The Report provides an overview of the statutory pre-application consultation exercise the Applicant; Spring, has carried out prior to the submission of the DNS Application. It discusses the issues raised during and after the consultation period and how these issues have been addressed as part of the application as made.
1.1.3 The Report has been prepared in accordance with the recommendations of Welsh Government Guidance document titled ‘Developments of National Significance – Appendix 7. The Consultation Report 1st June 2019’. The Report follows the guidance contained in this document that sets out the proposed structure and chapter requirements for DNS Consultation Reports.
1.1.4 Prior to the undertaking of the ‘statutory pre-application consultation’, a preliminary pre- application consultation in respect of the proposal took place with the local planning authority Carmarthenshire County Council (CCC). This exercise discussed a scope of work that should comprise a draft DNS application and was also an opportunity for CCC to provide some early informal direction. As part of this preliminary consultation exercise, CCC consulted with other statutory and non-statutory consultees before drafting a preliminary pre-application consultation response for the Applicant.
1.1.5 A copy of the ‘preliminary pre-application consultation’ response from CCC and its enclosures are contained at the back of Appendix 6 of this Report. Although these responses did not comprise part of the statutory consultation exercise, these comments were important in the process of designing a draft DNS application upon which the subsequent statutory consultation could be based.
1.2 The Statutory Pre-Application Consultation Exercise
1.2.1 The Developments of National Significance (Procedure) (Wales) Order 2016 (as amended) states that a proposed DNS application must be publicised and consulted on by the Applicant for a period of at least six weeks prior to the submission of a full DNS submission.
1.2.2 The Order advises that as a minimum, the applicant must:
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 5
• Consult specific community consultees, specialist consultees and any relevant persons, • Serve written notice on owners or occupiers of land adjoining the site, • Display site notices, eligible for the DNS process, in at least one place on or near the site, and • Place a notice in a local newspaper.
1.2.3 Following the end of the consultation period, the Order confirms that a ‘Consultation Report’ must be prepared by the applicant and this must be submitted with the application and should provide details of the consultation process, the representations received and the applicant’s response to them. This Report forms the ‘Consultation Report’ required by the Order.
1.2.4 In accordance with Part 2 Article 8 and 9 of The DNS (Procedure) (Wales) Order 2016, a Statutory Pre-Application Consultation exercise was carried out on a draft DNS application. The Draft Application was available for reading on a purpose webpage www.springche.com/tycroes where consultees were directed to view the proposal and provide comments. The Consultation period commenced on 17th January 2020 and ended on 2nd March 2020.
1.2.5 During the publicised 45-day consultation period, a Community Consultation Event took place at the Tycroes Village Hall on 24th February 2020 where members of the local community were invited to view exhibition boards displaying proposal information, and to meet the Applicant to discuss the proposal and leave feedback.
1.2.6 The consultation process has allowed the applicant to undertake some amendments and provide further information regarding the proposal prior to the formal DNS application being made.
1.3 Location of the Site
1.3.1 The proposal comprises 3 areas of land described as Land to the east of the A48 (Coordinates E 257386, N 209389), and Land to the south west of Tycroes (coordinates E 259219 N 209551 & E 259904 N 209590). These areas are identified as Area 1, 2 and 3 in Figure 1b below.
1.3.2 The 3 areas of development are on the south-eastern side of the County of Carmarthenshire; approximately 20km south east of Carmarthen, 10km north east of Llanelli and about 15km north west of Swansea. Figures 1a and 1b below provide a reference to the location of the three areas of land the subject of the application.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 6
Figure 1a
Source: Google Maps/Earth
Renplan Ltd, Office 207, The H Website: www.renplan.co.uk 7
Figure 1b
1.3.3 Area 1 and Area 2: Land to the south west of Tycroes (coordinates E 259219 N 209551 &E 259904 N 209590)
1.3.4 The land to the south west of Tycroes consists of 2 parcels of land and from a visual perspective these essentially extend the existing Clawdd-du Solar Farm.
1.3.5 The larger parcel of land is referred to Area 1. It adjoins the northern boundary of the Clawdd-du solar farm and would consists of approximately 24ha. A local footpath runs through this parcel of land and will be temporarily diverted during installation of the development. This diversion will be addressed through a separate application.
1.3.6 The smaller (western most) parcel of land is referred to as Area 2 in the application. This area of land consists of approximately 1.8ha of land accessed directly from the A483. The coordinates for this land are E 259219 N 209551.
1.3.7 Area 3: Land to the east of the A48 (Coordinates E 257386, N 209389)
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 8
1.3.8 This area is referred to in the application submission as Area 3 and consists of approximately 21ha of land accessed directly from the A48 to the west.
1.3.9 The land in question sits alongside the A48 and slopes gently to the east. Direct access from the A38 is gained from the southbound carriageway.
1.4 The Proposal
1.4.1 The Applicant - Spring - is a renewable energy development company proposing to install a ground-mounted Photo Voltaic (PV) solar development consisting of 3 separate parcels of land as outlined in the enclosed Site Location Plan. Permission would be required for 40 years and the installation would have the design capacity of between 36-40MW of electricity generation.
1.4.2 Together with associated infrastructure and housings the development is comprised of the following main elements:
• PV panels mounted on fixed metal frames with support posts driven into the ground to a depth of approximately 1.5m, avoiding the use of concrete foundations.
The panels are laid out in east-west orientated rows in order to optimise solar gain. The lowest edge of the panels would be approximately 0.8m above ground level with the highest edge being approximately 3.5 m above ground.
The rows are spaced approximately 4-5m apart to avoid one row of panels shading the next. The panels are non-reflective, designed to absorb light and minimise glint or glare and angled at approximately 20-25° to horizontal.
• Inverter technology, which converts direct current (DC) into alternating current (AC). These are likely to be string inverter (80 cm by 1m) affixed beneath the PV panels to the PV mounting system.
• There will be approx. 24cabinets containing electrical equipment such as switchgear and transformers housed within flat roofed pre-fabricated units no higher than 3m and with a footprint of approximately 5m x 2.5m.
• An on-site sub-station.
• Security fencing (most likely deer fencing) to a height of 2.4m along with infra-red security cameras which will feature around the perimeter of the development; directed inward only. There will be no external lighting.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
• Each of the three parcels of land benefits from an established vehicular access directly from both the A48 and the A483 suitable for the delivery vehicles required to deliver the equipment proposed to be installed at the site. Existing gateways and tracks will be used to access the site itself; the surfaces of which would be improved by way of providing additional gravel or the temporary use of aluminium/plastic trackway.
• Cable route linking each of the 3 x solar sites the subject of the proposal. The cable is laid within a shallow and narrow trench measuring approximately 1.4m depth and 0.6m wide. The route utilises existing tracks including the A483 road verge and gated entrances between fields.
Renplan Ltd, Office 207, The Website: www.renplan.co.uk
2. Statutory Consultees
2.1 Introduction
2.1.1 The Developments of National Significance (Procedure) (Wales) Order 2016 (as amended) advises that as a minimum, the applicant must consult:
• ‘specific community consultees’ • ‘specialist consultees’ and • ‘any relevant persons’
2.1.2 Welsh Government also lists Statutory Consultees in an Information Report: List of Statutory and Non-Statutory Consultees in the Planning Application Process which is available to view at: https://gov.wales/sites/default/files/publications/2018-09/planning- consultees.pdf
2.1.3 An overview of the statutory consultation undertaken is set out in this Chapter. The addresses of those consulted are provided in Appendix 3 to this Report.
2.2 ‘Specific Community Consultees’
2.2.1 Community Consultees are defined by The Order as: • ‘Each Councillor representing each electoral ward in the County or County Borough Council in which the site is situated’ (In this instance, Carmarthenshire County Council; CCC); and • ‘The Community Council(s) in which the site is situated’. (In this instance, Llanedi and Llannon Community Councils)
CCC Ward Members 2.2.2 At the time of the consultation exercise, there were 74 Ward Members serving at Carmarthenshire County Council (CCC). The serving Ward Members were identified from the CCC website at http://democracy.carmarthenshire.gov.wales/mgMemberIndex.aspx?FN=WARD&VW=TA BLE&PIC=1.
2.2.3 These Members are listed In Figure 2a below which is followed map of all the CCC Wards (Figure 2b):
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
Figure 2a
2.2.4 As required to be included in this report, an extract of the boundary lines of each CCC Ward is provided below in Figure 2b. This information was derived from the document titled ‘Carmarthenshire County Profile prepared by the Research and Information Unit, CCC, January 2019 (https://www.carmarthenshire.gov.wales/media/2924/county- profile.pdf).
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
Figure 2b
https://www.carmarthenshire.gov.wales/media/2924/county-profile.pdf
2.2.5 The Local Planning Authority Office at CCC was also consulted as the Local Planning Authority the subject of the DNS.
Community Councils 2.2.6 There are two ‘Community Council’s’ affected by the proposals. These were identified using https://magic.defra.gov.uk/magicmap.aspx interactive mapping choosing ‘Other Administrative Boundaries’ and then ‘Parishes’ from the Table of Contents.
2.2.7 Areas 1 and 2 both fall within the ‘Llanedi Community Council’ administrative area, and Area 3 within the ‘Llannon Community Council’ administrative area. The Community Councils share the same clerk (David Davies) who was the point of contact for consultation on the draft DNS application as well as the community exhibition.
2.2.8 As required to be included in this report, an extract of the boundary lines from the ‘Magic Map’ is included below identifying the Llanedi and Llannon Community Council administrative boundary between each Community Council area, in relation to the Areas 1, 2 and 3.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
Figure 3
https://magic.defra.gov.uk/magicmap.aspx
2.3 ‘Specialist Consultees’
2.3.1 Specialist Consultees that may need to be consulted on a development are listed in the Order as:
• The Welsh Ministers • NRW • The Local Highways Authority • The railway network operator • The Coal Authority • The Health and Safety Executive • The Office for Nuclear Regulation • The Control of Major Accident Hazards (COMAH) competent authority, and any person in control of land associated with a hazardous installation • The Theatres Trust • The Sports Council for Wales
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
• The Canal and Rivers Trust
2.3.2 Those relevant Specialist Consultees listed above are listed below alongside additional relevant consultees to the proposed Solar (PV) DNS Application were identified as:
• The Welsh Ministers • Welsh Government – Trunk Roads; the relevant Authority in respect of the management of ‘Trunk Roads’ in Wales, and also as landowner of part of the cable route along the A483. • Welsh Government’s Cadw Office; as the competent body for consultations on proposals that might impact heritage assets • Natural Resources Wales (NRW); as the competent Authority in respect of flood risk, protected species and the assessment of the screening of a proposal against the Habitats Regulations • The Local Highways Authority; as the competent authority in respect of assessing the highways impacts of the proposal on the local highway infrastructure • The Coal Authority; as the competent authority to be consulted on proposals for development in ‘High Risk Areas’; • The Health and Safety Executive; as the competent authority to assess potential impact of a proposal on the presence within the vicinity of toxic, highly reactive, explosive or inflammable substances (e.g. significant underground infrastructure such as High-Pressure Gas Mains).
2.3.3 Each of the above organisations were consulted as part of the statutory Pre-Application Consultation by both postal letter and email containing a covering email, copies of both the English and Welsh Notices and a Site Location Plan. Contact details are listed in Appendix 3 to this Report.
2.4 Any ‘Relevant Persons’
2.4.1 ‘Relevant Persons’ are persons / organisations required to be consulted if a DNS application includes one or more secondary consents. In such circumstances, the applicant must consult the authority which would normally determine the application.
2.4.2 No secondary consents are sought as part of this DNS application.
2.5 Additional Statutory and Non-Statutory Consultations
2.5.1 The bodies listed below were also consulted as part of the pre-application consultations. • Dyfed Archaeological Trust • Welsh Water
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
• The City and County of Swansea Council
2.5.2 As the eastern most part of the application site falls approximately 1km from the administrative boundary with The City and County of Swansea Council (Swansea Council). The Local Planning Authority Office of Swansea Council was consulted along with the closest ward members of the County Council who were identified as Brigitte Rowlands (Ward Member for Mawr), Philip Downing (Ward Member for Pontarddulais) and Kevin Griffiths (Ward Member for Pontarddulais).
2.5.3 Each of the above were consulted by both postal letter and email containing a covering email, copies of both the English and Welsh Notices and a Site Location Plan. Contact details are listed in Appendix 3 to this Report.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
3. Statutory Publicity
3.1 Introduction
3.1.1 The Developments of National Significance (Procedure) (Wales) Order 2016 (as amended) advises that the applicant is required to publicise the proposed DNS application in such manner as is reasonably considered likely to bring it to the attention of a majority of the persons who own or occupy premises in the vicinity of the land.
3.2 Displaying at least one site notice
3.2.1 The Applicant’s Statutory Pre-Application Consultation period commenced on 17th January 2020 and ended on 2nd March 2020. The Applicant displayed both English and Welsh versions of the site notice in 4 separate locations.
3.2.2 The Notices were displayed on 16th January and remained on display for the duration of the consultation period.
3.2.3 Full copies of the Notices and Photographs of the Notices in situ are contained in Appendix 1 to this Report. The locations of the Notices are identified in Figures 4a and 4b below.
Figure 4a
Ordnance Survey © Crown Copyright 2020. All rights reserved. Licence number 100022432
Renplan Ltd, Office 207, The Hive, Website: www.renplan.co.uk E 17
Figure 4b
Ordnance Survey © Crown Copyright 2020. All rights reserved. Licence number 100022432
3.3 Serving written notice on owners or occupiers of land adjoining the site
3.3.1 The Order confirms that written notice must be served on ‘owners or occupiers of land adjoining the site’.
3.3.2 A total of 30 written notices were undertaken to the landowners and occupiers of land adjoining the site. The ‘adjoining land’ was identified as all the properties adjoining the development area inclusive of the cable route. The Applicant then sourced the names and addresses of the properties and the property owners from the Land Registry. This data was used to send postal written notice to the adjoining properties.
3.3.3 Some of those identified and which received letters were ‘involved properties’; properties with an interest in the project itself.
3.3.4 Figures 5a and 5b on the following pages provide maps which identify the land titles of the land adjoining the site. The addresses for consultation associated with these land titles are listed in Appendix 3. For reasons of data protection, the names of the persons upon whom notice was served is not published.
Renplan Ltd, Office 207, The Hiv Website: www.renplan.co.uk 18
Figure 5a – Covering Site Areas 1 and 2
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
19
Figure 5b – Covering Site Area 3
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 20
3.3.5 Additional postal consultations with the closest 426 residents of addresses within a 1km radius of all 3 sites were also undertaken to invite them to attend a Community Exhibition which was held on 24th February 2020.. These addresses are also listed in Appendix 3 of this Report.
3.3.6 In total, the Applicant sent 426 letters on 5th February 2020 to those properties with a 1km radius of the 3 Site Areas inviting the residents to attend the Community Exhibition on 24th February 2020.
3.3.7 Although the exhibition was not a statutory form of pre-application consultation under The Order, the exhibition was a useful forum for the Applicant to engage with local people about the project and for both parties to exchange information relevant to the proposal.
3.3.8 A summary of the responses and feedback received are summarised in Chapter 4 to this report. Copies of the display boards and the template feedback form are also included in Appendix 5.
3.4 Publishing a notice in the local newspaper
3.4.1 A Notification of the formal pre-application consultation was placed in the South Wales Guardian newspaper on 15th January 2020 and which consisted of the English and Welsh versions of the Notice required to be displayed under Articles 8 and 9 of The Order. The Notice comprised a half page on Page 17 of the newspaper. A copy of the Page of the Newspaper is shown in figure 6 below. An original copy of the Notice is included in Appendix 1.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
21
Figure 6
3.5 Publishing all documents on a website for a period of not less than 42 days
3.5.1 All documents comprising the proposed draft DNS application were published on a specific webpage dedicated to the formal pre-application consultation exercise on 15th January 2020. The webpage URL: h was published in all consultation letters, all written notice consultation, and within the local newspaper Notice.
3.5.2 The draft DNS application documents remained available to view up to the point of the formal submission of the application for the DNS application to the Planning Inspectorate
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 22
at which stage they were replaced by documents comprising the formal DNS submission. These documents having been amended following receipt of the consultation responses to the pre-application consultation exercise.
3.5.3 The Consultation Notices advertised a commencement of consultation at 9am on 17th January 2020, ending at 9am on 3rd March 2020 which was a 46-day consultation.
3.5.4 Please refer to Appendix 1 for Declarations of compliance with the Act/Order.
3.5.5 Please refer to Appendix 2 for Copies of notices, publicity and letters.
3.5.6 Please refer to Appendix 3 for a List of addresses of those consulted.
Renplan Ltd, Office 207, T Website: www.renplan.co.uk
4. Number of responses, by type
4.1 Number of responses received
4.1.1 A total of 16 responses were received to the consultation exercise from statutory consultees including community and specialist consultees.
4.1.2 The following table takes the 16 responses and separates them into 2 distinct groups.
Group A – Specialist Consultees (Statutory and Non-Statutory Consultee Responses) Group B – Feedback from local Residents having attended the Public Consultation Event held on 24th February 2020
4.1.3 A 3rd group would typically comprise ‘Community Consultees’ (i.e. Councillors representing each electoral ward in the County or County Borough Council in which the site is situated; and The Community Council(s) in which the site is situated). However, feedback responses were not received from ward members of Carmarthenshire County Council and c although community council members attended the Exhibition, no written feedback was left.
4.1.4 For the avoidance of doubt, a potential 4th group of consultees ‘Relevant Persons’ (ref. the Order) may have also been included, however, there was no consultation on a proposed application for a secondary consent as no secondary consents are being sought as part of this proposal.
4.2 Group A – Specialist Consultees (Statutory and Non-Statutory Consultee Responses)
4.2.1 The following tables review the two groups of consultee responses; identifying whether an objection / support response was received and identifies the main issues discussed.
Group A (Specialist Consultees; Statutory and Non-statutory)
Group A Consultation response Received Type of Reponse Main Issues raised Local highways, ecology, arboriculture, countryside conservation, Carmarthenshire County Council Concerns raised landscape, public amenity, drainage and heritage Cadw No objections N/a Known historical shallow coal mine workings within and adjacent the Coal Authority Concerns raised site areas Highways - Welsh Government Trunk Roads Concerns raised Traffic and Site Access, Glint and Glare to road users Health and Safety Executive No objections N/a Ecology, protected species, landscape and visual, flood risk, Habitats Natural Resources Wales Concerns raised Regulation Assessment City and County of Swansea Council No comments N/a Welsh Water No objections N/a
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
4.2.2 It is important to note that there were no outright objections to the proposal from any of the specialist consultees. Initial ‘objections’ received related to the impacts associated with the proposal where the specialist consultee sought further clarification / amendments to be incorporated into a DNS submission.
4.2.3 In the circumstances, these types of objections have been considered as ‘concerns raised’ rather than as an ‘objection’ to avoid confusion that an objection position might be deemed an opposition to the proposal itself. In each of the cases where concerns were raised, the Applicant identifies these as ‘Main Issues’ arising from the consultation exercise.
4.2.4 The Consultation responses received are discussed in greater detail in Chapters 5 and 6 of this report. the Applicant’s consequent actions to the responses received are detailed in Chapter 5 (Responses from statutory consultees and consequent actions) whilst further information relevant to the overall proposal is addressed in Chapter 6 (Main Issues) of this Report.
4.3 Group B – Feedback from Local Residents attending the Public Consultation Event of 24th February 2020
4.3.1 The public consultation event was reasonably well attended with approximately 40 people visiting through the 4-hour period. Feedback was encouraged from all attendees, although only 8 of those persons attending chose to leave feedback.
4.3.2 For purposes of data protection, the persons attending the event have been identified as Residents 1-8 in the following table.
Group B (Feedback from local Residents having attended the Public Consultation Event held on 24th February 2020) Group B Resident Type of Reponse Main Issues raised 1 Support Would like to see suitable local organisation to manage the solar park renumeration 2 Strongly Support None left 3 Strongly Support None left 4 Support None left 5 Undecided Solar energy is the way forward'. Need to be careful not to make development to big 6 Objection I agree with the principle of solar. Object to the size and location of the proposal 7 Undecided None left 8 Undecided I would like the community to beneft further with jobs
4.3.3 Although a small sample size, the exhibition drew feedback of 4 x the level of support for the proposal (‘Strongly Agree’ & ‘Agree’) in comparison to objections (‘Disagree’) with 3 respondents remaining neutral (‘Don’t know’). The following graph helps provide a quick reference to the level of support received to the proposal from local members of the community.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
Graph to show the level of support to the solar farm project received from respondents to the Public Exhibition Event held on 24th February 2020 4 3 2 1 I support the solar farm 0 project Strongly Agree Don't Disagree Strongly No agree know disagree answer given
4.3.4 The Applicant has considered the main issues raised in the feedback received from local residents and comments on these as follows:
4.3.4.1 With respect to a renumeration package to the local community, this is not a financial package necessary to render the proposal acceptable. If the proposal is approved and the project is built, the solar farm will become a new local business and the Applicant is amenable to make some charitable giving to the community. This will be arranged and managed between the Applicant and suitable local community organisations and outside of the DNS process.
4.3.4.2 With respect to not making the development ‘too big’, the Applicant has taken the development through several design iterations, accommodating constraints including Landscape and visual impacts that correlate with scale. The design process has seen the development reduce in scale and the LVIA finds that the impacts are acceptable. The scale of the project needs to be balanced with economic viability and environmental gain delivered through the generation of low-carbon electricity.
4.3.4.3 The primary influence on the project location is the proximity to a viable grid connection; in this instance the Ammanford substation located on Heol Ddu. The design process then assesses land within a reasonable radius, applying constraining factors such as ecological or landscape sensitivity to help identify suitable and available land. The Applicant believes the areas the subject of this proposal are some of the most suitable land within a reasonable radius of the viable grid connection.
4.3.4.4 The Applicant acknowledges some local residents will oppose the location proposed and there are other local residents that support it. It is unlikely such a proposal can be located where it would satisfy all local residents. Having notified a large number of local residents regarding the proposal, the minimal levels of concern and the slightly larger degree of local support received for the location has been welcomed.
Renplan Ltd, Office 207, The Website: www.renplan.co.uk
4.3.4.5 With respect to delivering benefit through the creation of local jobs, during the construction phase particularly, the proposed solar farm will create employment opportunities and income opportunities for local businesses, such as material supplies, plant hire, accommodation and hospitality and catering services. Once installed, the project will generate local business rates. There is unlikely to be a significant, long-term benefit to local employment however it is feasible that the site’s maintenance requirements can be deliver by local services.
Additional Feedback Received from Residents
4.3.5 Local residents were also asked 5 other questions. The feedback received to these questions is summarised in the following table below:
Group B In principle, I support The local community This is an Climate change is an solar energy projects will benefit from appropriate site for Resident important issue I support solar energy in my area renewable energy a solar farm 1 Strongly agree Agree Agree Agree Agree 2 Strongly agree Strongly agree Strongly agree Strongly agree Strongly agree 3 Strongly agree Strongly agree Strongly agree Agree Agree 4 Don't know Agree Agree Agree Agree 5 Strongly agree No answer given Strongly agree Don't know Disagree 6 Strongly agree Strongly agree Agree No answer given Don't know 7 Strongly agree Agree Don't know Agree Don't know 8 Strongly agree Strongly agree Don't know Disagree Don't know
4.3.6 The exhibition was an excellent opportunity for the Applicant to engage with local residents and those most likely to be affected by the proposal. Not all attendees (approximately 40) chose to leave feedback. However, it is reasonable to state that there was a greater feeling of support for this proposal than of opposition by those who attended and engaged in discussions with the Applicant.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 27
5. Responses from statutory consultees and consequent actions
5.1 Introduction
5.1.1 The purpose of this chapter is to identify the specific issues raised within the consultee responses and to explain the consequent actions of the Applicant in finalising the DNS application. Each of the 8 specialist consultee responses received from both statutory and non-statutory consultations are addressed in turn in the Table within this Section of the Report.
5.1.2 On receipt of all consultation responses, the specific comments were tabulated to identify each item to be addressed and then acted to resolve each comment. The table identifies each of these comments as an Item Number in the left hand column, quotes the respondent in Column 2, the Topic of the Comment in Column 3, the Comment itself in Column 4 and then the Applicant’s Consequent Actions in Column 5.
5.1.3 Respondents are identified by the name of the organisation that made the response. For example, ‘Carmarthenshire County Council’, or ‘Natural Resources Wales’ etc. For ease of reference, these organisations are referred to by their abbreviated term where it is appropriate to do so.
5.1.4 The 8 respondents are listed below together with their abbreviated terms where applicable:
Carmarthenshire County Council (CCC) Cadw Coal Authority Highways - Welsh Government Trunk Roads (Trunk Roads) Health and Safety Executive (HSE) Natural Resources Wales (NRW) City and County of Swansea Council (Swansea Council) Welsh Water
5.1.5 No secondary consents are applicable to this proposal and therefore there are no comments in respect of ‘relevant persons’ on matters relating to secondary consents.
5.1.6 In respect of local community feedback from local residents, please refer back to Section 4.3 of this report for an overview of the issues raised by the 8 no. of local residents that left feedback at the Public Exhibition on the 24th February 2020 and the applicant’s response to these issues.
5.1.7 Some of the documents / legislation referred to in the table below are abbreviated for ease of reference. These include the following abbreviations: Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
LVIA – Landscape and Visual Impact Assessment CEMP – Construction and Environmental Management PlanLEMP – Landscape and Ecological Management Plan HRA – Habitats Regulations Assessment TS – Transport Statement HIA – Heritage Impact Assessment FCA – Flood Consequences Assessment
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
Table 1 - Responses from statutory consultees and consequent actions
Item Consultee Topic Summary of Comments Received Consequent Action no. 1 CCC - Lindsay Site Plans The proposed site plans do not identify a section of the This discrepancy between plans has been noted and amended Rendle & proposed cable route from grid ref SN258130 209060 to in the formal DNS submission. Rosie grid ref SN258980 209590 Carmichael (Appendix 4 ref. A4.1d) 2 CCC - Lindsay Proposed Site Proposed Site Plan 2 and the Tree Surveys identify the This discrepancy between plans has been noted and amended Rendle & Plan proposed cable route in different locations in the field at in the formal DNS submission Rosie grid ref SN259930 209760 Carmichael (Appendix 4 ref. A4.1d) 3 CCC - Lindsay General Tree The Tree report does not assess ‘services’ or the cable A ‘Supplementary Report’ dated 26 March 2020 which has Rendle & Protection route been prepared by Woodland & Countryside Management Ltd. Rosie Comments identifies the works associated with the cable route and Carmichael provides a method statement to minimise impact to local trees. (Appendix 4 ref. A4.1d)
4 CCC - Lindsay General Tree The tree survey misses out a proportion of the proposed The tree survey work has been supplemented by a Rendle & Protection cable route entirely from grid ref SN257980 290090 to ‘Supplementary Report’ dated 26 March 2020 provides Rosie Comments grid ref SN258530 209320. additional plans. Carmichael (Appendix 4 ref. A4.1d)
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
30
5 CCC - Lindsay Western Plans The proposed cable route appears to run through RPAs The installation of this section of cable will use the Horizontal Rendle & of trees along the Afon Gwili and no tree protection Directional Drill (HDD) method (as detailed in the submitted Rosie measures are identified on the associated tree CEMP). Using the HDD method will ensure that the cable works Carmichael protection plan – Areas of concern between grid are at a depth that will pass beneath the Afon Gwili and (Appendix 4 references SN257590 209250 and SN257700 209150 beneath the root protection zone of the trees within the ref. A4.1d) identified area.
The ‘Supplementary Report’ dated 26 March 2020 identifies these works as being undertaken by HDD. 6 CCC - Lindsay Central Plans The proposed cable route appears to run adjacent to or The length of this section of cable route has been revised to Rendle & through woodland trees between grid references run down the middle of the farm access road rather than down Rosie SN258540 209305 and SN258980 209585, no tree the verge of the road. This ensures the root protection areas of Carmichael protection measures or RPAs are identified on the the adjacent trees will not be impacted by the cable. (Appendix 4 associated plans in this area and is cause for concern. ref. A4.1d) The ‘Supplementary Report’ dated 26 March 2020 identifies this change.
7 CCC - Lindsay Central Plans The proposed cable route appears to run through RPAs The cable will follow the access gate and will sit outside the Rendle & of trees and tree protection areas at grid ref SN259225 trees RPA’s and will run inside the field boundary a minimum of Rosie 209596. 1.0m outside the crown line of the hedgerow. Carmichael (Appendix 4 The ‘Supplementary Report’ dated 26 March 2020 which has ref. A4.1d) been prepared by Woodland & Countryside Management Ltd. provides additional clarity on this.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 31
8 CCC - Lindsay Central Plans The proposed cable route appears to run through tree The cable will sit outside the tree route protection areas and Rendle & protection areas between grid ref SN259225 209596 will run inside the field boundary, at a minimum of 1.0m Rosie and SN259350 209548. outside the crown line of the hedgerow. Carmichael (Appendix 4 The ‘Supplementary Report’ dated 26 March 2020 provides ref. A4.1d) additional clarity on this.
9 CCC - Lindsay Central Plans The proposed cable route appears to run adjacent to or The cable will run inside the field boundary at a minimum of Rendle & through hedgerows and trees between grid references 1.0m outside the crown line of the hedgerow. Where passing Rosie SN259350 209548 and SN259490 209497, no tree through hedgerows and hedgerow trees, installation will use a Carmichael protection measures or RPAs are identified on the ‘moling’ trenchless system (as detailed in the LEMP, Table 3 (Appendix 4 associated plans in this area and is cause for concern point 6). Fencing will be erected a minimum of 2.0m away ref. A4.1d) from the hedge or tree RPA extending a minimum of 3.0m either side of the line of entry. This will be repeated on the other side of the hedge or tree.
The ‘Supplementary Report’ dated 26 March 2020 clarifies this. 10 CCC - Lindsay North East The proposed cable route appears to run adjacent to or The cable will run inside the field boundary at a minimum of Rendle & Plans through hedgerows and trees between grid references 1.0m outside the crown line of the hedgerow. Where passing Rosie SN259558 209675 and SN259618 209666, no tree through hedgerows and hedgerow trees, installation will be by Carmichael protection measures or RPAs are identified on the using a trenchless system (as detailed in the LEMP, Table (Appendix 4 associated plans in this area and is cause for concern 3.6). Fencing will be erected a minimum of 2.0m away from ref. A4.1d) the hedge or tree RPA extending a minimum of 3.0m either side of the line of entry. This will be repeated on the other side of the hedge or tree.
The ‘Supplementary Report’ clarifies this situation.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
11 CCC - Lindsay North East The proposed cable route appears to run through tree The cable will run inside the field boundary a minimum of 1.0m Rendle & Plans protection areas between grid ref SN259620 209670 outside the crown line of the hedgerow. Rosie and SN259680 209764. Carmichael The ‘Supplementary Report’ dated 26 March 2020 which has (Appendix 4 been prepared by Woodland & Countryside Management Ltd. ref. A4.1d) clarifies this.
12 CCC - Lindsay North East No tree protection measures proposed for construction As detailed in Table 2 of the LEMP, hedgerows at the solar farm Rendle & Plans compound despite adjacent trees between SN259693 boundaries will be protected by a 7m buffer from all Rosie 209762 and SN259837 209745. construction activities, whilst internal boundaries will be Carmichael protected by a 5m buffer. These buffers will be delineated by a (Appendix 4 suitable fence before further works, such as at the creation of ref. A4.1d) the construction compound.
The ‘Supplementary Report’ dated 26 March 2020 clarifies the relationship of the proposal with the compound. 13 CCC - Lindsay North East The proposed cable route appears to run adjacent to or The cable will sit outside the trees RPA’s and will run inside the Rendle & Plans through hedgerows and trees between grid references field boundary a minimum of 1.0m outside the crown line of Rosie SN259925 209749 and SN260059 210135, no tree the hedgerow. Where passing through hedgerows and Carmichael protection measures or RPAs are identified on the hedgerow trees, installation will be by using a trenchless (Appendix 4 associated plans in this area and is cause for concern system (as detailed in the LEMP, Table 3.6). Fencing will be ref. A4.1d) erected a minimum of 2.0m away from the hedge or tree RPA extending a minimum of 3.0m either side of the line of entry. This will be repeated on the other side of the hedge or tree.
The ‘Supplementary Report’ dated 26 March 2020 clarifies this.
14 CCC - Lindsay HRA - Section 1.2.7 states the purpose of the HRA screening The competent authority is Natural Resources Wales (NRW) Rendle & Screening report is to enable CCC to undertake a HRA screening. who were consulted as part of the pre-application exercise. Rosie However, CCC will not be the competent Authority in Carmichael relation to this scheme and this will be the responsibility (Appendix 4 of the Planning Inspectorate. ref. A4.1d) Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 33
15 CCC - Lindsay HRA - Advice on the HRA screening report findings is under the Comment noted. Rendle & Screening remit of NRW in relation to DNS Rosie Carmichael (Appendix 4 ref. A4.1d) 16 CCC - Lindsay Preliminary Otter are under the remit of NRW however they may The updated Preliminary Ecology Assessment Report (PEA) Rendle & Ecological request the survey work highlighted under section 5.2 of relating to the cable route dated April 2020 and Table 3 of the Rosie Appraisal the report to inform the application, however it is noted LEMP dated April 2020 have been updated to discuss the Carmichael (PEA) of Solar that the cable route assessment does state an otter proposed mitigation measures to minimise risks to otter (Appendix 4 Sites check has been undertaken habitat. ref. A4.1d)
17 CCC - Lindsay Preliminary The recommendations of the PEA should be updated to The PEA discussing the 3 site areas dated April 2020 (Paragraph Rendle & Ecological clarify that a developer contribution in relation to the 4.4.7) has been updated to confirm that a developer Rosie Appraisal Caeau Mynydd Mawr SAC SPG is not required and to contribution is not required. Carmichael (PEA) of Solar align with the findings of the HRA Screening report (Appendix 4 Sites ref. A4.1d) 18 CCC - Lindsay Construction A detailed methodology is required for the HDD The CEMP has been updated (Section 13) to provide a Rendle & Environmenta operations methodology for the HDD operations. Rosie l Carmichael Management (Appendix 4 Plan (CEMP) ref. A4.1d) 19 CCC - Lindsay Construction Section 11.2.2.2 must also refer to watercourse buffers The updated CEMP (Paragraph 10.2.8) now refers to Rendle & Environmenta watercourse buffers and Paragraph 11.2.2.2 also quotes the Rosie l buffer distance of minimum 7m; following the methodology of Carmichael Management the LEMP. (Appendix 4 Plan (CEMP) ref. A4.1d) 20 CCC - Lindsay Landscape A specification for badger gates is required and details Specifications have now been provided in an amended LEMP; Rendle & and of distribution identified on the LEMP plan see Page 15, Item T4.4. Rosie Environmenta Carmichael l (Appendix 4 Management ref. A4.1d) Plan (LEMP)
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 34
21 CCC - Lindsay Landscape The applicant need(s) to propose and agree with the This matter has been discussed with Rose Carmichael of CCC. It Rendle & and LPA a suitable grassland mix for the site for inclusion in is agreed that although the Applicant has committed to a Rosie Environmenta the LEMP suitable grazing mix such as those produced by South West Carmichael l Seeds, specifying the precise mix is not required at this pre- (Appendix 4 Management determination stage. ref. A4.1d) Plan (LEMP) It is anticipated these details may be reserved for future approval in the form of a planning condition specific to seed mix and sowing.
22 CCC - Lindsay Landscape A more detailed habitat monitoring strategy and work The LEMP has been updated in Section 5 to discuss a more Rendle & and specification to identify floral diversity must be detailed habitat monitoring strategy and a commitment to Rosie Environmenta presented in the LEMP floral species diversity. Carmichael l (Appendix 4 Management ref. A4.1d) Plan (LEMP) 23 CCC - Lindsay Landscape Management of hedgerows during the operational The Applicant has noted these comments and discussed them Rendle & and phase of the development. The proposals submitted in further with CCC’s Rose Carmichael. Rosie Environmenta the PAC Consultation highlights the importance of the Carmichael l hedgerows around and within the sites and sets out The principles of hedgerow management were discussed with (Appendix 4 Management how these will be managed during the lifetime of the Rosie Carmichael via telephone on 25/03/20. The LEMP has ref. A4.1d) Plan (LEMP) development. been amended in sections 4.2 and 5.2 to detail further It is proposed that the hedgerows across the site will be information about hedge protection during construction and managed by means of mechanical flailing to attain a practices to manage and enhance the hedgerows through the height of 3.5m. Adjacent to each hedgerow there will be operation phase of the site. a grassy buffer strip. Given that the development is for 40 years it is Paragraph 5.2 of the LEMP specifies the principles to be recommended that the proposed hedgerow followed within a habitat monitoring strategy, which is management regime should include hedge laying and if proposed to be presented and agreed with the Local Authority necessary, coppicing to re-rejuvenate the hedgerows as by way of satisfying a condition of planning. appropriate, as well as flailing. It is very difficult to retain the structure at the base of the hedge over a Please refer to Appendix 4 (ref. A4.1d): CCC’s Further Ecology prolonged period when flailing is the only management comments (Highlighted) by Rosie Carmichael dated 25.03.2020 tool. Hedgerows can become thin at the base after years which agrees this as an appropriate approach to securing a of repeated flailing, and if this happens their value to hedgerow management plan. biodiversity is reduced. For these reasons it is recommended that the hedgerows are managed in Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
different ways to create diversity of structure across the sites, and this should include hedge-laying, and in the case of any very sparse hedges, coppicing and enrichment planting. The prescriptions in the LEMP should be expanded in a more detailed hedgerow management plan, and written so as to provide some flexibility, and opportunity for review. It is appreciated that the proposal to lay hedges may mean that for certain periods the hedges are providing less of a visual screen, however as Priority Habitats they will be in more favourable condition and as such provide a higher quality of ecological connection across the site. In addition this plan should also show lengths of hedgerow where it is already identified that enrichment planting would be beneficial. This is set out as a proposal, but it is not quantified, nor is this prescription mapped. Without a clear proposal it is difficult to enforce this type of management activity. The approach set out above is consistent with the Carmarthenshire LDP - policies EQ4 and EQ5. Adoption of this approach is also consistent with the delivery of Carmarthenshire CC’s Environment Act (Wales) 2016 duty – a duty that applies to any public body in Wales. A hedgerow management plan based on the above should accompany the application. It could be an appendix to the Landscape and Ecological Management Plan.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 36
24 CCC - Lindsay LEMP Table 2 The Preliminary Ecological Assessment (May 2019) During discussions with Rosie Carmichael on 25.03.20, it was Rendle & T 2.1 refers to the possibility of cattle grazing in the grassland clarified that the grassland buffer would be regularly cut and Rosie buffers – see para 7.1. It also refers to creating species- the possible option of grazing these areas would be reserved Carmichael rich grassland see para 7.2. Both these paras include the for future consultation and appropriate agreement with CCC. It (Appendix 4 word “could” and if this is to be a prescription it should would be expected that an appropriately worded planning ref. A4.1d) read as “will” not “could”. Moving on to the Landscape condition would require the Developer to consult and agree a and Ecological Management Plan, there is a proposal for different means of management of the grassland buffers (such light grazing the of the grassland buffer areas, after the as grazing) prior to this change being implemented, if and hay cut has been completed - see para 4.3.2 and 4.3.4. If when this scenario arises. it is the intension to lightly graze these areas, then fencing of the hedges to exclude stock is a prerequisite. The proposed management for the cutting of the grass will If sheep were to graze these areas it is not unlikely they retain a degree of flexibility and be kept simple and practical. would get caught in bramble if the hedges are to be flailed only every 2-3 years, and any stock will browse Where the landowner grazes sheep within the fenced solar on young re-growth if hedges are coppiced or laid. panel areas, this will continue under the panels only within the The fencing of internal hedges so as to permit light fenced areas of the panels and not in the grassland corridors grazing need to be addressed within the LEMP. surrounding the sites.
The fencing of internal hedges is not required under a ‘cutting’ management scheme of the grassland buffers.
Please refer to Appendix 4 (ref. A4.1d): CCC’s Further Ecology comments (Highlighted) by Rosie Carmichael dated 25.03.2020 which agrees this strategy. The submitted LEMP has been updated to note the importance of management plan review, specifically for livestock activity which may be subject to changes as agricultural activity changes.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
25 CCC - Lindsay Plug planting The seed source for these plugs is important. Plugs The sourcing of an appropriate supplier of seed mix is agreed in Rendle & of Devil’s Bit grown on from a Carmarthenshire seed source are principle. Following discussion with Rosie Carmichael, T3.6 in Rosie Scabious preferable. The origin of the seed for these plugs must the LEMP now refers to an option on the works relating to Carmichael Succisa be agreed with CCC prior to them being procured and Devil's bit scabeous in Field F8 where the turf will be cut, (Appendix 4 pratensis planted. Imported seed will not be acceptable. Plugs removed and returned once the works are complete or if a ref. A4.1d) should be grown on in a peat free growing medium. standard trench is dug, then plant plugs from a suitable source This may require a planning condition will be used to recolonise the area.
A supplier cannot be specified at this stage and therefore this could be reserved by way of a planning condition.
26 CCC - Lindsay Monitoring of Monitoring of ecological mitigation/ management Section 5.2 of the LEMP specifies the principles to be followed Rendle & habitat associated with the development will include the within a habitat monitoring strategy which are proposed to be Rosie enhancement monitoring of: presented and agreed with the Local Authority by way of Carmichael s • Increasing species diversity of grassland buffers next satisfying a planning condition. This approach was discussed (Appendix 4 to hedgerow and agreed in principle with Rosie Carmichael by telephone on ref. A4.1d) • Success of plug planting of Succisa pratensis 25.03.2020 and is covered by her additional comments • Establishment success of hedge plants and any trees received and which are enclosed in Appendix 4 (ref. A4.1d). planted on the site • Condition of hedges that have been dug out by hand The Applicant is willing to meet the reasonable costs of the for the cable route monitoring CCC would like to conduct and suggest / agree with • Restoration of all habitats affected by the cable route CCC that the need for monitoring is reviewed in-line with the • Other monitoring as identified evolution of the management plan, which – as the It is requested that a habitat monitoring plan is enhancement measures establish – will need less human developed for the application that will include all involvement. The seeds will be agreed in pursuance of monitoring required to demonstrate the success or satisfying a condition. otherwise of the management of the habitats affected by either the construction or operation phase of the development or both . The purpose of each monitoring exercise must be set out together with the aim of each habitat management activity, how/ when we will know that it has been successful, how the monitoring will be carried out, by whom, how frequently/what the assessment criteria will be, how it will be reported and to whom. Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 38
If CCC are to receive monitoring reports and to carryout annual checks et then CCC should be financed to complete this work. A monitoring plan should accompany the application rather than being conditioned. It should be subject to periodic review with the appropriate authority.
27 CCC – Lindsay Internal tracks A plan must be provided with the application that shows The existing farm tracks within the site will be improved as Rendle & to be created/ the lay out of the tracks that will be used during required with additional 300mm granular material. Where Rosie upgraded to construction – the transport plan refers to there being additional tracks are required for construction and areas of Carmichael facilitate crushed stone on the access tracks – and a typical cross hardstanding for the site compound, these will be created (Appendix 4 construction. section. This is important as the run-off form these using interlocking sheet material of either reinforced plastic or ref. A4.1d) tracks may carry sediment and this run-off should be aluminium trackway. The tracks and the hardstanding will managed by means of sustainable drainage solutions. It adhere to the minimum buffer distances from trees, must not be allowed to enter the existing water courses hedgerows and water courses as defined in the updated CEMP as it is likely to have a different pH if limestone (Section 11). chippings are used as surfacing material. For the same reason temporary storage areas and parking areas These matters were discussed further with Rosie Carmichael on should be shown on the same plan, and the run-off from 25.03.2020 and her further comments are contained in these areas should also be managed by SUDS. This plan Appendix 4 (ref. A4.1d). should accompany the planning application.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk Em 39
Amended layout plans now show the positions of both the permanent track to be improved and the locations of the temporary trackway. Further details in respect of access tracks is now also provided in the updated CEMP.
28 CCC - Buffers From the site clearance plan Section 4.3 of the LEMP has been updated to provide options Conservation adjacent to (https://www.springche.com/s/Site-Clearances-Plan-ref- to the management of the buffer areas while safeguarding the Project Officer hedgerows SP-SCD2-PL.pdf) it looks like there is only a 5m gap ecology enhancements that are proposed. Amanda and woodland between the hedges and the security fences. I don’t Grazing is not proposed along grassland buffers/corridors but is Evans think taking a hay cut is practical in such a narrow within the fenced solar panel site areas. (Appendix 4 buffer. Light sheep grazing, possibly in the winter only, ref. A4.1e) across the whole site is recommended (buffers and under panels). This should be monitored and adjusted to prevent overgrazing. 29 CCC - Grassland A list of the [grass seed mix] species to be used is Section 4.3 of the LEMP provides further information on the Conservation beneath solar required. CCC Ecology can recommend an appropriate enhancements to the grassland, based on discussions with Project Officer panels species mix. CCC’s Rosie Carmichael. Amanda Evans (Appendix 4 ref. A4.1e) 30 CCC – Suggest I suggest you contact the Conservation section to A meeting was initially arranged for 26.03.2020, however as a Planning arranging a discuss habitat management prior to submission of the result of the Government guidance introduced on 23.03.2020 Officer Gary meeting with DNS. A site meeting with your ecologist would be to ‘stay at home’ (ref. COVID-19), the meeting was replaced by Glenister Lindsay useful. a telephone conference call that took place on 25.03.2020. (Appendix 4 Rendle & Following the conference call meeting, Rosie Carmichael ref. A4.1b) Rosie provided supplementary comments on ecology and rural Carmichael to discuss conservation. These are included in Appendix A4.1b – please refer to highlighted text. Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 40
ecology issues.
31 CCC – The Location The ‘Location Plan’ does not include a blue line The Applicant is a developer with rights over the areas of land Landscape Plan boundary to define other land owned by the applicant, within the planning redline of the application site. The Officer Steve close to or adjoining the application site. Applicant does not own adjacent land such that it can be Welchman included within a blue line. (Appendix 4
ref. A4.1f) For the avoidance of doubt, the red line of the application site follows the field boundaries rather than the proposed fenced boundaries and therefore covers the areas subject to habitat and planting management programmes.
32 CCC - Layout Plans The ‘planning boundary’ (red line) as indicated on The proposed layout plans include the cable route details with Landscape ‘Proposed Site Layout’ plans do not appear to cover the varying shades to denote the technique for laying the cable. Officer Steve areas of land which would accommodate the proposed The cable is laid entirely underground. Welchman cable route. (Appendix 4 The existing plans have also been updated to include the cable ref. A4.1f) route in red.
33 CCC - Layout Plans However, the cable route is indicated as a narrow single . The Location Plan has been updated to provide a corridor Landscape red line following the proposed alignment on the area of land required for the process of laying the cable. Officer Steve ‘Location Plan’. Welchman (Appendix 4 ref. A4.1f) 34 CCC - Cable Trench It is noted that the proposed trench dimensions are Due to the scale of the Plans, it is not possible to demonstrate Landscape 1.4m depth x 0.6m width – this would result in a the width of the cable route. The Location Plan has however Officer Steve potential significant operational width to enable safe been updated to provide two vertical lines to denote the area Welchman excavation and machine access. It is advised that the required for the cable and to install the cable. (Appendix 4 operational width of all sections of cable route ref. A4.1f) proposed for trench excavation should be included within the application boundary.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
35 CCC - LVIA – The location of the 33kV substation is located in In the revised layout plan the location has been moved as far as Landscape Location of proximity to the public right of way – relocation would reasonably practical from the PRoW, whilst maintaining Officer Steve substation act to minimise visual impacts to users of the route. practical accessibility for Western Power Distribution (WPD) Welchman (Appendix 4 It is proposed to colour the substation green; RAL140 20 20 ref. A4.1f) (BS12 B29); as advised by the landscape officer, which will help assimilate the structure into its surroundings and minimise visual impacts.
36 CCC - Layout Plans The ‘Proposed Site Layout’ plans do not include the The existing farm tracks within the site will be improved as Landscape location, layout or construction details of any access required by adding additional 300mm granular material. Where Officer Steve tracks or other areas of hard surfacing associated with additional tracks are required for construction and areas of Welchman either the construction or operational phases. The Flood hardstanding for the site compound, these will be created (Appendix 4 Consequence Assessment at para 4.5. states that ‘tracks using interlocking sheet material of either reinforced plastic or ref. A4.1f) will be formed in 300mm granular material’. Proposed aluminium. The tracks and the hardstanding will adhere to the tracks or other hard standing areas may result in minimum buffer distances from trees, hedgerows and water associated impacts to existing hedge line boundaries, courses as defined in the Construction Management Plan trees or woodland and potential surface water/ SAB (Section 11). implications. It is advised that appropriate information be provide to enable full assessment. 37 CCC - Elevation The drawings [of substation and transformer The Transformer and substation housings will be green colour Landscape drawing of housings]do not provide definition of material RAL140 20 20 (BS12 B29); as advised by the landscape officer, Officer Steve substation specification, colours or finishes. [colours are suggested] which will help assimilate the structure into its surroundings Welchman and minimise visual impacts. (Appendix 4
ref. A4.1f)
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 42
38 CCC - Planning Para 6.3.8 states ‘Selected hedgerow and tree in-fill This paragraph was a discrepancy in the Planning Statement Landscape Statement planting to existing boundaries, new hedgerows and report that was the subject of the pre-application consultation Officer Steve extensive woodland replacement planting will also exercise. Welchman improve screening and promote the field pattern and (Appendix 4 regular landscape structure.’ The comments made in this paragraph are not applicable to ref. A4.1f) It appears that the following identified elements are not the Tycroes solar DNS application and the Planning Statement detailed within any of the submitted documents has now been updated to remove these comments. − ‘new hedgerows’ − ‘extensive woodland replacement planting’
39 CCC - LVIA – It is not clear how the visual impacts to individual The submitted LVIA document has been updated to identify Landscape residential residential properties have been assessed. the closest residential properties to the site and to discuss the Officer Steve properties This is not included within the Landscape and Visual likely impacts to these properties. Welchman Impact Assessment (LVIA) (Appendix 4 Paragraphs 3.90 – 3.92 and 6.58 – 6.61 of the updated LVIA are ref. A4.1f) applicable in respect of discussing this issue.
The LVIA concludes (ref. Para 6.61 of the LVIA) that: Properties that are not ‘involved’ (as a landowner) in the project would experience either a ‘low impact’ or ‘neutral impact’. Of those properties that are involved, one property (Ty-Isaf - immediately to the south and east of Area 3) would be expected to experience a ‘medium impact’.
40 CCC - Fencing LVIA defines a 2m high fence to PV array areas whereas This was a discrepancy and has now been corrected. The Landscape elevation drawings indicate 2.4m correct height is dictated by reasons of security and is 2.4m. Officer Steve Welchman (Appendix 4 ref. A4.1f)
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 43
41 CCC - CCTV and LVIA does not appear to include CCTV, or proposals for The existing farm tracks within the site will be improved as Landscape Access Tracks access tracks or hardstanding areas required by adding additional 300mm granular material. Where Officer Steve additional tracks are required for construction and areas of Welchman hardstanding for the site compound, these will be created (Appendix 4 using interlocking sheet material of either reinforced plastic or ref. A4.1f) aluminium trackway. The tracks and the hardstanding will adhere to the minimum buffer distances from trees, hedgerows and water courses as defined in the Construction Management Plan (Section 11).
CCTV equipment will be located as marked in the updated proposed site layout drawings (Site Plan Proposed 1of3 ref. SP- SL1-D02-PL and Site Plan Proposed 3of3 ref. SP-SL3-D02-PL). CCTV will be at a maximum height of 4m as shown in CCTV Plan ref. SP-CTD2-PL.
The submitted LVIA has been updated in Paragraphs 1.6, 2.20, 4.9, 4.15, 4.16, 4.19, 5.1 and 6.18 to discuss these elements of the proposal.
42 CCC - Residential The LVIA does not contain a specific Residential Amenity Please refer to Item 39 on the previous page as Item 42 is a Landscape Amenity impact assessment. The LVIA identifies individual repeat comment on the same topic. Officer Steve residential properties as high sensitivity visual amenity Welchman receptors and draws conclusions on impacts. (Appendix 4
ref. A4.1f) 43 CCC - Identify It is advised that a clear schedule and location plan A plan identifying the locations of the closest properties is Landscape Residential which identifies the properties which have been included as Figures 3 and 4 of Paragraph 4.3 of the submitted Officer Steve Properties assessed should be included for transparency and to Glint and Glare Study report prepared by ‘Pager Power’. Welchman enable the residents to effectively comment on the (Appendix 4 proposals. The LVIA report can be cross referenced with Paragraphs 3.90 – ref. A4.1f) 3.92 and 6.58 – 6.61 of the updated LVIA.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
44 CCC - LEMP The Landscape and Ecology Management Plan identifies Ref. to ‘new hedgerows’ and ‘extensive woodland replacement Landscape does not provide the following landscape elements planting’ comes from a discrepancy in the Planning Statement Officer Steve identified within the Planning Statement: - the subject of the pre-application consultation. Welchman − ‘new hedgerows’ (Appendix 4 − ‘extensive woodland replacement planting’ For the avoidance of doubt, as per comments in relation to ref. A4.1f) It is advised that inclusion of these elements be Item 38 of this Table, no new hedgerows, or extensive clarified. The wider landscape is characterised by strong woodland replacement planting are proposed as part of this hedge line framework with small deciduous woodland solar farm proposal because no new hedgerows or woodland blocks. Appropriate inclusion of these landscape replacement planting is necessary. elements (in the red or blue line boundaries) would This information was included in the planning Statement assist integration of the proposed development and accidentally and has now been removed from the report that is delivery of policy objectives. The Landscape and Ecology submitted with the formal DNS application. Management Plan should be amended to include any additional elements For information on boundary treatments in respect of the management of the existing landscaped boundaries of the 3 site areas, please refer to the submitted Landscape Masterplan Drawings (Figures 18A and 18B of the LVIA).
45 CCC - Implementing The Landscape and Ecology Management Plan does not The application site area; as outlined in red, covers all those Landscape the LEMP define the mechanism, or responsibility for delivery long areas covered by the proposed ecological and landscape Officer Steve term maintenance, management or monitoring mitigation / management schemes. Welchman Experience from previous solar PV development within (Appendix 4 Carmarthenshire has identified the importance of The red line of the three site areas include the grassland ref. A4.1f) securing this information prior to determination corridors and hedgerow field boundaries. These areas It is advised that a draft legal agreement between the represent the areas of land that would be leased by the landowner(s) and any future solar PV operator should Applicant. The Applicant therefore bares the responsibility of be provided prior to determination to enable effective the implementation of ecological and landscape mitigation / and constructive legal clarification to be established to management schemes; as expected to be required by ensure that either: - appropriately worded conditions of planning. a Proposed lease boundaries include all land covered by the Landscape and Ecology Management Plan; in which case all responsibility for delivery shall be undertaken by However, the applicant is willing to share excerpts from the the leasee OR agreements held with landowners to verify the lessee’s b The existing landowner(s) are aware and legally responsibility in this matter. (N.B. sensitive personal and responsible for delivery of all elements of an approved commercial data will be omitted) Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 45
Landscape and Ecology Management Plan (and that any related financial liabilities are included within lease agreements)
46 CCC - LEMP and The Landscape and Ecology Management Plan; and Please refer to Items 38 and 44 above in respect of comments Landscape Landscape Illustrative Landscape Masterplan drawings Figs 18 A made to ‘new hedgerows’ or ‘extensive woodland replacement Officer Steve Masterplan and 18B provide details of an overall landscape concept. planting’. Welchman drawings However, the submitted documents do not include (Appendix 4 Figs 18 A sufficient landscape specification information to enable As part of discussions with CCC’s Rosie Carmichael, the ref. A4.1f) and 18B approval, compliance monitoring or enforcement. Applicant has agreed to undertake a Hedgerow Management It is advised that appropriate specification information Plan in pursuance of satisfying a condition of planning. The and detail of any additional landscape elements (‘new ecological requirement for this plan will also identify landscape hedgerows’ or ‘extensive woodland replacement characteristics of the existing hedgerows. The plan can planting’) be provided in an approvable Landscape therefore double as additional information in respect of habitat Design Scheme prior to determination. and landscape management.
The Landscape Masterplan drawings Figs 18A and 18B does not propose additional landscape planting other than any gaps being infilled with native hedgerow species.
The additional survey information in respect of the proposed Hedgerow Habitat Management Plan would provide a proportionate amount of additional information to address these comments by CCC’s landscape officer to the Landscape Masterplan drawings.
47 CCC - Landscape Landscape proposal plan providing clear indication of The Landscape Masterplan drawings Figs 18A and 18B do not Landscape Design the following: - propose additional landscape planting other than any gaps Officer Steve Scheme - location of all existing landscape elements within, on being infilled with native hedgerow species. Welchman Information or adjacent to the site boundary; which are to be (Appendix 4 Requirements retained or translocated; The additional specific information being sought can be ref. A4.1f) - definition of the material types for all external space, secured by way of a suitably worded condition of planning, including areas to be planted and grassed, and areas of Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
hard surfacing; providing a detailed management plan that specifies these - location, extents and description of all proposed elements and to be approved by CCC, if necessary. landscape elements, as distinct landscape types, i.e. wildflower grass areas, shrub, hedge, individual trees, etc. • Landscape 48 CCC - Landscape Landscape specification information The Landscape Masterplan drawings Figs 18 A and 18B do not Landscape Design - Plant specification for all proposed distinct landscape propose additional landscape planting other than any gaps Officer Steve Scheme types to include: - being infilled with native hedgerow species. Welchman Information - Plant species, varieties and cultivars (Appendix 4 Requirements - Planting stock specification (stock size, form, root The additional specific information being sought could be ref. A4.1f) condition etc.) secured by way of a suitably worded condition of planning, - Planting specification for all proposed distinct providing a detailed management plan that specifies these landscape types to include: elements and to be approved by CCC, if necessary. - Depths of topsoil and subsoil; ground preparation and cultivation - Dimensions of planting pits or trenches and proposed backfill material - Planting densities/spacing or numbers - Methods of weed control, plant protection and support - Seed mix specifications and sowing rates; and/or turf specification - Translocation method statement (if required)
49 CCC - Applicant It is not clear whether consultation has been Consultation with The City and County of Swansea Council was Landscape should undertaken with CC Swansea LPA – this authority area undertaken as part of the pre-application consultation exercise. Officer Steve consult City will be subject to potential significant visual impacts The Authority responded to advise that they had ‘no comments Welchman and County of from rising ground to the eastern side of the Loughor at this stage’. (Appendix 4 Swansea Valley ref. A4.1f) Council 50 CCC - High Pressure It is noted that the South Wales high pressure gas The Health and Safety Executive (HSE) were consulted on this Landscape Pipeline pipeline and associated clearance areas pass through proposal as part of the pre-consultation exercise. The HSE Officer Steve site 2; it does not appear that this constraint has been comments advised that the: Welchman acknowledged within the submitted.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
(Appendix 4 “easternmost sections of the proposed development area fall ref. A4.1f) within HSE public safety zones associated with Major Accident Hazard Pipeline(s)”,
and that..
“Providing no populations are introduced within any part of the proposed development, HSE does not advise against the proposed project”.
HSE also advised that “There are currently no Major Hazard Installations in the vicinity of the proposed project.”
Please refer to Appendix 4 (Ref. 4.4) for a copy of the HSE response.
Considering the close proximity of the HSE public safety zones associated with Major Accident Hazard Pipeline(s) the developer will carry out full consultations with the appropriate operators of these gas pipe lines to ensure development can be installed in accordance with prevailing guidelines for development workings within such areas.
51 CCC - Horizontal It is noted that the proposals include horizontal The installation of the cable utilises three techniques: Landscape Directional directional drilling (HDD) of the cable route through A. Conventional trench system Officer Steve Drilling areas of semi-natural broadleaved woodland, under B. Horizontal Directional Drill (HDD) Welchman running water features and within some areas of C. Trenchless system of ‘moling’ the cable (Appendix 4 marshy grassland. It is recommended that this ref. A4.1f) technique be considered for use at hedgeline crossing An illustrative section drawing of the HDD is now contained in points. the submitted CEMP (Figure 8 in Paragraph 13.6) and the plans that accompany The Arboricutural ‘Supplementary Report’ outline details of a typical ‘trenchless system of ‘moling’ the cable (dated 26 March 2020 which has been prepared by Woodland & Countryside Management Ltd).
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
Most of the route will be installed by way of the conventional trench system.
The HDD route will be used for the routing beneath Afon Gwili and the semi-natural broadleaved woodland as well as for crossing the A483.
In those locations where a conventional trench system is not suitable (such as crossing hedgerows), the Applicant has shown a ‘trenchless’ system to be used. This will involve a bore-hole technique known as ‘moling’ the cable underneath features such as hedgerows.
52 CCC - General CCC Planning Ecologist has provided detailed comment Arboricultural comments provided by CCC are covered by Items Landscape comments on the submitted arboricultural information - all 1-13 of this Table and are provided by CCC Officers Lindsey Officer Steve comments are fully endorsed Rendle and Rosie Carmichael. Welchman (Appendix 4 The Applicant’s consequent actions to these comments are ref. A4.1f) discussed alongside these Item numbers.
53 CCC – Glint and An assessment of glint and glare would be required as The Glint and Glare Assessment formed part of the pre- Planning glare part of the determination process. application consultation documentation. It has since been Officer Gary updated in the light of comments received by Trunk Roads Glenister (Item 74). Public
Protection comments The Assessment reviews anticipated impacts on residential receptors as well as road users and concludes the proposal (Appendix 4 would not result in significant glint or glare impacts. ref. A4.1b)
54 CCC – Noise General advice is provided regarding noise and planning. The Applicant notes these comments by the Planning Officer Planning Please note that solar schemes can generate noise from Gary Glenister. Considering the low levels of noise that are Officer Gary the transformers, inverters and rain hitting the panels, produced by the electrical equipment being installed in Glenister so an assessment of impact on residential properties conjunction with the distances to the nearest receptors, a Public will need to be undertaken as part of the process. Noise Assessment is not necessary as part of this proposal. Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
Protection comments For the avoidance of doubt, equipment noise level data is now provided in Section 6.4 of the Planning Statement. (Appendix 4 ref. A4.1b)
55 CCC – Flood As the development area is more than 100sqm, SAB This comment is noted and the flood risk engineer Clive Onions Planning Consequences approval would be required for surface water drainage. would prepare this application for SAB approval as and when a Officer Gary Assessment DNS permission is granted and prior to the commencement of Glenister (FCA) any development. Drainage
comments Details of the proposed management of surface water drainage (Appendix 4 are contained in the Clive Onions FCA report. ref. A4.1b)
56 CCC – Built Heritage No response has been received from the conservation These comments have been noted and consultation has been Planning officer, however it is noted that CADW has identified carried out with Cadw. This is discussed further in Item 77 of Officer Gary historic assets in the vicinity. In particular, I note that this Table. Glenister Built Area 1 is relatively close to and would be seen in the Heritage context of the Listed Plas Mawr / Cwrt y Ceidrim House Reference the comments about the potential for ‘indirect comments (LB 19453) when viewed at distance from the rising land impacts’, the applicant’s Flood Risk Engineer Clive Onions has (Appendix 4 on the Swansea side of the Loughor Valley which also prepared a Surface Water Drainage Strategy as part of the FCA ref. A4.1b) has Scheduled Ancient Monuments. Area 3 is also to design out the potential for indirect impacts arising. within 500m of Plas Newydd Mill (LB 19451). The proposal could affect the Mill indirectly if surface water The Heritage Impact Assessment (HIA) prepared by is affected and has an impact on the Afon Gwili. This Archaeology Wales references the proposed surface water will need careful consideration. drainage strategy to confirm that this would mitigate against the potential for any indirect impacts. 57 Coal Authority Recommend that the layout should be amended and The Coal Authority identified three areas of concern in respect – Planning designed around both the conjectured positions of the of known former shallow mine workings. Two of these Liaison shafts and their respective zones of zones of influence. locations relate to the cable route and are adjacent to the Manager A483, and the third is located at the north west edge of Site Chris Area 3. McCarthur
Website: www.renplan.co.uk
(Appendix 4 A method to address these known constraints was agreed in ref. A4.3) post consultation telephone correspondence between the Applicant’s Geo-Technical Consultant ‘Yellow Sub Geo’ and the Coal Authority.
In respect of the two risk areas along the cable route and the A483, the Applicant has committed to undertaking suitable works to investigate, assess and (if necessary) remediate the shafts to the satisfaction of the Coal Authority as part of the detailed design phase of the project when a contractor is appointed to carry out these works. It is considered appropriate that such work be controlled by use of a suitably worded planning condition, thus ensuring that the Coal Authority maintains oversight and approval of the works. Please refer to Section 3. Of the Yellow Sub Geo Addendum dated 25th March 2020 for further information.
In respect of the known shallow mine shaft entry at Site Area 3, it has been agreed with the Coal Authority to provide a 20m radius zone of influence from the shaft meaning no solar panels or associated equipment in this area. A hand dug method of installing security fencing would be used within the zone of influence.
Please refer to Sections 3 and of the Yellow Sub Geo Addendum dated 25th March 2020 for further information.
The submitted layout plans have been amended to reflect the required 20m clearance distance of the ‘zone of influence’ from the shaft entry.
Website: www.renplan.co.uk
58 CCC - Traffic and Notwithstanding this, ‘area 3’ of the solar development Highways and roads will impact upon the U2310 unclassified county road, The Transport Statement has been amended to take into Transport we therefore expect details to be included within the consideration the potential impacts on other users of the Officer Aaron Transport Statement to assess the county highway at U2310 and to remove any risk of causing a blockage hazard on Evans this location and any potential impacts i.e. carriageway the unclassified road when entering from the A48. (Appendix 4 ref. A4.1c) width/passing places as well as visibility splays for accesses to the parcels of lands (fields). Visibility splays In respect of Site Area 3, the tracking shows access from the shall be in accordance with standards set out in County Road A48 onto the unclassified U2310 and into Site Technical Advice Note 18 (TAN 18). It is noted solar Area 3; as illustrated in Appendix 2. panel parcels will be in fields/lands both north and south of the U2310 carriageway. The updated CEMP confirms in Paragraph 5.4 the proposed strategy for accessing Site Area 3 from the U2310 County Road. The U2310 unclassified road may not be utilised as a ‘through route’ however is regarded as on and actually links the A48 to the west with the A483 to the east, correct measures/mitigation shall therefore be considered, assessed and incorporated into the development proposals.. There is currently limited information in the TS and CEMP of any possible impact on U2310 county road and the mitigations measures that may be necessary. 59 HSE - Dave. High Pressure The Health and Safety Executive (HSE) were consulted The Health and Safety Executive (HSE) were consulted on this MHPD. Adams Gas Pipelines on this proposal as part of the pre-consultation exercise. proposal as part of the pre-consultation exercise. The HSE On Behalf of HSEW comments note the easternmost sections of the comments advised that the: NSIP proposed development area fall within HSE public safety Applications zones associated with Major Accident Hazard “easternmost sections of the proposed development area fall
(Appendix 4 Pipeline(s): within HSE public safety zones associated with Major Accident • Hazard Pipeline(s)”, Ref. 4.4) 28 Feeder Felindre (Swansea)/Brecon [Transco ref: 2776, HSE ref 4027393] • Pontardulais/Ammanford (HW066) [Transco ref: and that.. 1629, HSE ref 7370] “Providing no populations are introduced within any part of the Providing no populations are introduced within any part proposed development, HSE does not advise against the of the proposed development, HSE does not advise proposed project”. against the proposed project. Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
HSE also advised that “There are currently no Major Hazard HSE also advised that “There are currently no Major Installations in the vicinity of the proposed project.” Hazard Installations in the vicinity of the proposed project.” Please refer to Appendix 4 (Ref. 4.4) for a copy of the HSE response.
Considering the close proximity of the HSE public safety zones associated with Major Accident Hazard Pipeline(s) the developer will carry out full consultations with the appropriate operators of these gas pipe lines to ensure development can be installed in accordance with prevailing guidelines for development workings within such areas.
60 NRW – Rhian Absent Survey Although the document covers much of the proposed The initial NRW comments dated 28.02.20 are enclosed in Isaac – information cable route and fields (largely) on the eastern side of the Appendix 4 ref. A4.5a). Development site, it does not include the whole development area, as Planning marked on the red-line site boundary. There appears to Following receipt of the NRW consultation comments, the 2 x Team be no survey information on the land to the west of the Preliminary Ecological Appraisal (PEA) reports for the solar sites
Comments Afon Gwili and field F14, where we understand that and secondly for the cable route were both updated. received solar arrays will also be installed. 28.02.2020 Therefore, before we can provide further comments, we The Applicant sought further comments from NRW on the & would require additional survey information on these updated PEA’s. NRW have since confirmed (ref. email 24.03.2020 areas, along the potential impacts on the Caeau Mynydd correspondence contained in Appendix 4 Ref. A4.5b) that Mawr SAC, surrounding Caeau Afon Gwili SSSI and Felin having reviewed the updated reports, their main concerns are (Appendix 4 Fach Meadows SSSI, particularly in relation to habitat with respect to the cable route. In reviewing the updated Ref. A4.5a & fragmentation and its impacts to Marsh Fritillary PEA’s, NRW advised that “our concerns have mostly been A4.5b) butterflies (Annex II species), which are the feature of addressed, however there are still some concerns regarding the SAC and SSSIs. otters and dormice but there are mitigation measures proposed.”
The Applicant sought from NRW to establish agreement to the proposed mitigation measures. A response has not been received to this most recent correspondence (copy enclosed in Appendix 4 Ref. A4.5b). This may be because with the outbreak
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 53
of Covid-19, NRW have suspended their discretionary pre- application service until further notice.
The PEA was updated with respect of providing mitigation for both otters (Paragraph 5.3.10) and dormice (Paragraph 5.3.5). The mitigation is considered proportionate in the light of the identified risks.
The Applicant remains confident that the proposed otter and dormice mitigation is sufficient and proportionate to address the identified risk from the proposed laying of the cable route and the solar panel areas.
Ref. comment on Field 14: The PEA that was consulted on included two smaller areas close to Site 3. This is because at the time the survey work was carried out (May 2019), these two fields were ‘available’ within the same ownership. A detailed review of various planning constraints has since dictated that neither should be included in any layout design and they are therefore not included for solar development in this application
The PEA survey work pre-dates the layout designs for this proposal.
Please refer to the submitted Location Plan for the red line for the application site and the Proposed Layout Plans for details of the panel layouts and cable route.
To avoid any future confusion, the PEA reports relating to the three site areas have been updated to delete the two small areas of land close to Site 3
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 54
61 NRW – Rhian Mitigation This additional information should also include any Please see Applicant’s ‘Consequential actions’ comments to Isaac – and updated mitigation and enhancement Item 60. Development Enhancement recommendations for the surrounding protected sites Planning and for Section 7 habitats that may be impacted by the Mitigation is provided in the updated PEA’s for the solar panel Team scheme. site areas and the PEA for the cable route.
Comments received NRW have since provided additional comments advising that 28.02.2020 “our concerns have mostly been addressed, however there are & still some concerns regarding otters and dormice but there are 24.03.2020 mitigation measures proposed.”
(Appendix 4 Please refer to (Appendix 4 Ref. A4.5a & A4.5b) Ref. A4.5a & A4.5b) 62 NRW – Rhian Field 13 The Ecological Assessment has also identified that field Field F13 is not impacted by the proposal; the cable being Isaac – F13 contained marsh grassland habitat, and that this is drilled beneath this area of land. Development field located directly adjacent to the Caeau Afon Gwili Planning SSSI. The PEA report has been updated as part of the DNS Team submission. Paragraph 4.4.3 for the cable route states “It is
Comments expected that the construction and operation of the proposed received cable route would have a negligible effect on the interest 28.02.2020 features of these sites, due to separation distance and the & habitat types” 24.03.2020 Paragraph 4.4.3 of the PEA advises that “No mitigation is (Appendix 4 recommended in relation to adverse effects on Nationally Ref. A4.5a & designated sites (SSSIs)”. A4.5b)
63 NRW – Rhian CEMP The Construction and Environmental Management Plan The updated CEMP addresses each of the matters listed by Isaac – CEMP January 2020) has provided some details and of NRW to the CEMP; providing additional information and clarity Development working times, traffic movement and habitat protection, on the measures proposed to be implemented to manage Planning however there is limited information regarding pollution construction associated environmental impact. Team prevention during construction.
As a minimum we recommend the plan should include:
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 55
Comments • Identification of surrounding watercourses and received potential pollution pathways from the construction site 28.02.2020 to those watercourses. & • How each of those watercourses and pathways will be 24.03.2020 protected from site run off.
(Appendix 4 • How the water quality of the watercourses will be Ref. A4.5a & monitored and recorded. A4.5b) • What the construction company intends to do with surface water runoff from the site during the construction phase. Please note that it is not acceptable for ANY pollution (e.g. sediment/silt/oils/chemicals/cement etc.) to enter the surrounding watercourses. • storage facilities for all fuels, oils and chemicals • measures for dealing with any contaminated material (demolition waste or excavated waste) • identification of any buried services, such as foul sewers, so that they are protected • details of emergency contacts, for example Natural Resources Wales’ Pollution Hotline. 64 NRW – Rhian Caeau Afon This addition information should provide confirmation For the avoidance of doubt, the cable route does not fall within Isaac – Gwili SSSI and justification as to how the SSSI and surrounding the SSSI but passes the northern boundary of the Caeau Afon Development habitat will be protected. We would also wish to see Gwili SSSI where it is directionally drilled beneath this land. Planning further information on working methods, for the open There are no above ground works at or adjoining the SSSI. Team trench cable installation in field F8.
Comments The updated PEA for the cable route discusses the cable route received in the context of local SSSI’s including: 28.02.2020 & Paragraph 4.4.3 for the cable route states “It is expected that 24.03.2020 the construction and operation of the proposed cable route would have a negligible effect on the interest features of these (Appendix 4 sites, due to separation distance and the habitat types” Ref. A4.5a & A4.5b)
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
Paragraph 4.4.3 of the PEA advises that “No mitigation is recommended in relation to adverse effects on Nationally designated sites (SSSIs)”.
Further information has been included in the updated PEA for the cable routes that discusses the open trench cable installation at Field 8.
65 NRW – Rhian Bats Bats Please see Applicant’s ‘Consequential actions’ comments to Isaac – Section 3.3.5 of the assessment states that: ‘no suitable Item 60 Development features for roosting bats were present with the Planning footprint of the cable route.’ However, it is unclear The PEA for the solar array site areas 1, 2 and 3 confirms in Team whether there are any trees with potential roosting Paragraph 3.6.5 that “No suitable features for roosting bats
Comments features (PRF’s), across the rest of the development site, were present within the footprint of the proposed solar PV received or whether any such trees would be impacted by the array. Trees associated with boundaries enclosing Site A and 28.02.2020 development. This needs to be clarified. Site B are largely early mature and would not provide much in & Furthermore, the assessment states that: ‘Trees the way of bat roosting habitat, although occasional larger 24.03.2020 associated with woodland along the River Gwili may trees are present that would have potential roosting features. provide some potential for roosting bats.’ However, it Boundaries enclosing Site C have little in the way of larger trees (Appendix 4 unclear whether any of these trees with potential have with potential for roosting bats.” Ref. A4.5a & been subject to detailed inspection or would be A4.5b) impacted by the development. This also needs to be For the avoidance of doubt, the proposal does not involve the clarified and detailed within the ES. removal of any trees, or indeed the pruning, lopping or topping of any trees.
NRW has assumed an ES would accompany this DNS application which is not the case. The EIA screening direction was negative in this regard.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk
66 NRW – Rhian Otters Otter Please see Applicant’s ‘Consequential actions’ comments to Isaac – Section 3.3.12 of the Ecological Appraisal acknowledges Item 60 Development that; ‘it is likely that otters are actively foraging along Planning the river Gwili, although a search of the banks on either During survey work, no evidence of otters were found. Team side of the cable route failed to find any likely holt sites.’ However, the Afon Gwili is noted as suitable foraging habitat.
Comments Although, this section mentions ‘either side of the cable received route’, it is not clear whether either side of the river The Applicant appreciates the land is suitable otter habitat and 28.02.2020 bank (in the vicinity of the development), were also therefore Paragraph 5.3.10 of the PEA for the proposed cable & surveyed. We advise that this is clarified route provides best practice mitigation in relation to the works 24.03.2020 that have the potential to take place in areas that might be used by otter. (Appendix 4 Ref. A4.5a & These mitigation recommendations will be implemented and a A4.5b) condition of approval securing these measures would, be welcomed by the Applicant.
67 NRW – Rhian LVIA The photographs and photomontages should be These comments have been noted and checked with the Isaac – produced in accordance with the recent Landscape Applicant’s Landscape Consultant Amalgam Landscape and Development Institute Technical Guidance Note 06/19 Visual have been confirmed to comply with the prevailing guidance Planning Representation of Development Proposals. quoted. Team
Comments received 28.02.2020
(Appendix 4 Ref. A4.5a) 68 NRW – Rhian Flood Risk However, we would wish to highlight that the proposed The cable will not cross the River Gwili but instead will be Isaac – cable route crosses the River Gwili, which is classed as crossed via horizontal directional drill following the Development Main River. Therefore, it is likely that this activity methodology detailed in section 13 of the CEMP. Therefore a Planning requires a Flood Risk Activity Permit. We would direct Flood Risk Permit would not be necessary. As identified by the Team you to https://naturalresources.wales/permits-and- exemption 3 on flood risk exemption – ‘the erection of a service
permissions/flood-risk-activities/?lang=en with specific crossing below the bed of a main river by directional drilling not reference to the potential use of Flood Risk Activity
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 58
Comments Exemptions 2 and 3 which may be suitable. If this involving an open cut technique’. The Applicant will register received exemption does not apply, we would encourage you to this exemption with Natural Resources Wales via FRAX01 Form. 28.02.2020 contact us as soon as possible to discuss the Flood Risk Activity Permit. The cable route colouring was one colour in the PEA (Appendix 4 documents the subject of the pre-application consultation Ref. A4.5a) which suggests (without cross reference to the submitted Layout Plans) a potential impact. It is therefore reasonable for NRW to assume the proposals might cross the River unless they also refer to the Site Layout Plans.
To avoid future mis-interpretation of these drawings in the DNS application submission, the PEA documents have now been updated to revise the colouring for the different means of laying the cable to make it clear where those areas of the cable are either drilled or ‘moled’ under landscape features.
69 NRW HRA The applicant will need to provide sufficient information The pre-application consultation did include a Habitat for the competent authority to be able to carry out a Regulations Screening that concludes an Assessment would not Habitat Regulations Assessment (HRA). be necessary as it is not expected there would be significant impacts on protected species as a result of this proposal.
70 Trunk Roads – Area 2 Access This access is via a field gate located on a redundant Following receipt of these comments, Acstro Ltd (the Route section of highway (now used as a substandard layby Applicant’s Transport Consultant) made contact with Richard Engineer and access to 3 dwellings). The field gate appears too Jones of Trunk Roads to discuss the required updates to the Richard Jones narrow to accommodate the number and size of Transport Statement (TS).
vehicles that is proposed for the site. The access is also (Appendix 4 Ref. 4.4) unsurfaced and likely to breakup during the The TS has been updated accordingly to provide additional construction of the park. In addition, this access will be information in respect of providing access for construction into used for future maintenance operations during all times the 3 site areas. This information includes a more detailed and of the year. There should be measures in the details amended delivery traffic information in respect of the type and that take care of mud and detritus being deposited on number of HGV movements. the lay-by or carriageway. This access should be improved with the gate widened, surfaced in a suitable Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 59
material and set back to allow vehicles to park off the In addition, Appendices to the Transport Statement provide lay-by area. This in turn would require a S184 swept path analysis for access of HGV movements into Site application. It should also be demonstrated that the Areas 2 and 3. improved access either meets standards or has been accepted for use with an appropriate departure at In respect of Site Area 2, this involves a widening of the gated Welsh Government. entrance to facilitate access from the A483; as illustrated in Appendix 1. This addresses this Item comment by Trunk Roads.
71 Trunk Roads – Area 2 Access Exiting this layby and making a left turn to travel south Additional work to address these comments includes Route with a HGV rigid body or an articulated vehicle Appendices 1 and 2 to the Transport Statement. Engineer transporting the 40ft container would be very tight. A Richard Jones swept path analysis of this area showing the turning Appendix 1 to the Transport Statement provides a swept path
manoeuvres should be provided to assess the potential analysis for access of HGV movements into Site Area 2 from the (Appendix 4 Ref. 4.4) impacts. A483. The drawing shows a widening of the gated entrance to facilitate access from the A483.
72 Trunk Roads – Area 3 Access. The documentation delivery/construction vehicles will The TS has been updated accordingly to provide additional Route be instructed to not make the right turn manoeuvres information on access for construction into the 3 site areas. Engineer into this County road junction. How is this going to be This information includes a more detailed and amended Richard Jones enforced during the construction process? There are delivery traffic information in respect of the type and number
proposals for a banksman but how would this person of HGV movements. (Appendix 4 Ref. 4.4) control movements on a dual carriageway? The access to the site compound is via a single track County road Additional work to address these comments includes with very limited passing areas and forward Appendices 1 and 2 to the Transport Statement. visibility. There is no mention of how vehicular movements are going to be controlled along this section In respect of Site Area 3, the tracking in Appendix 2 shows of road to prevent vehicles stacking at the junction with access from the A48 onto the unclassified U2310 and into Site the Trunk Road. Again, as with the access to Area 3, a Area 3 is achievable and satisfactory without undue risk to swept path for articulated vehicles carrying the 40ft highway safety. container would be required especially to ensure that a vehicle travelling in the opposite direction does not cause an issue at the junction. 73 Trunk Roads – General On all access points, we would require that the wheel The TS has been updated accordingly to provide additional Route comments washing facilities are present at all times. It is also information in respect of the issues raised by Richard Jones in relating to noted that aggregate materials for access tracks are to Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 60
Engineer access to all 3 be delivered in 10t loads, please confirm that this is respect of wheel washing facilities, traffic types and loads, Richard Jones site areas correct as this will increase the number of vehicular number of movements, and works at the site compounds. movements to and from each area. The TS also (Appendix 4 identifies areas for site compounds. With the number The Transport Statement also acknowledges in Section 5 that a Ref. 4.4) of construction workers estimated for the site(60 to Traffic Management Plan (TMP) would be adopted by the 120) this will generate a number of additional Principal Contractor (when they are appointed) and sets out a movements which have not been included within the TS minimum level of information that such a plan should contain. and will need to be allowed for. Prior to any works It is expected that a condition of approval would require the commencing on site a Traffic Management Plan must be TMP to be submitted for approval by CCC in consultation with submitted for approval. Trunk Roads; prior to the commencement of development. 74 Trunk Roads – glint and glare A ‘Glint and Glare’ document has also been included The Applicant’s Glint and Glare consultant Pager Power has Route within the submission. This document has highlighted a updated the Glint and Glare Study report with a new version Engineer few areas of concern with the majority being mitigated dated March 2020. The revised report is updated to address Richard Jones by the comment ‘Screening in form of vegetation has these comments and confirms the vegetation exists currently
been identified’ but it not clear if this is current and concludes that “the maximum impact forecasted for any (Appendix 4 Ref. 4.4) vegetation or additional planting. There are some areas type of vehicle travelling on A483 is “low” and no mitigation is located on the A483 that they expect some ‘Low required under such conditions.” impact’. The assessment has been undertaken at a height of 1.5m above the road surface which is low for The Report also concludes that “no impact is anticipated for any HGV or agricultural vehicular movements along the any type of vehicle travelling on A48 at all seven receptor Trunk Road Network. locations, and no mitigation is required”.
75 Trunk Roads – Cable route The Location plan included within the list of The laying of the cable will take place within the highway verge Route road works documentation shows a red line between Area 3 and and will be carried out by an accredited operative and Engineer Area 2 which according to the ‘Landscape and Ecology overseen by an accredited supervisor. The proposal will to be Richard Jones Management Plan’ is the cable route. There is no laid cable in verge of highway using a trench. The operator of
assessment of this route nor who will be responsible for the solar farm would retain ownership of the cable. (Appendix 4 Ref. 4.4) the installation and ownership of the new cable along the Trunk Road Network and we require further details A Section 50 Licence in accordance with The New Roads and of this. Streetworks Act 1991 would be required from the Highway Authority being Welsh Government – Trunk Roads. This licence would be applied for once permission has been granted. It’s noted that works must commence within three of the licence being granted, and be completed with six months of licence
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 61
being granted. No works will undertaken in highways until the licence has been granted.
76 CCC – Ecology Drilling It would be useful to have illustrations of the direct An illustration depicting a horizontal directional drill process Rosie drilling and borehole techniques has been included in the CEMP at figure 8. Carmichael Further Comments (Appendix 4 ref. A4.1d) 77 Cadw – Initial Heritage Summary of initial comments provided by Denise Harris: The HIA prepared by Archaeology Wales was initial rejected by comments Submitted Heritage Impact Assessment (HIA) is Cadw. The HIA was therefore re-worked in the light of the provided by inadequately documented and does not properly follow initial comments provided by Denise Harris- Casework Denise Harris the methodology of prevailing guidance and therefore a Manager. – Casework proper assessment of the proposal cannot be made. Manager (Appendix 4 Re-consultation took place on the amended HIA in April 2020 Ref. A4.2a) Summary of Supplementary response provided by and amended comments were received from Nichola Davies on th Nichola Davies: 15 April 2020 advising that Cadw agree with the analysis of Supplementar the amended HIA and therefore have no objections to the y Comments proposal. provided by Nichola Davies – Casework Manager (Appendix 4 Ref. A4.2b) 78 City and No Comments N/a N/a County of Swansea Council –
79 Welsh Water No Objection N/a N/a
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 62
6. Main issues
6.1 Introduction
6.1.1 The preceding Chapter (5) has sought to identify and separate each issue raised by each consultee and address or resolve each issue wither within the table or through reference to relevant updated report.
6.1.2 This Chapter (6) aims to address the main issues arising from consultation, providing the applicant’s ‘rounded’ response to each of the main issues, having considered feedback received through the pre-application consultation exercise. These main issues have been assembled into the following subject considerations:
Main Issues: A. Highway Safety, Traffic Management and Site Access B. Local Biodiversity C. Protected Species & Habitat Regulations Screening D. Landscape and Visual E. Public Amenity F. Heritage G. Flooding and Surface Water Drainage H. Coal Mine Workings I. Construction and Environmental Management
6.1.3 These issues listed are discussed in order below using the recommended template for grouping of main issues as provided in the ‘Development of National Significance Appendix 7. The Consultation Report’ Guidance.
Renplan Ltd, Office 207, The Hiv Website: www.renplan.co.uk
63
Main issue A. Highway Safety, Traffic Management & Site Access Relevant Principal Application Document: application Transport Statement documents: Glint and Glare Study Ancillary Application Documents: Design and Access Statement Construction and Environmental Management Plan (CEMP) Respondents: Carmarthenshire County Council (CCC) Highways Welsh Government – Trunk Roads Applicant’s Consultation responses identified concerns in respect of the access summary of capabilities of the proposed access into Site Area 2 and requested the responses: additional clarifications in respect of the access capabilities of Site Area 3. Further information was sought in respect of general access considerations. Applicant’s The Applicant instructed Acstro Ltd (the Transport Consultant) to response, undertake additional work to demonstrate the accesses into site Areas 2 including and 3 are both achievable and acceptable. Swept path analysis of HGV reasons: movements are provided for both accesses and updated traffic types and numbers accessing site Area 2 has also been provided as part of this work. In addition, the gated access from the public highway into Site Area 2 has been widened. The further general transport related information has also now been incorporated into the Transport Statement.
Main issue B. Local Biodiversity Relevant Principal Application Documents: application Preliminary Ecology Appraisal (PEA) – Solar Site Areas documents: Preliminary Ecology Appraisal (PEA) – Cable Route Landscape and Ecology Management Plan (LEMP) Ancillary Application Documents: Construction and Environmental Management Plan (CEMP) Respondents: Carmarthenshire County Council (CCC) Natural Resources Wales (NRW) Applicant’s Comments received in respect of local wildlife impacts and the summary of enhancement and management of local wildlife habitat. the responses: Applicant’s Discussions were undertaken with CCC’s Rural Conservation Officer acting response, also as Service Lead for CCC’s biodiversity officer. Agreement has been including reached in relation to what additional information would be included in reasons: amended PEA’s and LEMP and which matters may satisfactorily be dealt with by way of condition/s of planning.
Both PEA’s and the LEMP have been updated since the pre-application consultation exercise to address each of the detailed comments raised by CCC and to reflect discussions with CCC’s Officer Rosie Carmichael. The PEA’s and LEMP have also been updated to have regard for comments received by NRW that did not relate to protected species.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 64
Main issue C. Protected Species & Habitat Regulations Assessment Relevant Principal Application Documents: application Preliminary Ecology Appraisal (PEA) – Solar Site Areas documents: Preliminary Ecology Appraisal (PEA) – Cable Route Landscape and Ecology Management Plan (LEMP) Ancillary Application Documents: Construction and Environmental Management Plan (CEMP) Respondents: Natural Resources Wales (NRW) Carmarthenshire County Council (CCC) Applicant’s Concerns have been raised in respect of mitigation measures needed to summary of be secured for potential impacts to otter; a nationally protected species the responses: Concerns have been raised in respect of mitigation measures needed to be secured for potential impacts to dormice; a nationally protected species Concerns also raised in respect of the need for additional clarifications and information to be included in the PEA’s. Applicant’s The PEA survey work did not find evidence of otters although it is response, acknowledged that the River Gwili is suitable foraging habitat and there including are records of otter in the general area. Mitigation had not previously reasons: been considered necessary because of the nature of the cable works. However, the PEA for the cable works has since been updated to provide mitigation measures that would help avoid potential impacts. The Applicant will implement the mitigation measures as set out in the PEA. The PEA identified records of dormice in the general area and site surveys identified some of the hedgerows as suitable habitat for dormice. Mitigation is set out in the updated PEA’s which would mitigate the risk for the potential for impacts. The Applicant will implement the mitigation measures as set out in the PEA. The PEA’s have also been updated to provide additional clarifications and information sought by CCC and NRW. Specific detail is provided in Chapter 5 of this report to address potential misinterpretation of plans / PEA information.
Main issue D. Landscape and Visual Relevant Principal Application Document: application Landscape and Visual Impact Assessment (LVIA) documents: Landscape and Ecology Management Plan (LEMP) Ancillary Application Document: Planning Statement Respondents: Carmarthenshire County Council (CCC) Natural Resources Wales (NRW) Applicant’s Amendments requested to Site Location and Site Layout Plans, Elevations summary of of Equipment and position of Substation. the responses: Requested additional information about new landscape planting and replacement planting to compensate for loss. These impacts were gleaned from a discrepancy contained in the Planning Statement that was consulted on in the pre-application exercise. Comments raised by CCC Landscape officer in respect of the proposed landscape masterplan (Figures 18A and 18B of the LVIA). Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 65
Implementing the LEMP.
Applicant’s Amendments requested to the plans have been made and these now response, form part of the DNS application. including Additional information in respect of new landscape planting and reasons: replacement planting to compensate for loss are not necessary – this comment being a discrepancy in the Planning Statement which has now been removed from this report. The Landscape Masterplan is considered sufficient for the purpose of the determination of the DNS. The discrepancies of the Planning Statement have been removed. The LEMP has been updated to take forward the advice received, and it is also considered deliverable as all management practices being proposed fall within the site areas outlined red.
Main issue E. Public Amenity Relevant Principal Application Documents: application Landscape and Visual Impact Assessment (LVIA) documents: Glint and Glare Study Ancillary Application Document: Planning Statement Respondents: Carmarthenshire County Council (CCC) Applicant’s CCC’s landscape officer requested that the LVIA should include an summary of assessment of impacts on the occupiers of nearby residential properties. the responses: CCC’s public protection identified the need for glint and glare assessment CCC’s public protection identified that noise needs to be considered. Applicant’s The Applicant’s landscape consultant, Amalgam Landscape has updated response, the LVIA to incorporate an assessment of impacts on residential amenity. including All impacts to non-involved properties were concluded to be low or reasons: neutral whilst only one property would be expected to experience a medium impact however this property is an ‘involved’ property as a landowner where panels would be installed. A glint and glare assessment was included as part of the pre-application consultation. Details of anticipated noise impacts are discussed in the Planning Statement. The low noise levels created by equipment in conjunction with the distances to closest receptors means noise is not considered an issue for this proposal. Equipment noise level data has now been provided in Section 6.4 of the Planning Statement.
Main issue F. Heritage Relevant Heritage Impact Assessment (HIA) application documents: Respondents: Carmarthenshire County Council (CCC) Cadw
Renplan Ltd, Office 207, The Website: www.renplan.co.uk
Applicant’s CCC: Advised that surface water drainage impacts may have indirect summary of impacts on a nearby listed building Plas Newydd Mill (LB 19451). Attention the responses: drawn by CCC to the importance of Cadw’s comments. Cadw: After an initial objection to the methodology of the HIA, Cadw were re-consulted with an amended HIA. Cadw confirmed in supplementary correspondence that they have no objections to the proposal.
Applicant’s Clarity has been provided in the finalised HIA that the surface water response, drainage strategy contained in the Flood Consequences Assessment including would mitigate any indirect risks to heritage assets. reasons: The revised HIA also addressed all other salient heritage considerations associated with the proposal.
Main issue G. Flooding and Surface Water Drainage Relevant Principal Application Documents: application Flood Consequences Assessment (FCA) documents: Ancillary Application Documents: Preliminary Ecology Appraisal (PEA) – Cable Route Respondents: Natural Resources Wales (NRW) Applicant’s Unless an exemption applies, a Flood Risk Permit would be needed for the summary of cable route which crosses the River Gwili. the responses: Applicant’s The previous version of the cable route PEA did not make clear that the response, cable would be installed beneath the Afon Gwili using a Horizontal including Direction Drill (HDD). Using conventional trenching methods would cause reasons: significant impacts to the River Gwili, where using an HDD method will not. The PEA drawings have been revised to specify the method of cable installation beneath the River Gwili by adding colours to the cable route and describing the method of laying in the legend.
Main issue H. Coal Mine Workings Relevant Coal Mining Risk Assessment application documents: Respondents: The Coal Authority Applicant’s The Coal Authority identified 3 risk areas associated with known former summary of shallow coal mining shafts. the responses: Applicant’s The Applicant’s Geotechnical consultant has liaised with the Coal response, Authority and agreed revisions to the Coal Risk Assessment and the Site including Layout to incorporate the following: reasons: Apply mitigation for the two shafts identified at the A483 with these details to be secured and subsequently agreed between the developer’s contractor and the Coal Authority prior to these works commencing. Revise the layout design to avoid the third identified shaft by providing a 20m radius zone of influence buffer where no panels or equipment would be installed. The security fencing that would fall within this buffer area would be installed using a hand dug method. Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 67
Main issue I. Construction and Environmental Management Relevant Construction and Environmental Management Plan (CEMP) application documents: Respondents: Carmarthenshire County Council (CCC) Natural Resources Wales (NRW) Applicant’s Amendments sought to refer to watercourse buffers, a methodology for summary of HDD works, details of access tracks, mitigation measures for the U2310 the responses: County Road and pollution prevention measures. Applicant’s Additional information has been incorporated int the Site Layout Plans response, and the submitted CEMP to address the issues raised in respect of the including installation process. Additional drawings have been provided to illustrate reasons: the method of installing a cable using a horizontal directional drill.
Renplan Ltd, Office 207, The Hive, 6 Beaufighter Road, Weston-super-Mare, North Somerset, BS24 8EE Website: www.renplan.co.uk 68
BACK PAGE
Renplan Ltd, Office 207, The Website: www.renplan.co.uk 69