Flood Consequence Assessment 5

Flood Consequence Assessment 5. 2

Brechfa Forest Connection Development Consent Order Application - Reference EN020016

Flood Consequence Assessment

May 2015

Regulation reference: The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 Regulation 5(2)(e)

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Contents

1 Introduction 4

2 Context and scope of work 6

3 Legislation and policy context 8

4 TAN 15 11

5 Sources of information/consultation 13

6 Climate change 15

7 Nant Pibwr Crossing 16

8 Flood mitigation measures – Nant Pibwr 24

9 Planning Context 27

10 Site description – Towy/Gwili floodplain 30

11 Flood mitigation measures – Towy/Gwili floodplain 45

12 Planning context 50

13 Site description – River Gwili crossing 54

14 Flood mitigation measures – River Gwili 63

15 Planning context 67

16 Conclusions and recommendations 70

17 References 72

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Tables

Table 3.1: National legislation and policy context 8

Table 3.2: LDF policy context 10

Table 5.1: Relevant studies 13

Table 7.1: NRW modelled river levels (mAOD) for the Nant Pibwr node NP6 21

Table 10.1: NRW modelled river levels (mAOD) for the River Towy (nodes AT*) and River Gwili (nodes AG*) 36

Table 10.2: Predicted flood levels at works locations 38

Table 10.3: Present day tidal levels for at Carmarthen Quay 40

Table 11.1: Danger to people for different combinations of depth and velocity 48

Table 13.1: NRW modelled river levels (mAOD) for the River Gwili 59

Figures

Figure 7.1: Site location plan 16

Figure 7.2: TAN15 Development Advice Map (accessed April 2015) 19

Figure 7.3: Environment Agency surface water flood map (accessed April 2015) 22

Figure 10.1: Site location plan 31

Figure 10.2: TAN15 Development Advice Map (accessed April 2015) 35

Figure 10.3: Environment Agency surface water flood risk map (accessed April 2015) 41

Figure 10.4: Environment Agency reservoir flood map (accessed April 2015) 43

Figure 13.1: Site location plan 55

Figure 13.2: TAN15 Development Advice Map (accessed April 2015) 58

Figure 13.3: Environment Agency surface water flood map (accessed April 2015) 60

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Appendices

Appendix A – RSK Service Constraints

Appendix B – Natural Resources Wales flood level data

Appendix C – Nant Pibwr crossing plans

Appendix D – Towy/Gwili Floodplain crossing plans

Appendix E – River Gwili crossing plans

Appendix F – Natural Resources Wales correspondence

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1 Introduction

1.1.1 RSK Land and Development Engineering Ltd (RSK) was commissioned to carry out a Flood Consequence Assessment (FCA) for WPD (Client). The assessment is in support of the Environmental Impact Assessment as part of a planning submission to PINS for the proposed development.

1.1.2 The assessment has been prepared in accordance with Planning Policy Wales (PPW) (Ref. 1) and the Technical Advice Note 15 (TAN 15) (Ref. 2), the Interim Code of Practice for Sustainable Drainage (Ref. 3) and BS 8533-2011 Assessing and Managing Flood Risk in Development Code of Practice (Ref. 4), with site- specific advice from the Natural Resources Wales (NRW), Carmarthenshire County Council (CCC) and the client.

1.1.3 The NPPF sets out the criteria for development and flood risk by stating that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. The key definitions are:

. “Areas at risk of flooding” means land within Flood Zones B and C1 or C2; or land within Flood Zone A which has critical drainage problems and which has been notified to the local planning authority by NRW; and

. “Flood risk” means risk from all sources of flooding including from rivers and the sea, directly from rainfall on the ground surface and rising groundwater, overwhelmed sewers and drainage systems, and from reservoirs, canals and lakes and other artificial sources.

1.1.4 For this Flood Consequences Assessment three locations are being assessed:

. OHL crossing of the Nant Pibwr north of the A48;

. HDD and Open Trench works within the Towy/Gwili floodplain between

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Carmarthen and Abergwili; and

. OHL crossing of the Gwili between Llanpumsaint and LLanllawdogg.

1.1.5 For this site, the key aspects that require the assessment are:

. The NRW’s Development Advice Map shows that these locations cross or are located within Flood Zones B or C2.

1.1.6 The comments given in this report and opinions expressed are subject to RSK Group Service Constraints provided in Appendix A.

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2 Context and scope of work

2.1.1 A key element of project development is to prepare a FCA to establish the flood risk associated with the proposed development and to propose suitable mitigation, if required, to reduce the risk to a more acceptable level.

2.1.2 The scope of work relating to a FCA is based on the guidance provided in Chapter 13 of Planning Policy Wales (Ref. 1) and its accompanying Technical Advice Note (TAN) 15 (Ref. 2).

2.1.3 A site-specific FCA must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. The scope of this assessment therefore comprises the following elements:

. to review architect plans, planning information and other studies to determine existing site conditions;

. to obtain information on the hydrology and hydrological regime in and around the site;

. to obtain the views of the NRW including scope, location and impacts;

. to determine the extent of new flooding provision and the influence on the site;

. to assess the impact on the site from climate change effects and anticipated increases in rainfall over a 60 year period for the energy infrastructure (poles) and over a nine month period (undergrounding civils operations being completed within an estimated two months and a further one month for cable installation, i.e. cable pulling through the ducts) period for the temporary works and compounds in the Towy/Gwili location and for the working areas associated with the pole erection at the Nant Pibwr and River Gwili crossings;

. to review site surface water drainage based on the proposed layout and, if necessary, to determine the extent of infrastructure required;

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. to provide mitigation measures to protect the safety of the users and the equipment at the temporary compounds and works locations; and

. to prepare a report including calculations and summaries of the source information and elements reviewed.

2.1.4 This report is in support of the following key reports and information:

. Environmental Impact Assessment (Ref. 5) carried out by RSK for WPD.

2.1.5 Reliance has been place on factual and anecdotal data obtained from the sources identified. RSK cannot be held responsible for the scope of work, or any omissions, misrepresentations, errors or inaccuracies with the supplied information. New information, revised practices or changes in legislation may necessitate the re-interpretation of the report in whole or in part.

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3 Legislation and policy context

3.1 National policy

Table 3.1: National legislation and policy context

Legislation Key provisions

Planning Policy Wales (PPW) contains guidance considered relevant to the scope of the environmental assessment. PPW is supported by a number of Technical Advice Notes (TANs). Flood Risk and climate change are considered in section 13.2, this section highlights that flood risk is a material consideration. Paragraph 13.2.4 highlights that “meeting the Welsh Government’s objectives for sustainable development requires action through the planning system to move away from flood defence and mitigation of the consequences of new development in areas of flood hazard towards a more positive avoidance of development in areas defined as being of flood hazard.” Section 13.4 addresses development management and flood risk, this section highlights the NPS, stating that “development proposals in areas defined as high flood hazard should only be considered:  new development can be justified in that location, even though it is likely to be at risk from flooding; and  the development proposal would not result in the Planning Policy Wales (Ref. 1) intensification of existing development which may itself be at (2014) risk; and  new development would not increase the potential adverse impacts of a flood event. Section 13.12 considers development management and improvements to the quality of water and air. It states that pollution affecting the use of land will be a material consideration and will include location, impact on health and amenity, risk to the surrounding environment, prevention of nuisance, impact on the transport network and the need, where relevant, and feasibility of restoring the land to standard sufficient for an appropriate use. Section 13.10 of PPW highlights the need to improve water and air quality. Paragraph 13.10.1 states that: “The planning system should determine whether a development is an acceptable use of land and should control other development in proximity to potential sources of pollution rather than seeking to control the processes or substances used in any particular development”.

Technical Advice Note (TAN) 15 technical guidance which Technical Advice Note 15 supplements the policy set out in Planning Policy Wales in relation to (Ref. 2) development and flooding. TAN 15 provides advice on:

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. development advice maps; . nature of development or land use; . justifying the location of built development; . assessing flooding consequences; . surface water run-off from new development; . action through Development Plans; . development control; and . development affecting protected and priority habitats and species.

The Flood and Water Management Act (FWMA) aims to implement the findings of the 2007 Pitt Review and co-ordinate control of drainage and flood issues. Flood and Water There are a number of increased responsibilities within the Act that (Ref. 6) Management Act 2010 affect adoption of Sustainable Drainage Systems (SuDS) features and the role of NRW to expand on the mapping data they provide. The implementation of SuDS features has many beneficial impacts on the treatment of surface water during remediation works.

Section 24 - The NRW is empowered under this Act to maintain and improve the quality of ‘controlled’ waters Water Resources Act 1991 Section 85 - It is an offence to cause or knowingly permit pollution of (Ref. 7) controlled waters Section 88 - Discharge consents are required for discharges to controlled waters

The Water Framework Directive (WFD) requires all inland and coastal waters to reach ‘good’ chemical and biological status by 2015. Flood risk management is unlikely to have a significant impact on chemical water quality except where maintenance works disturb sediment (such as de-silting) or where pollutants are mobilised from Water Framework Directive contaminated land by floodwaters. (2000) The main impact of the WFD on flood risk management, both now (Ref. 8) and in the future, relates to the ecological quality of water bodies. Channel works, such as straightening and deepening, or flood risk management schemes that modify geomorphological processes can change river morphology. The WFD aims to protect conservation sites identified by the EC Habitats Directive and Birds Directive that have water-related features, by designating them as ‘protected sites’.

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3.2 Local policy

Table 3.2: LDF policy context

LDF document Key provisions and policies

The relevant policies are listed below: . CDUP9 - Landscape/Environment . GDC30 - Development and Flood Risk Carmarthenshire Unitary . EN10 - Protection of Controlled Waters and Water Development Plan (Adopted Resources 2006) . UT2 - Electricity Lines . UT8 – Surface Water . UT12 - Pollution

The relevant policies are listed below: . SP1 - Sustainable Places and Spaces . SP2 Climate Change Carmarthenshire Local . SP14 - Protection and Enhancement of the Natural Development Plan - Environment Composite Plan (December . GP1 - Sustainability and High Quality Design 2014) . EP1 - Water and Environmental Capacity . EP2- Pollution . EP3- Sustainable Drainage

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4 TAN 15

4.1.1 TAN15 provides technical guidance on flood risk and development which supplements the policy set out in Planning Policy Wales.

4.1.2 In line with Figure 2 of TAN15, the development category for the works is Less Vulnerable Development, which includes utilities infrastructure. In line with Figure 1 of TAN15, less vulnerable development is acceptable in Flood Zones C1 and C2 subject to the application of the justification test, including the acceptability of consequences.

4.2 Justification Test

4.2.1 Where development is outlined in Flood Zone C1 or C2, the development will only be permitted if determined by the planning authority to be justified in that location. As such, development will only be justified if it can be demonstrated that:

1. Its location in Zone C is necessary to assist, or be part of, a local authority regeneration initiative or a local authority strategy required to sustain an existing settlement; or

2. Its location in Zone C is necessary to contribute to key employment objectives supported by the local authority, and other key partners to sustain an existing settlement or region;

4.2.2 And

3. It concurs with the aims of PPW and meets the definition of previously developed land; and

4. The potential consequences of a flooding event for the particular type of development have been considered and in terms of the criteria contained in sections 5 and 7 and appendix 1 (TAN15) found to be acceptable.

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4.3 Assessing Flood Consequences

4.3.1 To satisfy the criteria of the assessment of flood consequences, the following conditions should be satisfied;

1. Flood defences must be shown by the developer to be structurally adequate;

2. The cost of future maintenance for all new/approved flood mitigation measures, including defences must be accepted by the developer and agreed with NRW;

3. The developer must ensure that future occupiers of the development area are aware of the flooding risk and consequences;

4. Effective flood warnings are provided at the site;

5. Escape/evacuation routes are shown by the developer to be operational under all conditions;

6. Flood emergency plans and procedures produced by the developer must be in place;

7. The development is designed by the developer to allow the occupier the facility for rapid movement of goods to areas away from the floodwaters;

8. Development is designed to minimise structural damage during a flooding event and is flood proofed to enable it to be returned to its prime use quickly in the aftermath of the flood;

9. No flooding elsewhere.

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5 Sources of information/consultation

5.1 Natural Resources Wales consultation

Development Advice Maps

5.1.1 The NRW Flood Zone mapping for Wales is available on their website at http://maps.environment-agency.gov.uk/

Site specific consultation

5.1.2 Natural Resources Wales have been consulted throughout the project, with a request for flood related information (including flood levels) included in the consultation. Their full response to the flood data request can be found in Appendix B. NRW also provided details of their river model of the River Towy, River Gwili and Nant Pibwr, which have been used in this assessment and are discussed further in Section 7.2 (Nant Pibwr), Section 10.2 (Gwili / Towy confluence) and Section 13.2 (River Gwili).

5.2 Relevant studies

Table 5.1: Relevant studies

Study Comments

The principle aim of the SFCA was to map all forms of flood risk in order to provide an SFRA: evidence base to locate new development. It Carmarthenshire County also aims to provide appropriate policies for Council Strategic Flood the management of flood risk, and identify the Consequences level of detail required for site-specific FCAs. Assessment The SFCA contains information and maps 2011(Ref. 11) detailing flood sources and risks. Information relevant to the site is detailed in Sections 7.2, 10.2 and 13.2 of this report.

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5.3 Development Plans

5.3.1 Plans for the Nant Pibwr crossing location works are located in Appendix C.

5.3.2 Plans for the works in the Towy/Gwili Floodplain are included in Appendix D.

5.3.3 Plans for the River Gwili crossing location works are located in Appendix E.

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6 Climate change

6.1.1 Within the context of the existing flood risk at the site, and the requirements of the PPW and TAN15, climate change impacts from different flood sources have been considered alongside the present day scenario as described in Section 7.

6.1.2 As an overview; Climate change can affect local flood risk in several ways. Impacts will depend on local conditions and vulnerability.

6.1.3 In the Western Wales River Basin District, wetter winters and more rain falling in wet spells may increase river flooding for rivers and tributaries. More intense rainfall causes more surface runoff, increasing localised flooding and erosion. In turn, this may increase pressure on drains, sewers and water quality. Storm intensity in summer could increase even in drier summers. Rising sea or river levels may increase local flood risk inland or away from major rivers because of interactions with drains, sewers and smaller watercourses.

6.1.4 In accordance with the requirements of the PPW the latest climate change predictions will be considered within this assessment.

6.2 UK Climate Predictions (UKCP09)

6.2.1 From UK Climate Predictions (UKCP09) data, latest figures for Western Wales River Basin District show that if emissions follow a medium future scenario, UKCP09 projected changes by the 2050s (2040-2069) relative to the recent past are:

. winter precipitation increases of around 15% (very likely to be between 3% and 33%);

. precipitation on the wettest day in winter up by around 12% (very unlikely to be more than 27%); and

. peak river flows in a typical catchment likely to increase between 12% and 20%.

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7 Nant Pibwr Crossing

7.1 Site description

Location

7.1.1 Site Name: Nant Pibwr Crossing

7.1.2 Location: North of A48, approximately 1.3km west of Nantycaws

7.1.3 Site National Grid Reference: Easting: 243978; Northing: 218413

7.1.4 Figure 7.1 shows a site location plan, with further mapping included in Appendix C.

Figure 7.1: Site location plan

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Proposed Development/Works

7.1.5 The proposal for the location is the erection of a single pole angle/section (Pole 73). Associated working areas and access routes will be utilised, with the construction process in the area taking a few days. The single strung wooden pole will remain in the flood zone following construction.

Geology

7.1.6 Based on published geological records for the area (British Geological Survey online mapping), the site exhibits the following geology:

. Superficial Geology: Alluvium

. Base rock Geology: Tetragraptus Beds

Hydrology

7.1.7 Description of hydrology of Nant Pibwr:

7.1.8 Main River, approximately 2-3m wide, meandering (straight at crossing point), vegetation lined banks, flows in a westerly direction towards the River Towy.

Hydrogeology

7.1.9 Hydrogeological information was obtained from the Natural Resource Wales online mapping service. These maps indicate that the site is underlain by a Secondary B bedrock aquifer (predominantly lower permeability layers which may store and yield limited amounts of groundwater due to localised features such as fissures, thin permeable horizons and weathering). The maps also indicate that the site is underlain by a Secondary A superficial aquifer (permeable layers capable of supporting water supplies at a local rather than strategic scale, and in some cases forming an important source of base flow to rivers).

7.1.10 The site is not located within a Groundwater Source Protection.

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7.2 Sources of flood risk

Criteria

7.2.1 In accordance with the PPW, TAN 15 and advice from Natural Resources Wales, a prediction of the flood sources and levels is required along with the effects of climate change from the present for the design life of the development (in this case assumed to be 60 years).

7.2.2 The flood risk elements that need to be considered for any site are defined in BS 8533 as the “Forms of Flooding” and are listed as:

. Flooding from Rivers (fluvial flood risk);

. Flooding from the Sea (tidal flood risk);

. Flooding from the Land;

. Flooding from Groundwater;

. Flooding from Sewers (sewer and drain exceedance, pumping station failure etc); and

. Flooding from Reservoirs, Canals and other Artificial Structures.

7.2.3 The following section reviews each of these in respect of the Nant Pibwr crossing location.

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Flooding from rivers (fluvial flood risk)

Main River

Figure 7.2: TAN15 Development Advice Map (accessed April 2015)

7.2.4 Development Advice Map (Figure 7.2) shows that the site lies within Flood Zone C2: without significant flood defence infrastructure (Zones C1 and C2 are based on Environment Agency’s extreme flood outlined >=0.1% (river tidal or coastal)).

7.2.5 The resultant fluvial flood risk is considered to be high.

7.2.6 River levels have been supplied by Natural Resources Wales for a number of nodes within the vicinity of the crossing location (Appendix B). The closest river nodes to the site area NP5 and NP6 approximately the same distance from the crossing location. The river levels for key flood events are given in Table 7.1. These levels take into account the fluvial flows of the Nant Pibwr.

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Table 7.1: NRW modelled river levels (mAOD) for the Nant Pibwr node NP6

Water Surface Elevation (mAOD) for the Annual Probability of Flooding

Node Grid Ref 50% 20% 10% 4% 2% 1.3% 1% 0.5% 0.2% 0.1%

244028; 25.5 25.7 25.8 25.9 25.9 26.0 26.0 26.1 26.2 26.2 NP5 218430

243888; 24.8 24.9 25.1 25.3 25.5 25.5 25.6 25.7 25.8 25.9 NP6 218354

7.2.7 For a 1 in 100 (1%) year annual probability of flooding the maximum predicted water level is 26.0m AOD.

Climate change

7.2.8 The works at this location are only scheduled to last 1-3 days, with construction envisaged for 2016. As such, climate change will not be an influence during the construction of the poles, and due to the nature of the development, will not impact on the structure.

Flooding from the sea (tidal flood risk)

7.2.9 The site is not considered to be at risk from tidal flooding due to its elevation.

7.2.10 The resultant tidal flood risk is considered to be low.

Flooding from the land (surface water flood risk)

7.2.11 Intense rainfall can create conditions where the local infiltration and drainage capacity is insufficient to cope with the volume of water and so water flows overland. Surface water flooding can also occur due to a reduction in the capacity of a drainage system due to some form of blockage.

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Figure 7.3: Environment Agency surface water flood map (accessed April 2015)

7.2.12 The Environment Agency’s online map ‘Risk of Flooding from Surface Water’ (Figure 7.3) indicates that the site is at high risk from this source of flooding due to the floodplain nature of the area.

7.2.13 The risk of surface water flooding at the site is considered to be high and mitigation measures will be implemented to protect the workforce during the erection of Pole 73.

Climate change

7.2.14 Surface water flooding is likely to increase as a result of climate change in a similar ratio to fluvial flooding. Increased intensity and frequency of precipitation is likely to lead to reduced infiltration and increased overland flow. Due to the nature of the development and the short time frame for development, climate change will not result in an increase in surface water flood risk.

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Flooding from groundwater

7.2.15 Groundwater flooding occurs when the water held underground rises to a level where it breaks the surface in areas away from usual channels and drainage pathways. Groundwater flooding typically occurs following long periods of sustained intense rainfall and is typically associated with low-lying areas underlain by permeable aquifers.

7.2.16 Due to the small scale of the completed development (single wooden pole) and short duration of the construction, flooding from groundwater is not considered an issue and the risk can be quantified as low.

Climate change

7.2.17 Climate change will not result in a change in groundwater flood risk to the site.

Flooding from sewers

7.2.18 Due to the nature of the development and works, and the Greenfield location (it is anticipated that there are no sewers in the area which would contribute to flood risk) and as such, flooding from sewers is assessed as being low.

Climate change

7.2.19 Climate change will not result in a change in sewer flood risk to the site.

Flooding from reservoirs

7.2.20 Flood events can occur from a sudden release of large volumes of water from reservoirs, canals and artificial structures.

7.2.21 According to the Environment Agency reservoir flood maps, the site is not at risk of reservoir flooding.

7.2.22 The resultant flood risk is considered low.

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Climate Change

7.2.23 Climate change will not result in a change in reservoir flood risk to the site.

7.3 Historic flooding

7.3.1 Due to the flood plain nature of the site, flooding to the proposed development area is likely to have occurred in the past, however given the rural nature of the site, information is not available.

7.4 Flood risk resulting from the development

7.4.1 In theory any development can increase flood risk downstream, if it is not designed properly.

7.4.2 Due to the nature of the development (single wooden pole), there will be a negligible increase in impermeable area, with no attributable increase in surface water runoff or restriction in flows. As such, there will be no increase in flood risk resulting from the development.

7.5 Flood risk summary

7.5.1 From the Development Advice Maps (Figure 7.2), the whole site is located within Flood Zone C2 (EA’s >= 0.1% Flood Outline) and as such is at a high risk of flooding from fluvial and tidal sources.

7.5.2 Flood risk from pluvial sources is also considered to be high according to the Environment Agency’s flood map (Figure 7.3).

7.5.3 The flood risk to the workforce during the construction period is high and as such mitigation measures to protect the workforce in line with Section 8 below should be put in place.

7.5.4 Flood risk from other sources (groundwater, sewer and artificial bodies) to the site is also considered to be low or very low.

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8 Flood mitigation measures – Nant Pibwr

8.1 Overview

8.1.1 This section focuses on the flood risk mitigation measures proposed for the site focused on the key flood risks to the site. Access and egress to and from the site and flood warning and emergency evacuation are also considered.

8.2 Safe access/egress

8.2.1 For works at Pole 73 south of the Nant Pibwr, access to and egress from the working area is along the access road from the east, off the A48. The access track is located within Flood Zone C2.

8.2.2 In the unlikely event that personnel were on site at the onset of flooding, egress from the site compound would initially be immediately south towards the A48 (located in Flood Zone A). Should the site be flooded when erection of the pole is due, the works should be delayed until flood waters have receded.

8.3 On site safety

8.3.1 The main factors reflecting on site safety for the workforce is the velocity and depth of flood waters on site and the presence of personnel on site at the onset of a flooding event. A main safety aspect of flooding is that of the availability of a safe means of access/egress from the site.

8.3.2 The main means by which flood risks will be managed is through the Environment Agency’s Flood Warning System. The site is located within the NRW Flood Alert Area classified as ‘Rivers in the lower Towy catchment downstream of Llandeilo excluding Llandeilo’. The NRW charter is to provide a minimum two hours advance warning, which would provide sufficient time for site users to be evacuated to an area of safe refuge to the south on the A48. There will be no future users of the site.

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8.3.3 Flood warnings have no effect on flood levels or flows, but provide individuals with an opportunity to respond in advance of a flood. They also provide the opportunity for devising an appropriate ‘incident’ management strategy. Management procedures are to be developed to assess the risk of flooding following advice either from Natural Resources Wales or the LLFA. This assessment should consider evacuation of the site if a severe flood event is expected.

8.3.4 Flood warnings should be incorporated into a ‘Flood Risk Management’ strategy for the whole site. Site staff and management should be made aware of the availability of these and be registered with the SMS text warning service.

8.4 Personal safety

8.4.1 If there are any instances of workers being on site, a Flood Evacuation Plan should be provided, or included in operational management plans, to provide guidance to operators and visitors in the event of a flood event. The Flood Evacuation Plan will include the following:

. how flood warning will be disseminated;

. priorities for protection of critical infrastructure;

. availability of staff and time taken to respond to a flood warning;

. provision and maintenance of a refuge area for staff;

. the time needed to evacuate the site;

. provision of safe access to and from the development; and

. expected time taken to re-establish normal operation following a flood event.

8.5 Flood Evacuation Plan

8.5.1 Details of evacuation plans for the works in this area would be developed prior to commencing construction and would detail the procedure to be followed once a flood warning or alert is received from NRW. Primary considerations for the

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evacuation plan include:

. Evacuation of personnel for the working areas at risk of flooding – this is the primary safety consideration, and is the highest priority in the unlikely event that there is insufficient time to make the site safe prior to evacuation; and

. Making the site safe prior to evacuation – this would include appropriate storage of equipment and materials, securing items within the site compounds to prevent them being mobilised in flood water.

8.5.2 Potential safe evacuation routes for the working areas have been detailed below.

8.6 Flood warning and evacuation

8.6.1 The site lies within an area designated to receive Flood Alerts from NRW for Rivers in the lower Towy catchment downstream of Llandeilo excluding Llandeilo.

8.6.2 Areas of Flood Zone A are located in very close proximity to the south of the working area. Emergency evacuation of the site should be directly to the south and the A48.

8.6.3 As the works are only temporary (1-3 days for each pole erection) with no permanent future users, the default position for the site will be dependent on flood warning and safe egress/evacuation to the south in the event of a flood.

8.6.4 Works will not be undertaken during a flood event and no personnel should go on site until flood waters have receded.

8.7 Flood resistance and resilience measures

8.7.1 No flood resilient/resistance measures are proposed for this development (x1 wooden pole).

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9 Planning Context

9.1 TAN 15 Justification Test

9.1.1 In line with Section 6, the following criteria should be met to demonstrate that the development is justifiable in C1 or C2:

. Its location in Zone C is necessary to assist, or be part of, a local authority regeneration initiative or a local authority strategy required to sustain an existing settlement

o N/A.

. Its location in Zone C is necessary to contribute to key employment objectives supported by the local authority, and other key partners to sustain an existing settlement or region;

o The development is a Nationally Significant Infrastructure Project improving electricity capacity and connection within Southern Wales, and as such would satisfy point 2.

9.1.2 And

. It concurs with the aims of PPW and meets the of previously developed land

o Due to the nature of the development (x1 wooden pole), this point is not applicable – the loss of undeveloped land would be negligible.

. The potential consequences of a flooding event for the particular type of development have been considered and in terms of the criteria contained in sections 5 and 7 and appendix 1 (TAN15) found to be acceptable.

o The consequences of flooding have been considered in line with the below and are deemed acceptable.

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9.2 Acceptability of Consequence

9.2.1 To satisfy the criteria of the acceptability of flood consequences, the following conditions should be satisfied:

1. Flood defences must be shown buy the developer to be structurally adequate;

N/A - no flood defences in area or required

2. The cost of future maintenance for all new/approved flood mitigation measures, including defences must be accepted by the develop and agreed with NRW;

N/A - no flood mitigation measures required

3. The developer must ensure that future occupiers of development area aware of the flooding risk and consequences;

N/A – there will be no future users of the development

4. Effective flood warnings are provided at the site;

The site is located in an area outlined to receive flood alerts from the EA. The construction team will be signed up to these alerts.

5. Escape/evacuation routes are shown by the developer to be operation under all conditions;

Escape/evacuation routes have been detailed and will be provided to the construction team.

6. Flood emergency plans and procedures produced by the developer must be in place;

Flood emergency plans and procedures will be provided to the construction team.

7. The development is designed by the developer to allow the occupier the

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facility for rapid movement of goods to areas away from the floodwaters;

N/A – there will be no occupier of the site

8. Development is designed to minimise structural damage during a flooding event and is flood proofed to enable it to be returned to its prime use quickly in the aftermath of the flood; and

The development (x1 wooden pole) should not be affected during a flood event and will remain operational

9. No flooding elsewhere.

The development will not increase the risk of flooding elsewhere – no increase in runoff or loss of flood plain storage

9.2.2 It is deemed that the development at this location would be justified with acceptable consequences if flooded during its operational lifetime. As such this section of the development should be deemed acceptable for its location.

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10 Site description – Towy/Gwili floodplain

10.1 Site Description

Location

10.1.1 Site Name: Towy/Gwili Floodplain

10.1.2 Location: located between Carmarthen to the west and Abergwili to the east. Works in question run from the River Towy in the south to the A485 in the north.

10.1.3 Site National Grid Reference: Easting: 243466; Northing 220792

10.1.4 Figure 10.1 shows a site location plan, with further mapping provided in Appendix D.

Figure 10.1: Site location plan

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Proposed Development/Works

10.1.5 The proposals for the location are:

. HDD undergrounding of the River Towy;

. temporary HDD compound located to the north of the Towy;

. temporary HDD compounds associated with HDD crossing of Abergwili Mill Leat and Bwlch Stream;

. temporary HDD compounds associated with HDD crossing of Abergwili Road;

. temporary HDD compounds associated with HDD crossing of the A40;

. temporary HDD compounds associated with HDD crossing of the Nant Crychiau;

. temporary satellite construction compound for all works associated with the HDD and open cut trenching in the area off the A485; and

. open cut trenching area between HDD sections.

Geology

10.1.6 Based on published geological records for the area (British Geological Survey online mapping), the site exhibits the following geology:

10.1.7 Superficial Geology: Alluvium

10.1.8 Base rock Geology: Didymograptus Bifidus Beds/Abergwili Formation (mudstone/Tuff, Felsig).

Hydrology

10.1.9 Description of hydrology: River Towy

. Main River, 30m wide, meandering flowing in westerly direction, associated flood plain.

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. Description of hydrology: River Gwili

. Main River, approximately 15m wide, straight channel, sparse vegetation on banks, flows southerly towards confluence with Towy

. Description of hydrology: Bwlch Stream

. Main River, small watercourse approx 1-2m wide, flows from Bishop’s Pond to Afon Gwili.

. Description of hydrology: Tributary of Bwlch Stream

. Small watercourse, approx <1m wide flows from Abergwili to Bwlch Stream.

. Description of hydrology: Abergwili Mill Leat

. Main River small watercourse approx 1m wide, flows from north of Abergwili Road to confluence with Bwlch Stream, vegetated banks. The Abergwili Mill Leat is approximately 0.8km in length. The watercourse was dry when site visit was undertaken on 19/9/2014 by RSK hydrologist.

. Description of hydrology: Nant Crychiau

. Small, straight watercourse, approx 4-5m wide, tree lined banks, flows south westerly towards Gwili

Hydrogeology

10.1.10 Hydrogeological information was obtained from the Natural Resources Wales online mapping service. These maps indicate that the site is underlain by a Secondary B bedrock aquifer (predominantly lower permeability layers which may store and yield limited amounts of groundwater due to localised features such as

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fissures, thin permeable horizons and weathering). The maps also indicate that the site is underlain by a Secondary A superficial aquifer (permeable layers capable of supporting water supplies at a local rather than strategic scale, and in some cases forming an important source of base flow to rivers).

10.1.11 The sites are not located within a Groundwater Source Protection Zone.

10.2 Sources of flood risk

Criteria

10.2.1 In accordance with the PPW, TAN 15 and advice from Natural Resources Wales, a prediction of the flood sources and levels is required along with the effects of climate change from the present for the design life of the development (in this case assumed to be 60 years).

10.2.2 The flood risk elements that need to be considered for any site are defined in BS 8533 as the “Forms of Flooding” and are listed as:

. Flooding from Rivers (fluvial flood risk);

. Flooding from the Sea (tidal flood risk);

. Flooding from the Land;

. Flooding from Groundwater;

. Flooding from Sewers (sewer and drain exceedance, pumping station failure etc.); and

. Flooding from Reservoirs, Canals and other Artificial Structures.

10.2.3 The following section reviews each of these in respect of the works in the Towy/Gwili floodplain.

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Flooding from rivers (fluvial flood risk)

Main River

Figure 10.2: TAN15 Development Advice Map (accessed April 2015)

10.2.4 Development Advice Map (Figure 10.2) shows that the site lies within Flood Zone C2: without significant flood defence infrastructure (Zones C1 and C2 are based on Environment Agency’s extreme flood outlined >=0.1% (river tidal or coastal)).

10.2.5 The resultant fluvial flood risk is considered to be high.

10.2.6 River levels have been supplied by Natural Resources Wales for a number of nodes within the vicinity of the crossing location (Appendix B). Due to the linear nature of the development several river nodes are relevant to the development. The applicable river nodes for the River Towy and the River Gwili are included in Table 10.1.

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Table 10.1: NRW modelled river levels (mAOD) for the River Towy (nodes AT*) and River Gwili (nodes AG*)

Water Surface Elevation (mAOD) for the Annual Probability of Flooding

Node Grid Ref 50% 20% 10% 4% 2% 1.3% 1% 0.5% 0.2% 0.1%

243580; 7.4 7.7 8.0 8.3 8.6 8.7 8.8 9.2 9.6 9.9 AT2 220173

243385; 7.3 7.7 8.0 8.3 8.6 8.7 8.8 9.1 9.6 9.9 AT3 220155

243268; 7.3 7.7 8.0 8.3 8.6 8.7 8.8 9.1 9.6 9.9 AT4 220311

243195; 7.2 7.6 7.8 8.1 8.4 8.6 8.7 9.0 9.4 9.7 AT5 220451

243145; 7.0 7.4 7.6 8.0 8.2 8.4 8.5 8.8 9.2 9.6 AT6 220502

243114; 7.0 7.4 7.6 7.9 8.2 8.4 8.5 8.8 9.2 9.5 AT7 220522

243199; 7.3 7.7 7.9 8.2 8.5 8.7 8.8 9.1 9.5 9.9 AG31 220539

243267; 7.3 7.7 7.9 8.3 8.5 8.7 8.8 9.1 9.6 9.9 AG30 220658

243364; 7.3 7.7 7.9 8.3 8.5 8.7 8.8 9.1 9.6 9.9 AG29 220822

243361; 7.3 7.7 7.9 8.3 8.5 8.7 8.8 9.1 9.6 9.9 AG28 221022

243356; 7.3 7.7 7.9 8.3 8.5 8.7 8.8 9.1 9.6 9.9 AG27 221043

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Water Surface Elevation (mAOD) for the Annual Probability of Flooding

Node Grid Ref 50% 20% 10% 4% 2% 1.3% 1% 0.5% 0.2% 0.1%

243356; 7.5 7.9 8.2 8.5 8.8 8.9 9.0 9.3 9.7 10.1 AG26 221048

243311; 7.5 7.9 8.2 8.5 8.8 8.9 9.1 9.3 9.8 10.1 AG25 221159

243300; 7.5 7.8 8.1 8.4 8.7 8.8 9.0 9.2 9.7 10.0 AG24 221242

243299; 7.5 7.9 8.1 8.5 8.8 9.0 9.2 9.5 10.1 10.6 AG23 221251

243296; 7.7 8.1 8.3 8.7 9.0 9.2 9.4 9.7 10.3 10.7 AG22 221311

243250; 8.4 8.5 8.5 8.6 9.0 9.2 9.4 9.7 10.3 10.7 AG21 221437

243191; 9.0 9.2 9.2 9.3 9.4 9.4 9.5 9.8 10.3 10.7 AG20 221612

243161; 9.1 9.3 9.4 9.5 9.6 9.6 9.7 9.8 10.3 10.7 AG19 221741

243131; 9.3 9.5 9.7 9.8 10.0 10.0 10.1 10.3 10.4 10.7 AG18 221870

243121; 9.4 9.7 9.8 10.1 10.2 10.2 10.3 10.4 10.5 10.6 AG17 221822

243105; 9.4 9.7 9.8 10.1 10.2 10.3 10.3 10.4 10.5 11.2 AG16 221898

243090; 9.7 10.1 10.4 10.7 11.0 11.2 11.3 11.6 12.0 12.5 AG15 221911

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10.2.7 Table 10.2 outlines the ground levels, closest nodes and predicted flood levels for the different development components/areas.

Table 10.2: Predicted flood levels at works locations

Indicative Depth of Ground 1% Flood Development Closest Flooding of the Grid Ref Levels Levels component/area Node(s) Site during 1% (mAOD) (mAOD) event

. Temporary HDD exit . 243432; Compound for Towy . 5.8 . AT3 . 8.8 . 3.0 220232 Crossing

. Temporary HDD entry Compound for Bwlch. 243355; . 5.5 . AG30. 8.8 . 3.3 Stream and Abergwili 220611 Mill Leat Crossing

. Temporary HDD exit Compound for Bwlch. 243382; . AG30, . 6.0 . 8.8 . 2.8 Stream and Abergwili 220752 AG29 Mill Leat Crossing

. Temporary HDD entry Compound for . 243409; . 6.8 . AG28. 8.8 . 2 Abergwili Road 221018 Crossing

. Temporary HDD exit Compound for . 243404; . AG27, . 6.85 . 8.9 (ave). 2.05 Abergwili Road 221074 AG26 Crossing

. Temporary HDD entry . 243365; . AG24, Compound for A40 . 6.9 . 9.1 (ave). 2.2 221215 AG23 Crossing

. Temporary HDD exit . 243358; Compound for A40 . 7.5 . AG22. 9.4 . 1.9 221296 Crossing

. Temporary HDD entry . 243302; Compound for Nant . 8.3 . AG21. 9.4 . 1.1 221474 Crychiau Crossing

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Indicative Depth of Ground 1% Flood Development Closest Flooding of the Grid Ref Levels Levels component/area Node(s) Site during 1% (mAOD) (mAOD) event

. Temporary HDD exit . 243274; . AG21, Compound for Nant . 8.4 . 9.45 (ave). 1.05 221540 AG20 Crychiau Crossing

. Temporary Open cut trenches and working. n/a . . . . areas

. Temporary Satellite . AG18, . 243327; Compound for HDD . 12.25 AG17,. 10.23 (ave). No flood 221889 and Open Cut works AG16,

Ordinary Watercourse

10.2.8 Due to the scale of the Nant Crychiau and the small catchment size, it is unlikely that the watercourse will flood in isolation. Flood levels for the Nant Crychiau are likely to be driven by the flooding of the River Gwili.

Climate change

10.2.9 Fluvial flooding is likely to increase as a result of climate change. A greater intensity and frequency of precipitation is likely to raise river levels and increase the likelihood of a river overtopping its banks. It is therefore likely that the severity, frequency and depth of flood events experienced at the location would be increased, however due to the temporary nature of the development; no climate change influences would be expected to be experienced.

Flooding from the sea (tidal flood risk)

10.2.10 Tidal levels for Carmarthen Quay have been supplied by Natural Resources Wales (Appendix B).

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Table 10.3: Present day tidal levels for at Carmarthen Quay

Water Surface Elevation (mAOD)

1% Annual Probability of 0.5% Annual Probability of 0.1% Annual Probability of Flooding Flooding Flooding

Level Level Level

6.2 6.3 6.5

10.2.11 While the site may be influenced by tidal levels within Carmarthen Quay, the resultant risk is considered low, with the risk from fluvial flooding significantly greater.

Climate change

10.2.12 Due to the temporary nature of the development; no climate change influences would be anticipated.

Flooding from the land (surface water flood risk)

10.2.13 Intense rainfall can create conditions where the local infiltration and drainage capacity is insufficient to cope with the volume of water and so water flows overland. Surface water flooding can also occur due to a reduction in the capacity of a drainage system due to some form of blockage.

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Figure 10.3: Environment Agency surface water flood risk map (accessed April 2015)

10.2.14 The Environment Agency’s ‘Risk of Flooding from Surface Water’ (Figure 10.3) shows the risk of surface water flooding along the section of the route between the River Towy and the A40 ranges from very low to medium. Generally there are areas at a higher risk of flooding to the north of the A40. The proposed route alignment for the HDD sections and Open Cut Trench sections of the route is generally located in the areas outlined as very low to low risk of surface water flooding.

Climate change

10.2.15 Surface water flooding is likely to increase as a result of climate change in a similar ratio to fluvial flooding. Increased intensity and frequency of precipitation is likely to lead to reduced infiltration and increased overland flow over a long period of time. However due to the temporary nature of the development; no climate change influences would be expected to be experienced.

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Flooding from groundwater

10.2.16 Due to the temporary and short term nature of the works, groundwater flooding potential to the proposals is limited. Therefore groundwater flooding can be considered low.

Climate change

10.2.17 Due to the temporary nature of the development; no climate change influences would be expected to be experienced.

Flooding from sewers

10.2.18 Due to the location of the works, flooding from sewers is not anticipated in this area.

10.3 Flooding from reservoirs

10.3.1 Flood events can occur from a sudden release of large volumes of water from reservoirs, canals and artificial structures.

10.3.2 Figure 10.4 has been reproduced from the Environment Agency’s website and provides a worst case scenario of the maximum extent of flooding that would occur in the event that a reservoir were to fail and release the water it holds.

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Figure 10.4: Environment Agency reservoir flood map (accessed April 2015)

10.3.3 The map indicates a significant section of the site is located in an area at risk of flooding from this source. Llyn Brianne (45km to the north east of the site) at the head of the River Towy is the potential source of this risk. The risk associated with the aforementioned reservoir is yet to be determined by the NRW.

10.3.4 The Environment Agency reservoir flood map shows the largest area that might be flooded if a reservoir were to fail and release the water it holds. Since this is a prediction of a worst-case scenario, it is unlikely that any actual flood would be this large.

10.3.5 Reservoir flooding is also extremely unlikely. There has been no loss of life in the UK from reservoir flooding since 1925. Since then reservoir safety legislation has been introduced to ensure reservoirs are maintained. As such any residual risk is to be considered low.

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Climate Change

10.3.6 Reservoirs can be managed over time, controlling inflow/outflow of water and therefore there is the capacity to control the effects of climate change. Increased rainfall has the potential to increase base flow, but this should be minimal. It is unlikely that there will be a substantial change to the risk of flooding for this site.

10.4 Historic flooding

10.4.1 The area around the Towy/Gwili floodplain is known to have flooded regularly in the past.

10.5 Flood risk resulting from the development

10.5.1 In theory any development can increase flood risk downstream, if it is not designed properly.

10.5.2 Due to the temporary nature of the development; there will be no permanent increase in hardstanding or surface water runoff from the development

10.5.3 Once the works are complete and the areas reinstated, there will be no increase in flood risk resulting from the development.

10.6 Flood risk summary

10.6.1 From the Development Advice Maps and NRW flood maps, the whole area is located within Flood Zone C2 (Zones C1 and C2 are based on Environment Agency’s extreme flood outlined >=0.1% (river tidal or coastal)) and as such is at a high risk of flooding from fluvial and tidal sources.

10.6.2 Flood risk from pluvial sources is also predominantly considered to be very low to medium, with some areas of high risk to the north of the A40 according to the Environment Agency flood maps.

10.6.3 The flood risk to the workforce during the construction period is high and as such mitigation measures to protect the workforce in line with Section 11 should be put

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in place.

10.6.4 Flood risk from other sources (groundwater, sewer and artificial bodies) to the site is also considered to be low or very low.

10.7 Surface water drainage assessment

10.7.1 Due to the nature of the development works, HDD compounds and open cut trench working areas, there will be a negligible increase in impermeable area. In line with mitigation for the works and the compounds outlined within the Construction Environmental Management Plan (Ref. 12) and Environmental Statement (Ref. 5) for the development, the development in the area will only create a minimal increase in surface water runoff.

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11 Flood mitigation measures – Towy/Gwili floodplain

11.1 Overview

11.1.1 This section focuses on the flood risk mitigation measures proposed for the site focused on the key flood risks to the site. Access and egress to and from the site and flood warning and emergency evacuation are also considered.

11.2 Safe access/egress

11.2.1 For works south of Abergwili Road, access to and egress from the working areas for the HDD crossing works and compounds and associated open cut works in this section is from Abergwili Road. An Ordnance Survey spot level on Abergwili Road in the vicinity of the access location shows a level of 7mAOD, with the location still shown within Flood Zone C2 (with river levels approximately 8.8mAOD during a 1% AEP event).

11.2.2 In the unlikely event that personnel were on site at the onset of flooding, egress from the site compound would initially be immediately towards Abergwili Road, then west towards Cnwc Y Gwili (located in Flood Zone A).

11.2.3 Alternatively, for works to the north of the A40, egress from the development site will be immediately to the north, towards the compound area adjacent to the A485.

11.2.4 Given the potentially travel time required to reach higher ground out of the flood zone (potentially up to 1km), it is anticipated that it would be necessary to liaise with the emergency services and the Local Authority’s emergency planning function to agree a safe evacuation procedure.

11.3 On site safety

11.3.1 The main factors reflecting on site safety for the workforce is the velocity and depth of flood waters on site and the presence of personnel on site at the onset of a flooding event. A main safety aspect of flooding is that of the availability of a

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safe means of access/egress from the site.

11.3.2 The main means by which flood risks will be managed is through the Environment Agency’s Flood Warning System. The site is located within the NRW Flood alert areas classified as ‘Rivers in the lower Towy catchment downstream of Llandeilo excluding Llandeilo’, ‘ Carmarthenshire Coast’, and ‘Lower Towy’. Abergwili to the east of the site is located within the ‘Towy at Abergwili’ Flood Warning Area. The NRW charter is to provide a minimum two hours advance warning, which would provide sufficient time for site users to be evacuated to an area of safe refuge.

11.3.3 Flood warnings have no effect on flood levels or flows, but provide individuals with an opportunity to respond in advance of a flood. They also provide the opportunity for devising an appropriate ‘incident’ management strategy. Management procedures are to be developed to assess the risk of flooding following advice either from Natural Resources Wales or the LLFA. This assessment should consider evacuation of the site if a severe flood event is expected.

11.3.4 NRW provides a three day flood risk forecast by County which is updated daily and can be used to check the latest information regarding potential flooding in Carmarthenshire.

11.3.5 Due to the likelihood of flooding and the nature of the Towy/Gwili floodplain, it is considered prudent to consider the implementation of a flood management plan.

11.4 Personal safety

11.4.1 With reference to the DEFRA/Environment Agency publication “Flood Risk Assessment Guidance for New Development – Phase 2” (Ref. 13) the following residual risk due to the anticipated flood depths can be determined. Table 13.1 is reproduced below as Table 11.1.

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Table 11.1: Danger to people for different combinations of depth and velocity

11.4.2 Based on the data provided by Natural Resources Wales, for the 1 in 100 year event, the max flood depth on site would be up to 3m, it is therefore likely that the highest level of danger experienced on site would be ‘danger for all’.

11.4.3 Details of evacuation plans for the works in this area would be developed prior to commencing construction and would detail the procedure to be followed once a flood warning or alert is received, either from NRW or from Dwr Cymru for a reservoir breach. Primary considerations for the evacuation plan include:

. Removal of critical plant and equipment for Flood Zone C - this may be removal from the open cut trench working area or from the HDD compounds, and could include raising critical items above the design flood level to removing them from the floodplain completely to suitable alternative location

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for the duration of the event. At the construction storage the contractor would identify the need (or not) to remove equipment from the working areas based on the flood warnings or alerts received.

11.4.4 Potential safe evacuation routes for the working areas have been detailed below.

11.5 Flood warning and evacuation

11.5.1 The site lies within an area designated to receive Flood Alerts from NRW for Carmarthen Bay and the Lower Towy. Abergwili to the east of the development is also outlined to receive a Flood Warning.

11.5.2 The Development Advice Maps show that the vast majority of linear works are within the floodplain associated with the River Towy/River Gwili and associated smaller tributaries. In order to direct people from the southernmost works location (HDD Compound at the Towy) to an area wholly outside of the floodplain, users would need to travel for approximately 1km along the following route to the north of the site:

. from the compound, follow access track to the north; and

. turn left (west) along Abergwili Road for 300m until you have reached the junction of Abergwili Road and Cnwc Y Gwili (located in Flood Zone A).

11.5.3 The above directions for evacuation are applicable for all works location to the south of the Abergwili Road.

11.5.4 For works between the A40 and Abergwili Road, personnel should follow the access track north to the A40, ascend the embankment, turn left and proceed west to the A40/A485 roundabout (located in Flood Zone A). The raised A40 is located in Flood Zone A.

11.5.5 For works to the north of the A40 but south of the Nant Crychiau, personnel should follow the access track south to the A40, ascend the embankment, turn right and proceed west to the A40/A484 roundabout (located in Flood Zone A). The raised

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A40 is located in Flood Zone A.

11.5.6 For works to the north of the Nant Crychiau, personnel should follow the access track to the north towards the compound area adjacent to the A485. The majority of this compound area is located within Flood Zone A

11.5.7 It is not considered feasible to analyse in detail the predicted flood depths and ground levels along this route. As discussed previously, the flood level data highlights that the site will be impacted by flood waters during the 1 in 100 year climate change flood event and water depths of up to 3m would be anticipated due to the low lying land. The flood waters on site would represent “danger to all” scenario.

11.5.8 As the works are only temporary (undergrounding civils operations being completed within an estimated two months and a further one month for cable installation, i.e. cable pulling through the ducts) with no permanent future users, the default position for the site will be dependent on flood warning and a Flood Risk Management Plan during the construction period.

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12 Planning context

12.1 TAN 15 Justification Test

12.1.1 In line with Section 6, the following criteria should be met to demonstrate that the development is justifiable in C1 or C2:

1. Its location in zone C is necessary to assist, or be part of, a local authority regeneration initiative or a local authority strategy required to sustain an existing settlement;

N/A.

2. Its location in zone 3 is necessary to contribute to key employment objectives supported by the local authority, and other key partners to sustain an existing settlement or region;

The development is a Nationally Significant Infrastructure Project improving electricity capacity and connection within Southern Wales, and as such would satisfy point 2.

12.1.2 And

3. It concurs with the aims of PPW and meets the of previously developed land

Due to the nature of the development, this point is not applicable – the permanent loss of undeveloped land would be negligible.

The consequences of flooding have been considered in line with the below and are deemed acceptable.

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12.2 Acceptability of Consequence

12.2.1 To satisfy the criteria of the acceptability of flood consequences, the following conditions should be satisfied;

1. Flood defences must be shown buy the developer to be structurally adequate;

N/A - no flood defences in area or required (flood defences at Abergwili will not be impacted upon)

2. The cost of future maintenance for all new / approved flood mitigation measures, including defences must be accepted by the develop and agreed with NRW;

N/A - no flood mitigation measures required

3. The developer must ensure that future occupiers of development area aware of the flooding risk and consequences;

N/A – there will be no future users of the development

4. Effective flood warnings are provided at the site;

The site is located in an area outlined to receive flood alerts from the EA. The construction team will be signed up to these alerts.

5. Escape/evacuation routes are shown by the developer to be operation under all conditions;

Escape/evacuation routes have been detailed and will be provided to the construction team.

6. Flood emergency plans and procedures produced by the developer must be in place;

Flood emergency plans and procedures will be provided to the construction team.

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7. The development is designed by the developer to allow the occupier the facility for rapid movement of goods to areas away from the floodwaters;

The access tracks will provide a means to remove any sensitive equipment from the site and away from the floodwaters. Equipment not outlined to be removed during a flood event will be anchored in place

8. Development is designed to minimise structural damage during a flooding event and is flood proofed to enable it to be returned to its prime use quickly in the aftermath of the flood; and

While operations would cease during a flood period, with the removal of equipment from site, the removal of sensitive equipment from site and the nature of the development would mean that the construction of the underground sections of the route could resume once the flood waters had receded.

9. No flooding elsewhere.

The development will not increase the risk of flooding elsewhere – no increase in runoff or loss of flood plain storage

12.3 Other factors

12.3.1 The crossing locations and nature of the crossing works have been designed to minimise the impact on the natural environment and negate any impact on the designations of the Towy.

12.3.2 As agreed following consultation with NRW on 19 September 2014 and subsequent emailed response dated 30 October 2014 (Appendix F), the development should be justifiable as:

. No permanent structures are outlined for the crossing locations in the flood plain;

. During construction all site staff would be made aware of sections of the route

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that are located within a Flood Zone, the risks associated with the area and the evacuation process for Staff and Plant in the event of a flood;

. The Abergwili Flood Warning system, the Carmarthenshire Coast Flood Alert system and the Lower Towy Flood Alert system provided by NRW will be subscribed to;

. There will be no loss of flood plain following the HDD works there will be no permanent structures in the flood zone;

. Flood Defence Consent for the HDD works beneath the Towy will be obtained prior to construction;

. With the use of the HDD technique it is confirmed that there will be no impact upon the River Towy. The cables will be laid at a depth no less than 5m below the bed of the Towy and will emerge no less than 15m from the top of bank. Therefore there will be no requirement for a Water Framework Directive Assessment to be undertaken;

. Flood Defence Consent for the open cut works in Bwlch Stream and Abergwili Mill Leat will be obtained; and

. HDD works on the under the River Towy should be avoided during the main migration period for Shad on the River Towy and salmonids spawning season.

12.3.3 Overall, it is deemed that the development at this location would be justified with acceptable consequences if flooded during its operational lifetime. As such this section of the development should be deemed acceptable for its location.

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13 Site description – River Gwili crossing

13.1 Location

13.1.1 Site Name: River Gwili Crossing

13.1.2 Location: West of the A485 at Pontarsais (between Llanpumsaint in the west and Llanllawddog in the west)

13.1.3 Site National Grid Reference: Easting: 243734; Northing 228681

13.1.4 Figure 13.1 shows a site location plan, with further plans shown in Appendix E.

Figure 13.1: Site location plan

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13.2 Proposed development/works at location

13.2.1 The proposal for the location is the erection of a number of strung Single Intermediate Poles and an H-Pole Angle (poles 137-141 are located within the flood zone). Associated working areas and access routes will be utilised, with the construction process in the area taking a few days. The strung wooden poles will remain in the flood zone following construction.

13.3 Geology

13.3.1 Based on published geological records for the area (British Geological Survey online mapping), the site exhibits the following geology:

. Superficial Geology: Glaciolacustrine Deposits/Alluvium

. Base rock Geology: Glanyrafon Formation.

13.4 Hydrology

13.4.1 Description of hydrology: River Gwili

. Main River, approx 5m wide, meandering, sparse/intermittent vegetation on banks, flows westerly

. Description of hydrology: Nant Corrwg

. Small, watercourse, approx 2m wide, tree lined banks, flows north towards Gwili.

. Description of hydrology: Danfforddgaer Lakes

. Two 1.5 acre fishing lakes to the east of the proposed development (within the order limits).

13.5 Hydrogeology

13.5.1 Hydrogeological information was obtained from the Natural Resource Wales online mapping service. These maps indicate that the site is underlain by a Secondary A

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bedrock aquifer (permeable layers capable of supporting water supplies at a local rather than strategic scale, and in some cases forming an important source of base flow to rivers). The maps also indicate that the site is underlain by a Secondary A superficial aquifer (permeable layers capable of supporting water supplies at a local rather than strategic scale, and in some cases forming an important source of base flow to rivers) and by a Secondary (undifferentiated) aquifer.

13.5.2 The site is not located within a Groundwater Source Protection Zone.

13.6 Sources of flood risk

Criteria

13.6.1 In accordance with the PPW, TAN15 and advice from NRW, a prediction of the flood sources and levels is required along with the effects of climate change from the present for the design life of the development (in this case assumed to be 60 years).

13.6.2 The flood risk elements that need to be considered for any site are defined in BS 8533 as the “Forms of Flooding” and are listed as:

. Flooding from Rivers (fluvial flood risk);

. Flooding from the Sea (tidal flood risk);

. Flooding from the Land;

. Flooding from Groundwater;

. Flooding from Sewers (sewer and drain exceedance, pumping station failure etc); and

. Flooding from Reservoirs, Canals and other Artificial Structures.

13.6.3 The following section reviews each of these in respect of the subject site.

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Main River

Figure 13.2: TAN15 Development Advice Map (accessed April 2015)

13.6.4 Development Advice Map (Figure 13.2) shows that the site lies within Flood Zone C2: without significant flood defence infrastructure (Zones C1 and C2 are based on Environment Agency’s extreme flood outlined >=0.1% (river tidal or coastal)).

13.6.5 The resultant fluvial flood risk is considered to be high.

13.6.6 River levels have been supplied by Natural Resources Wales for a number of nodes within the vicinity of the crossing location (Appendix B). The closest river nodes to the site area, AG7, AG6 and AG5 are in close proximity to pole locations. The river levels for key flood events are given in Table 7.1. These levels take into account the fluvial flows of the River Gwili.

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Table 13.1: NRW modelled river levels (mAOD) for the River Gwili

Water Surface Elevation (mAOD) for the Annual Probability of Flooding

Node Grid Ref 50% 20% 10% 4% 2% 1.3% 1% 0.5% 0.2% 0.1%

243731; 92.2 92.3 92.4 92.5 92.6 92.6 92.7 92.7 92.9 93.0 AG7 228722

243867; 93.1 93.2 93.2 93.2 93.3 93.3 93.3 93.3 93.4 93.4 AG6 228812

244023; 94.1 94.2 94.3 94.4 94.4 94.5 94.5 94.5 94.6 94.7 AG5 228771

13.6.7 For a 1 in 100 (1%) year annual probability of flooding the maximum predicted water level is 94.5m AOD.

Climate change

13.6.8 The works at this location are only temporary and short term, with construction envisaged for 2016. As such, climate change will not be an influence during the construction of the poles, and due to the nature of the development, will not impact on the structure.

Flooding from the sea (tidal flood risk)

13.6.9 The site is not considered to be at risk from tidal flooding due to its elevation.

13.6.10 The resultant tidal flood risk is considered to be low.

Flooding from the land (surface water flood risk)

13.6.11 Intense rainfall can create conditions where the local infiltration and drainage capacity is insufficient to cope with the volume of water and so water flows overland. Surface water flooding can also occur due to a reduction in the capacity of a drainage system due to some form of blockage.

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13.6.12 The Environment Agency’s online map ‘Risk of Flooding from Surface Water’ (Figure 13.3) indicates that the route in this section is at a low to high risk from this source of flooding due to the floodplain nature of the area.

Figure 13.3: Environment Agency surface water flood map (accessed April 2015)

13.6.13 The risk of surface water flooding at the site is considered to be low to high and mitigation measures will be implemented to protect the workforce during the erection of Poles 136 to 141.

Climate change

13.6.14 Surface water flooding is likely to increase as a result of climate change in a similar ratio to fluvial flooding. Increased intensity and frequency of precipitation is likely to lead to reduced infiltration and increased overland flow. Due to the nature of the development and the short time frame for development, climate change will not result in an increase in surface water flood risk.

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Flooding from groundwater

13.6.15 Groundwater flooding occurs when the water held underground rises to a level where it breaks the surface in areas away from usual channels and drainage pathways. Groundwater flooding typically occurs following long periods of sustained intense rainfall and is typically associated with low-lying areas underlain by permeable aquifers.

13.6.16 Due to the small scale of the completed development (x5 wooden pole) and short duration of the construction, flooding from groundwater is not considered an issue and the risk can be quantified as low.

Climate change

13.6.17 Climate change will not result in a change in groundwater flood risk to the site.

Flooding from sewers

13.6.18 Due to the nature of the development and works, and the Greenfield location, flooding from sewers is assessed as being low.

Climate change

13.6.19 Climate change will not result in a change in sewer flood risk to the site.

Flooding from reservoirs

13.6.20 Flood events can occur from a sudden release of large volumes of water from reservoirs, canals and artificial structures.

13.6.21 According to the Environment Agency reservoir flood maps, the site is not at risk of reservoir flooding.

13.6.22 The resultant flood risk is considered low.

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Climate Change

13.6.23 Climate change will not result in a change in reservoir flood risk to the site.

13.7 Historic flooding

13.7.1 Due to the flood plain nature of the site, flooding to the proposed development area will have occurred in the past.

13.8 Flood risk resulting from the development

13.8.1 In theory any development can increase flood risk downstream, if it is not designed properly.

13.8.2 Due to the nature of the development (x5 wooden poles), there will be a negligible increase in impermeable area, with no attributable increase in surface water runoff.

13.8.3 There will be no increase in flood risk resulting from the development.

13.9 Flood risk summary

13.9.1 From the Development Advice Maps, the whole site is located within Flood Zone C2 (Zones C1 and C2 are based on Environment Agency’s extreme flood outlined >=0.1% (river tidal or coastal)) and as such is at a high risk of flooding from fluvial sources.

13.9.2 Flood risk from pluvial sources is also considered to be high according to the Environment Agency flood maps.

13.9.3 The flood risk to the workforce during the construction period is high and as such mitigation measures to protect the workforce in line with Section 14 should be put in place.

13.9.4 Flood risk from other sources (tidal, groundwater, sewer and artificial bodies) to the site is also considered to be low or very low.

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13.10 Surface water drainage assessment

13.10.1 Due to the nature of the development (x5 wooden poles), there will be a negligible increase in impermeable area, with no attributable increase in surface water runoff.

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14 Flood mitigation measures – River Gwili

14.1 Overview

14.1.1 This section focuses on the flood risk mitigation measures proposed for the site focused on the key flood risks to the site. Access and egress to and from the site and flood warning and emergency evacuation are also considered. Should the site be flooded when erection of the pole is due, the works should be delayed until flood waters have receded.

14.2 Safe access/egress

14.2.1 For works at Pole 137 and Pole 138 south of the River Gwili, access to and egress from the working area is along the access road from the west, through Glancorrwg. The access track is located within Flood Zone A.

14.2.2 In the unlikely event that personnel were on site at the onset of flooding, egress from the site compound would initially be immediately west towards the access road (located in Flood Zone A).

14.2.3 For works at pole 139, access to and egress from the working area is along the access road from the west, through Glancorrwg. The access track is located within Flood Zone A 150m to the south west of the pole location.

14.2.4 In the unlikely event that personnel were on site at the onset of flooding, egress from the site compound would initially be immediately south west along the access road towards the area of Flood Zone A.

14.2.5 For works at pole 140, access to and egress from the working area is along the access road from the east, off the A485. The access track is located within Flood Zone A.

14.2.6 In the unlikely event that personnel were on site at the onset of flooding, egress from the site compound would initially be immediately east along the access road

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(located in Flood Zone A).

14.2.7 For works at pole 141, access to and egress from the working area is along the access road from the east, off the A485. The first 200m of access track are located within Flood Zone C2; the remainder of the access track to the A485 is located within Flood Zone A.

14.2.8 In the unlikely event that personnel were on site at the onset of flooding, egress from the site compound would initially be immediately north towards Pole 142 (located in Flood Zone A). The land adjacent to Pole 141 to the north is located in Flood Zone A.

14.3 On site safety

14.3.1 The main factors reflecting on site safety for the workforce is the velocity and depth of flood waters on site and the presence of personnel on site at the onset of a flooding event. A main safety aspect of flooding is that of the availability of a safe means of access/egress from the site.

14.3.2 The main means by which flood risks will be managed is through the Environment Agency’s Flood Warning System. The site is located within the NRW Flood alert area classified as ‘Rivers in the lower Towy catchment downstream of Llandeilo excluding Llandeilo’. The NRW charter is to provide a minimum two hours advance warning, which would provide sufficient time for site users to be evacuated to an area of safe refuge. There will be no future users of the site.

14.3.3 Flood warnings have no effect on flood levels or flows, but provide individuals with an opportunity to respond in advance of a flood. They also provide the opportunity for devising an appropriate ‘incident’ management strategy. Management procedures are to be developed to assess the risk of flooding following advice either from Natural Resources Wales or the LLFA. This assessment should consider evacuation of the site if a severe flood event is expected.

14.3.4 Flood warnings should be incorporated into a ‘Flood Risk Management’ strategy

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for the whole site. Site staff and management should be made aware of the availability of these and be registered with the SMS text warning service.

14.4 Personal safety

14.4.1 If there are any instances of workers being on site, a Flood Evacuation Plan should be provided, or included in operational management plans, to provide guidance to operators and visitors in the event of a flood event. The Flood Evacuation Plan will include the following:

. how flood warning will be disseminated;

. priorities for protection of critical infrastructure;

. availability of staff and time taken to respond to a flood warning;

. provision and maintenance of a refuge area for staff;

. the time needed to evacuate the site;

. provision of safe access to and from the development; and

. expected time taken to re-establish normal operation following a flood event.

14.5 Flood Evacuation plan

14.5.1 Details of evacuation plans for the works in this area would be developed prior to commencing construction and would detail the procedure to be followed once a flood warning or alert is received from NRW. Primary considerations for the evacuation plan include:

. evacuation of personnel for the working areas at risk of flooding – this is the primary safety consideration, and is the highest priority in the unlikely event that there is insufficient time to undertake the following activities; and

. making the site safe prior to evacuation – this would include appropriate storage of equipment and materials, securing items within the site compounds

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to prevent them being mobilised in flood water.

14.5.2 Potential safe evacuation routes for the working areas have been detailed below.

14.6 Flood warning and evacuation

14.6.1 The site lies within an area designated to receive Flood Alerts from the Environment Agency for Rivers in the lower Towy catchment downstream of Llandeilo excluding Llandeilo.

14.6.2 Areas of Flood Zone A are located within 150m of all pole erection locations in very close proximity to the south of the working area. Emergency evacuation of the working area for Poles 137 and 138 should be directly to the fields to the west (Flood Zone A), from Pole 139 should be 150m to the east (Flood Zone A), from Pole 140 should be 50m to the south east (Flood Zone A) and from Pole 141 should be immediately to the north (Flood Zone A).

14.6.3 As the works are only temporary and short term, with no permanent future users, the default position for the site will be dependent on flood warning and safe egress/evacuation to the south in the event of a flood.

14.6.4 Works will not be undertaken during a flood event and no personnel should go on site until flood waters have receded.

14.7 Flood resistance and resilience measures

14.7.1 No flood resilient/resistance measures are proposed for this development (x5 wooden poles).

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15 Planning context

15.1 TAN 15 Justification Test

15.1.1 In line with Section 6, the following criteria should be met to demonstrate that the development is justifiable in C1 or C2:

1. Its location in zone C is necessary to assist, or be part of, a local authority regeneration initiative or a local authority strategy required to sustain an existing settlement;

N/A.

2. Its location in zone C is necessary to contribute to key employment objectives supported by the local authority, and other key partners to sustain an existing settlement or region;

The development is a Nationally Significant Infrastructure Project improving electricity capacity and connection within Southern Wales, and as such would satisfy point 2.

15.1.2 And

3. It concurs with the aims of PPW and meets the of previously developed land; and

Due to the nature of the development (x5 wooden pole), this point is not applicable – the loss of undeveloped land would be negligible.

The consequences of flooding have been considered in line with the below and are deemed acceptable.

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15.2 Acceptability of Consequence

15.2.1 To satisfy the criteria of the acceptability of flood consequences, the following conditions should be satisfied;

1. Flood defences must be shown buy the developer to be structurally adequate;

N/A - no flood defences in area or required

2. The cost of future maintenance for all new / approved flood mitigation measures, including defences must be accepted by the develop and agreed with NRW;

N/A - no flood mitigation measures required

3. The developer must ensure that future occupiers of development area aware of the flooding risk and consequences;

N/A – there will be no future users of the development

4. Effective flood warnings are provided at the site;

The site is located in an area outlined to receive flood alerts from the EA. The construction team will be signed up to these alerts.

5. Escape/evacuation routes are shown by the developer to be operation under all conditions;

Escape/evacuation routes have been detailed and will be provided to the construction team.

6. Flood emergency plans and procedures produced by the developer must be in place;

Flood emergency plans and procedures will be provided to the construction team.

7. The development is designed by the developer to allow the occupier the

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facility for rapid movement of goods to areas away from the floodwaters;

N/A – there will be no occupier of the site

8. Development is designed to minimise structural damage during a flooding event and is flood proofed to enable it to be returned to its prime use quickly in the aftermath of the flood; and

The development (x5 wooden poles) should not be affected during a flood event and will remain operational

9. No flooding elsewhere.

The development will not increase the risk of flooding elsewhere – no increase in runoff or loss of flood plain storage

15.2.2 It is deemed that the development at this location would be justified with acceptable consequences if flooded during its operational lifetime. As such this section of the development should be deemed acceptable for its location.

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16 Conclusions and recommendations

16.1.1 This FCA complies with the PPW and its Technical Guidance (TAN15) and demonstrates that flood risk from all sources has been considered in the proposed development. It is also consistent with the Local Planning Authority requirements with regard to flood risk.

16.1.2 The proposed locations for development at the highlighted locations lie within areas shown on the Development Advice Maps as Flood Zone C2 (Zones C1 and C2 are based on Environment Agency’s extreme flood outlined >=0.1% (river tidal or coastal)).

16.1.3 TAN15 sets out the Justification Test, which states that a development has to be justifiable to be developed within Flood Zone C1 or C2. This flood consequence assessment demonstrates that the requirements of the Justification Test have been met have been met for all three locations (Flood Zone C2).

16.1.4 The proposed development works are temporary, with no permanent structures left in the flood zone that would alter the existing impermeable area on site.

16.1.5 This flood consequence assessment has concluded that:

. the assessed areas of the development are located within Flood Zone C2, and as such is at a high risk of flooding from fluvial sources;

. the works in the Towy/Gwili floodplain at Carmarthen could be at risk of tidally influenced flooding;

. due to the linear nature of the works flood risk from surface water ranges from very low to high at the crossing locations;

. flood risk from other sources – groundwater, sewers, reservoirs and artificial sources – is demonstrated to be low;

. the development (both during and post construction) will have minimal to no

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impact on other forms of flooding;

. there will be a negligible increase in surface water runoff during the construction period at the Towy/Gwili floodplain works; and

. the FCA has demonstrated that the proposed developments in the locations assessed are justifiable and have acceptable consequences of flooding in line with TAN15.

16.1.6 Overall, taking into account the above points, the developments at the locations outlined should not be precluded on flood risk grounds.

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17 References

1. Welsh Assembly Government, Planning Policy Wales, Nov 2012.

2. Welsh Assembly Government, Planning Policy Wales, Technical Advice Note 15: Development and Flood Risk, July 2004

3. DEFRA (2004), ‘Interim Code of Practice for Sustainable Drainage Systems’ National SUDS Working Group, July 2004.

4. BSI (2011), ‘BS 8533-2011 Assessing and managing flood risk in development Code of practice’.

5. RSK, Brechfa Forest Connection Environmental Impact Assessment- 110516, 2015

6. Flood and Water Management Act, 2010.

7. Water Resources Act, 1991.

8. EU Water Framework Directive, 2000.

9. Carmarthenshire County Council, Carmarthenshire Unitary Development Plan, 2006.

10. Carmarthenshire County Council, Carmarthenshire Local Development Plan, 2014.

11. Carmarthenshire County Council, Carmarthenshire Strategic Flood Consequences Assessment, 2011

12. RSK, Brechfa Forest Connection- Construction Environmental Management Plan, 2015

13. DEFRA/Environment Agency Flood and Coastal Defence R&D Programme, Flood Risk Assessment Guidance for New Development- Phase 2, R&D Technical Report FD2320/TR2, Oct 2005

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Appendix A – Service constraints

RSK Group service constraints

1. This report and the Drainage design carried out in connection with the report (together the "Services") were compiled and carried out by RSK LDE Ltd (RSK) for WPD (the "client") in accordance with the terms of a contract between RSK and the "client" dated 2015. The Services were performed by RSK with the skill and care ordinarily exercised by a reasonable Civil Engineer at the time the Services were performed. Further, and in particular, the Services were performed by RSK taking into account the limits of the scope of works required by the client, the time scale involved and the resources, including financial and manpower resources, agreed between RSK and the client. 2. Other than that expressly contained in paragraph 1 above, RSK provides no other representation or warranty whether express or implied, in relation to the Services. 3. Unless otherwise agreed the Services were performed by RSK exclusively for the purposes of the client. RSK is not aware of any interest of or reliance by any party other than the client in or on the Services. Unless expressly provided in writing, RSK does not authorise, consent or condone any party other than the client relying upon the Services. Should this report or any part of this report, or otherwise details of the Services or any part of the Services be made known to any such party, and such party relies thereon that party does so wholly at its own and sole risk and RSK disclaims any liability to such parties. Any such party would be well advised to seek independent advice from a competent environmental consultant and/or lawyer. 4. It is RSK’s understanding that this report is to be used for the purpose described in the introduction to the report. That purpose was a significant factor in determining the scope and level of the Services. Should the purpose for which the report is used, or the proposed use of the site change, this report may no longer be valid and any further use of or reliance upon the report in those circumstances by the client without RSK's review and advice shall be at the client's sole and own risk. Should RSK be requested to review the report after the date hereof, RSK shall be entitled to additional payment at the then existing rates or such other terms as agreed between RSK and the client. 5. The passage of time may result in changes in site conditions, regulatory or other legal provisions, technology or economic conditions which could render the report inaccurate or unreliable. The information and conclusions contained in this report should not be relied upon in the future without the written advice of RSK. In the absence of such written advice of RSK, reliance on the report in the future shall be at the client's own and sole risk. Should RSK be requested to review the report in the future, RSK shall be entitled to additional payment at the then existing rate or such other terms as may be agreed between RSK and the client. 6. The observations and conclusions described in this report are based solely upon the Services, which were provided pursuant to the agreement between the client and RSK. RSK has not performed any observations, investigations, studies or testing not specifically set out or required by the contract between the client and RSK. RSK is not liable for the existence of any condition, the discovery of which would require performance of services not otherwise contained in the Services. For the avoidance of doubt, unless otherwise expressly referred to in the introduction to this report, RSK did not seek to evaluate the presence on or off the site of asbestos, electromagnetic fields, lead paint, heavy metals, radon gas or other radioactive or hazardous materials. 7. The Services are based upon RSK's

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observations of existing physical conditions at the site gained from a walk-over survey of the site together with RSK's interpretation of information including documentation, obtained from third parties and from the client on the history and usage of the site. The Services are also based on information and/or analysis provided by independent testing and information services or laboratories upon which RSK was reasonably entitled to rely. The Services clearly are limited by the accuracy of the information, including documentation, reviewed by RSK and the observations possible at the time of the walk-over survey. Further RSK was not authorised and did not attempt to independently verify the accuracy or completeness of information, documentation or materials received from the client or third parties, including laboratories and information services, during the performance of the Services. RSK is not liable for any inaccurate information or conclusions, the discovery of which inaccuracies required the doing of any act including the gathering of any information which was not reasonably available to RSK and including the doing of any independent investigation of the information provided to RSK save as otherwise provided in the terms of the contract between the client and RSK. 8. The phase II or intrusive environmental site investigation aspects of the Services is a limited sampling of the site at pre-determined borehole and soil vapour locations based on the operational configuration of the site. The conclusions given in this report are based on information gathered at the specific test locations and can only be extrapolated to an undefined limited area around those locations. The extent of the limited area depends on the soil and groundwater conditions, together with the position of any current structures and underground facilities and natural and other activities on site. In addition chemical analysis was carried out for a limited number of parameters [as stipulated in the contract between the client and RSK] [based on an understanding of the available operational and historical information,] and it should not be inferred that other chemical species are not present. 9. Any site drawing(s) provided in this report is (are) not meant to be an accurate base plan, but is (are) used to present the general relative locations of features on, and surrounding, the site.

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Appendix B – Natural Resources Wales Flood Levels

DATA REQUEST RESPONSE FORM

Please note.

The flood map for this location may also represent flood flow routing which may give different levels at specific locations of the flood plain to that supplied in this data response. The flood levels are our current best estimate based upon current information available to Natural Resources Wales and will periodically be reviewed and may change. Unless otherwise stated climate change has not been considered.

This information is provided under the Freedom of Information Act 2000/Civil Contingencies Act 2004/Environmental Information Regulations 2004 and we cannot guarantee the suitability of the data for your intended use. This data request must be read in conjunction with the Data Agreement Licence/Standard Notice supplied by Natural Resources Wales.

These flows were based upon information available to Natural Resources Wales at time of modelling, since that time additional information may have become available and/or different methods of calculation flood flows maybe in place. Hence these flows should not be used without verification that they are still valid.

The levels provided are NOT design flood levels hence cannot be used for planning submissions.

As stated above, the flood levels provided are not ‘design flood levels’ hence cannot be used for planning submissions. The information provided is from Natural Resources Wales in- house hydraulic modelling designed to improve the Flood Map and our understanding of overall flood risk for a community. Flood levels provided are based on information available to Natural Resources Wales at the time of modelling which would included topographical and river flow information. This information would require verification as being current and valid at the time of the request as any change might result in changes to the flood levels. Natural Resources Wales hydraulic modelling does not include blockage of in-river structures, possible breach of defence structures and may not include climate change that are considered as part of the Flood Consequences Assessment (FCA) during the planning process.

Additional guidance for preparing a FCA can be found within Appendix A of Technical Advice Note 15 (TAN15). This is the Welsh Government's document and can be found: http://wales.gov.uk/topics/planning/policy/tans/tan15/?skip=1&lang=en

Page 1 Water Surface Elevation (m AOD)* River Node Easting Northing for the Annual Probability of Flooding 50% 20% 10% 4% 2% 1.3% 1% 0.5% 0.2% 0.1% AG1 244383.7 228717.2 95.8 95.9 96.0 96.0 96.1 96.1 96.1 96.2 96.2 96.3 AG2 244319.9 228744.5 95.5 95.6 95.6 95.6 95.7 95.7 95.7 95.8 95.8 95.9 AG3 244263.6 228744.6 95.1 95.3 95.4 95.4 95.4 95.4 95.5 95.5 95.5 95.6 AG4 244196.9 228741.2 94.8 94.9 95.0 95.1 95.1 95.2 95.2 95.2 95.3 95.4 AG5 244023.7 228771.0 94.1 94.2 94.3 94.4 94.4 94.5 94.5 94.5 94.6 94.7 AG6 243867.6 228812.0 93.1 93.2 93.2 93.2 93.3 93.3 93.3 93.3 93.4 93.4 AG7 243731.3 228722.8 92.2 92.3 92.4 92.5 92.6 92.6 92.7 92.7 92.9 93.0 AG8 243617.3 228795.7 91.5 91.6 91.7 91.8 91.8 91.9 91.9 92.0 92.0 92.1 AG9 243563.4 228852.6 91.0 91.2 91.2 91.3 91.4 91.4 91.4 91.5 91.6 91.7 AG10 243400.6 228847.8 90.4 90.5 90.5 90.6 90.6 90.6 90.6 90.7 90.7 90.8 AG11 243212.9 228831.7 89.4 89.6 89.6 89.7 89.8 89.8 89.9 89.9 90.0 90.1 AG12 242759.8 222156.3 12.5 12.7 12.8 13.0 13.1 13.2 13.2 13.4 14.0 14.1 AG13 242894.3 222056.3 10.4 10.7 11.0 11.2 11.4 11.6 11.6 11.8 12.0 12.4 AG14 243028.2 221967.8 10.0 10.3 10.6 10.8 11.1 11.2 11.3 11.6 12.0 12.5

Gwili AG15 243090.3 221911.8 9.7 10.1 10.4 10.7 11.0 11.2 11.3 11.6 12.0 12.5 AG16 243105.5 221898.0 9.4 9.7 9.8 10.1 10.2 10.3 10.3 10.4 10.5 11.2 AG17 243121.5 221882.2 9.4 9.7 9.8 10.1 10.2 10.2 10.3 10.4 10.5 10.6 AG18 243131.9 221870.0 9.3 9.5 9.7 9.8 10.0 10.0 10.1 10.3 10.4 10.7 AG19 243161.4 221741.1 9.1 9.3 9.4 9.5 9.6 9.6 9.7 9.8 10.3 10.7 AG20 243191.5 221612.5 9.0 9.2 9.2 9.3 9.4 9.4 9.5 9.8 10.3 10.7 AG21 243250.7 221437.4 8.4 8.5 8.5 8.6 9.0 9.2 9.4 9.7 10.3 10.7 AG22 243296.7 221311.2 7.7 8.1 8.3 8.7 9.0 9.2 9.4 9.7 10.3 10.7 AG23 243299.9 221251.9 7.5 7.9 8.1 8.5 8.8 9.0 9.2 9.5 10.1 10.6 AG24 243300.9 221242.0 7.5 7.8 8.1 8.4 8.7 8.8 9.0 9.2 9.7 10.0 AG25 243311.6 221159.9 7.5 7.9 8.2 8.5 8.8 8.9 9.1 9.3 9.8 10.1 AG26 243356.9 221048.9 7.5 7.9 8.2 8.5 8.8 8.9 9.0 9.3 9.7 10.1 AG27 243356.9 221043.8 7.3 7.7 7.9 8.3 8.5 8.7 8.8 9.1 9.6 9.9 AG28 243361.1 221002.6 7.3 7.7 7.9 8.3 8.5 8.7 8.8 9.1 9.6 9.9 Page 2 Water Surface Elevation (m AOD)* River Node Easting Northing for the Annual Probability of Flooding 50% 20% 10% 4% 2% 1.3% 1% 0.5% 0.2% 0.1%

AG29 243364.1 220822.3 7.3 7.7 7.9 8.3 8.5 8.7 8.8 9.1 9.6 9.9 AG30 243267.1 220658.7 7.3 7.7 7.9 8.3 8.5 8.7 8.8 9.1 9.6 9.9 Gwili AG31 243199.0 220539.5 7.3 7.7 7.9 8.2 8.5 8.7 8.8 9.1 9.5 9.9 AT1 243779.4 220189.0 7.4 7.7 8.0 8.3 8.6 8.7 8.9 9.2 9.6 10.0 AT2 243580.4 220173.7 7.4 7.7 8.0 8.3 8.6 8.7 8.8 9.2 9.6 9.9 AT3 243385.7 220155.8 7.3 7.7 8.0 8.3 8.6 8.7 8.8 9.1 9.6 9.9

AT4 243268.9 220311.7 7.3 7.7 8.0 8.3 8.6 8.7 8.8 9.1 9.6 9.9 AT5 243195.6 220451.8 7.2 7.6 7.8 8.1 8.4 8.6 8.7 9.0 9.4 9.7 Tywi AT6 243145.7 220502.6 7.0 7.4 7.6 8.0 8.2 8.4 8.5 8.8 9.2 9.6 AT7 243114.9 220522.0 7.0 7.4 7.6 7.9 8.2 8.4 8.5 8.8 9.2 9.5 AT8 242949.4 220633.4 7.0 7.4 7.7 8.0 8.3 8.4 8.6 8.9 9.3 9.7 AT9 242763.2 220703.5 7.0 7.4 7.6 8.0 8.2 8.4 8.5 8.8 9.3 9.6 NP1 244335.1 218592.6 26.9 27.0 27.2 27.2 27.3 27.3 27.4 27.4 27.5 27.5 NP2 244285.7 218540.5 26.9 27.0 27.1 27.2 27.3 27.3 27.3 27.4 27.5 27.5

NP3 244168.6 218499.6 26.8 26.9 27.1 27.2 27.2 27.3 27.3 27.3 27.4 27.5

NP4 244126.8 218466.0 26.3 26.5 26.6 26.8 26.9 27.0 27.0 27.1 27.1 27.2

NP5 244028.8 218430.3 25.5 25.7 25.8 25.9 25.9 26.0 26.0 26.1 26.2 26.2 Pibwr NP6 243888.2 218354.6 24.8 24.9 25.1 25.3 25.5 25.5 25.6 25.7 25.8 25.9 NP7 243734.5 218370.4 24.9 25.0 25.2 25.3 25.5 25.5 25.6 25.7 25.8 25.9 NP8 243558.9 218372.9 24.3 24.5 24.6 24.7 24.8 24.9 24.9 25.0 25.2 25.4

* Rounded up to 1 decimal place. Please note these levels/flows maybe subject to change as new information is received and the model updated.

Page 3 The following table below provides tide levels at the requested location.

Tide Levels @ Carmarthen Quay

These estimated levels are based upon analysis of local records Please note the appropriate allowances for sea level rise due to Climate Change should be considered. This information provided is the best available to date to Natural Resources Wales

Advice on the use of these values can be given if needed by the Natural Resources Wales Flood Risk Analysis Team.

Water Surface Elevation (m AOD)** 1% Annual Probability of 0.5% Annual Probability of 0.1% Annual Probability of Flooding * Flooding * Flooding * Level Level Level 6.2 6.3 6.5

* Rounded up to 1 decimal place. Please note these levels/flows maybe subject to change as new information is received and the model updated.

** It is important to recognise that the tide levels provided in the above relate to what is known as 'Still Water Level'. Spray and wave overtopping may still affect locations where ground levels are above 'still water levels'.

Page 4 Page 5 Page 6 Page 7 Page 8

Flood Consequence Assessment – Volume 5.2

APPENDIX C – NANT PIBWR CROSSING PLANS

76 243000 244000 245000

Legend: # Proposed 4-Pole Terminal Position 84 Proposed H-Pole Terminal Position # Proposed H-Pole Angle Position Proposed H-Pole Intermediate Position Proposed Single Pole Angle/ 83 Section Position Proposed Single Intermediate Pole Position Proposed Overhead Line 82 Proposed Underground Cable HDD Open Cut HDD Areas

81 Current Limit of Deviation

250m Study Area

Indicative Access Route 80 # Detailed River Network v3 !!!!!!!!!! Defences

0 Flood Storage Areas

0 79 0

9 Areas Benefiting from Flood Defences 1 2 Flood Zone 3

78 Flood Zone 2

74 Notes: Proposed Overhead Alignment provided by LSTC Gas pipeline data provided by WPD Landfill and SSSI locations provided by Natural Resources Wales Flood Map and Detailed River Network data provided by Natural Resources 73 Wales Borehole data provided by British Geological Survey

Some of the information within the Flood Map is based d 72 in part on digital spatial data licensed from the Centre x m for Ecology and Hydrology © NERC. . 0 0 0

Coordinate System: British National Grid 0 1 71 Projection: Transverse Mercator 3 A

Datum: OSGB 1936 s

Units: Metre e n o

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Source: Global Land Cover Facility, www.landcover.org. 1 - 1 1 - 4

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66 1 0 \ t s e r o F

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00 13/11/2014 First Draft JG KJ VR h c e r B

Rev Date Description Drn Chk App -

64 1 5 0

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63 t u o S

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REV 00 o D © Crown copyright and database rights 2014 Ordnance Survey 0100031673 Contains British Geological Survey materials © NERC 2014 Contains Natural Resources Wales information © Natural Resources Wales and database right. Ordnance Survey license number 100019741. Contains Ordnance Survey data © Crown copyright and database right 2014

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Flood Consequence Assessment – Volume 5.2

Appendix D - Towy/Gwili floodplain crossing plans

77 FINAL ISSUE WESTERN POWER DISTRIBUTION (BRECHFA FOREST CONNECTION) ORDER LIMITS AND LANDUSE PLANS SECTION B SHEET 1 OF 2 WPD Approved 31 March 2015

A 6 SITE MAP 8 485 CR 14

Y 5 CH Clos

IAU Ty-ni Rosegarth Glas Glyn Aur DOLGWILI k ROAD Trac 13.3m Noddfa

CAST Carrog GYN ROAD Y Felin 2

ELL Pen-y-banc Depot DW 11.6m

15.7m Afon 1 CR

Dismantled

Gwili 9 Rail Pavilion 2

A w 8 485 ay 19

4 Bishops Spring Abergwili El Sub Residence Mill Ta n e rd y

1 A40( Sta T) 9 4 Sports 7.8m 2 Ta nk s T) 5 Field Llif yr A40( Car Park Afon BRIALLU Canolfan Dyffryn FB Gwenog Wellfield 1 Nant Ford l lO 1 y Felin 6 1 6 23 5 l l2 Issues LON G 2 4 OG C Drain L Llangunnor Y CH A B 2 VR KEY Llwynhelug SECTION BOUNDARY Abergwili A 40 Bytheway ORDER LIMITS (RED LINE The BOUNDARY) Vicarage Path PERMANENT EASEMENT 12 FB CLASS OF RIGHT 1 Castle 3 P n Manor Crossi igyn PERMANENT ACCESS CLASS ng OF RIGHT Drai Gwili Ffynnon 6 22 Dyssul 13 TEMPORARY FOR Car Park CONSTRUCTION CLASS OF Starling E RIGHT Abergwili VC Hol Pond lymed A 40 4 e Llehyfryd 7 Co TEMPORARY FOR MITIGATION Dragons ttage I 9 4 3a CLOS CLASS OF RIGHT Lair K Slurry a2 1a R 3 2 Llys Gwyn INFRASTRUCTURE LAYERS Lwy Hedd-fan GWIL 2 Ebeneser Path PA M CNWC Y Bed 14 aes FOR INFORMATION

n Pat awelon te 98 94 Peny-y-bont 1 Hafon OVERHEAD LINE CENTRELINE

2 g Def h

Glasdir 1 Abergwili " 86 Posts 56a NEW TERMINAL H POLE 83 Drain MS 53 Meml 44 51 53 12.2m 7.7m 41 ED Bdy Flood Gate LB 40 ! NEW INTERMEDIATE SINGLE Green 2 Bdy 9.8m 1 59 D 3 21 26 9.2m POLE Meadow CR E 7.1m 1 15 PH 32 39 Def BWLCH 33 DYFFRYN TYWI 61 ath LANE ! NEW INTERMEDIATE H POLE 3 P 1 " NEW ANGLE SINGLE 5 n Esgob 4 60 62 Fa g 63 r-Afon ulo " NEW ANGLE H Track -y He

n rnoway Bwlch i 17 # ISMY rm NEW SECTION SINGLE POLE M 23 Fa Gogerdden Sto ll Issues 6 Ha # NEW SECTION H POLE RD Track # EXISTING TOWER EE42 D 10.2m Pond IN Drain Bwlch CHU # LANE SUBSTATION GANTRY Ta nk 12 R CABLE CENTRELINE - OPEN C Path H CUT TRENCH 2 Old 3 CABLE CENTRELINE - Vicarage HORIZONTAL DIRECTIONAL DRILL St David's CABLE - JOINT BAY

ack R r Issues CABLE - HDD WORKING

C T Drain Sinks SITE COMPOUND AFFECTED EXISTING ASSET - CENTRELINE Track ! AFFECTED EXISTING ASSET - POLE POSITION

n fo li A i Gw

, &

Co Consty Const sl A Bdy ED

Shingle

Pond MLW NTL

Notes This drawing is scaled at paper size A1, therefore any Shingle prints taken at smaller sizes will affect accuracy of the measurement units and should not be scaled against.

Ponds

Mud

Pond Drain

Pond Coordinate System: British National Grid Units: Metre Projection: Transverse Mercator Datum: OSGB 1936 Scale Factor: 0.9996 Drai n X Centroid Coordinate: 243460 Pond Y Centroid Coordinate: 220700 F

0 40 80 120 160 200 Mud Pond Metres Church REPRODUCED FROM ORDNANCE SURVEY MAPS, BY PERMISSION OF THE ORDNANCE SURVEY ON Pond BEHALF OF THE CONTROLLER OF HER MAJESTY'S Church Shingl STATIONARY OFFICE. CONTAINS ORDNANCE Llangunnor SURVEY DATA © CROWN COPYRIGHT AND DATABASE RIGHTS [2015] OS 0100042840 e 12.2m Eglwys

Bdy 11.4m Vicarage ED CCLW Mean High Water River Towy (Afon Tywi) EL CAP Bryn-Towy Mean High HEOL APEL Water DEWI / C D 13.8m DEWI ROA FINAL 31/03/2015FINAL SF JC AJH/GG

ISSUEDATE COMMENTS DRAW CHK'D APP'D 18.2m Lodge

1 Wenallt

LB 5 Bwthyn Penrhiw 0 30 Cwm-Tawel 3 B 4 2 Title 33 20.5m 6 2 Pond / 39 7 WESTERN POWER DISTRIBUTION 11 I 36 2 5 EW Pant 31 2 T D D 3 3 (BRECHFA FOREST A OWY EL O 0 2 AP I R P 2 1 C W 29 2 CONNECTION) E ARK 3 OL D E L V H E 19 P I ORDER LIMIT AND LANDUSE PLANS EW 8 CA 1 The 14 22.0m SECTION B

86 5 5 4 1

T Parc-y-groes 0 P O 30 A B 4 WY RK 4 2

LB V 22.9m Kiri IE Star Lodge 46 W Bach Cottage ORIGINATOR DRAWING No. APPLICATION No. GIS 45 57_13571_85 N/A A1 Cottages 85 PROJECT DRAWING No. DRAWING No. SCALE Brynderwen N/A N/A 1:2,500 ISSUE SHEET 1 OF 2 N/A Pond FINAL COPYRIGHT NOT TO BE REPRODUCED WITHOUT THE WRITTEN PERMISSION OF WESTERN POWER DISTRIBUTION FINAL ISSUE WESTERN POWER DISTRIBUTION (BRECHFA FOREST CONNECTION) ORDER LIMITS AND LANDUSE PLANS SECTION B SHEET 2 OF 2 WPD Approved 31 March 2015

Ta nk SITE MAP

Cattle Rhydyrhaw Grid Rhydyrhosyn

CR Mast Well 2

Ta nk 92

485 Awelfryn

Abergwili

Ta n e rd y A40( Rhydyrhaw T)

T) T rack A40(

91 1

Llangunnor B

Allt Llwyn-pi?od KEY 90 SECTION BOUNDARY

485 Lodge A ORDER LIMITS (RED LINE BOUNDARY) PERMANENT EASEMENT CLASS OF RIGHT 67.1m PERMANENT ACCESS CLASS OF RIGHT Spring Glyn View Cottage TEMPORARY FOR CONSTRUCTION CLASS OF CH k 89 RIGHT Swn y (disused) Trac TEMPORARY FOR MITIGATION dial CLASS OF RIGHT Maes Y Llwynpiod INFRASTRUCTURE LAYERS Coed Gat-goch FOR INFORMATION Ta nk 3 Spring OVERHEAD LINE CENTRELINE

2 " NEW TERMINAL H POLE Collects 1 ! NEW INTERMEDIATE SINGLE Greensleeves POLE 88 Spring ! NEW INTERMEDIATE H POLE Trac k " NEW ANGLE SINGLE Uwchgwili " NEW ANGLE H Bwthyn y Garddwr Spring # NEW SECTION SINGLE POLE Spring # NEW SECTION H POLE CB 87 # EXISTING TOWER EE42 # SUBSTATION GANTRY Track CABLE CENTRELINE - OPEN C Spring H CUT TRENCH CABLE CENTRELINE - HORIZONTAL DIRECTIONAL DRILL th a CABLE - JOINT BAY P m) (u CABLE - HDD WORKING Co Const,

Asly Const SITE COMPOUND AFFECTED EXISTING ASSET - CENTRELINE

! AFFECTED EXISTING ASSET - POLE POSITION Rhiwdywyll

Gorwel

Well

64.3m Pond Dr ain Spring Spring

Y Beudy 72.5m Issues

248 Waterfall

Track Notes This drawing is scaled at paper size A1, therefore any Danrhiw prints taken at smaller sizes will affect accuracy of the measurement units and should not be scaled against.

122 26.9m 47.4m

116

Well Ger-y-nant 34.1m BRONWYDD ROAD Frondeg Drain 42.4m

ynber 28.0m Well Coordinate System: British National Grid 116a l lan Dr Units: Metre Path a Projection: Transverse Mercator in Datum: OSGB 1936 114 Issues 1 Scale Factor: 0.9996 05 FB X Centroid Coordinate: 243132 Maesgwili Castell-Pigyn Y Centroid Coordinate: 222493 108 MP 247.75 7 F 8 25.4m 5

6 0 40 80 120 160 200 Path 9 (um) Metres 7 Path 108c (um) Glynteg REPRODUCED FROM ORDNANCE SURVEY MAPS, 9 3 BY PERMISSION OF THE ORDNANCE SURVEY ON 108d Glangwili 79 BEHALF OF THE CONTROLLER OF HER MAJESTY'S 3 26.9m 485 A STATIONARY OFFICE. CONTAINS ORDNANCE 89 Derwydd A 484 SURVEY DATA © CROWN COPYRIGHT AND Deri DATABASE RIGHTS [2015] OS 0100042840 75 Frongelli Cottage 2 Villas Shelter 1 Frongelli Castle LB Pigyn Lodge

63 El Sub Pat 24.7m 106 (um) h Sta 69

59 Issues Bridge FINAL 31/03/2015FINAL SF JC AJH/GG The 13.7m ISSUEDATE COMMENTS DRAW CHK'D APP'D Spreads Cottage

51 LI

9 2 D 2 ism 5 LGWI CAE OAD O 24.0m Issues a R 9 SEIRI n D 0 tled Bryn 9 6 Helyg 13.4m

49 Dol-Gwili t u n ia 47 a Title 1 N ch D ry 8 r C Tawelan a i P n Llys yr WESTERN POWER DISTRIBUTION 2 A N T Spring Afon Rhandir GL FB (BRECHFA FOREST 45 A h S t a Nant Oer m) Tyrnant CONNECTION) L 25.6m P (u Brookview

O 11 11.8m Burrswood ORDER LIMIT AND LANDUSE PLANS

DD 1 4 Golygfa 41a 2 SECTION B Y 8 n Deg Erwlon aiar Talh 1 Y Bedol Aur

1 A 6 8 CR 4 4 8 1

5 Y 5 I C 58 L HIA Clos 35 Glas GWI Rosegarth L D Ty-ni U ORIGINATOR DRAWING No. APPLICATION No. 56 29.7m O A Glyn Aur GIS D O Track R 57_13571_85 N/A 33 13.3m Noddfa A1 50 DRAWING No. CASTE PROJECT DRAWING No. SCALE

PI Carrog RO Y Felin 1:2,500 G N/A N/A 1 AD YN 3 ISSUE LL 11.6m 15 Depot DW SHEET 2 OF 2 N/A FINAL COPYRIGHT NOT TO BE REPRODUCED WITHOUT THE WRITTEN PERMISSION OF WESTERN POWER DISTRIBUTION

Flood Consequence Assessment – Volume 5.2

Appendix E – River Gwili crossing plans

78 243000 244000 245000 149 Legend: # Proposed 4-Pole Terminal Position 148 Proposed H-Pole Terminal Position # Proposed H-Pole Angle Position Proposed H-Pole Intermediate Position Proposed Single Pole Angle/ 147 Section Position Proposed Single Intermediate Pole Position Proposed Overhead Line 146 Proposed Underground Cable HDD Open Cut 145 HDD Areas

Current Limit of Deviation

144 250m Study Area Indicative Access Route

Detailed River Network v3 143 !!!!!!!!!! Defences

Flood Storage Areas

229000 142 Areas Benefiting from Flood Defences

Flood Zone 3 141 Flood Zone 2

140

139

#138

137

Notes: Proposed Overhead Alignment provided by LSTC Gas pipeline data provided by WPD Landfill and SSSI locations provided by Natural Resources Wales 136 Flood Map and Detailed River Network data provided by Natural Resources Wales Borehole data provided by British Geological Survey

Some of the information within the Flood Map is based d 135 in part on digital spatial data licensed from the Centre for Ecology and Hydrology © NERC.

Coordinate System: British National Grid Projection: Transverse Mercator 134 Datum: OSGB 1936 Units: Metre

133 228000

132 Source: Global Land Cover Facility, www.landcover.org.

131

130 00 13/11/2014 First Draft JG KJ VR

129 Rev Date Description Drn Chk App

Brechfa Forest Connection

128

127

TITLE: Figure 13.1: Flood Zones 126 Map 8

125 0 200 400

Metres / SCALE: 1:10,000 @ A3 REV 00 Document Path: P:\EIA\110000 EPD - South Projects\110516 Brechfa- Forest\01 GIS\2014-11-13 Figure 13.1 Flood ZonesA3 10000.mx 227000 © Crown copyright and database rights 2014 Ordnance Survey 0100031673 Contains British Geological Survey materials © NERC 2014 Contains Natural Resources Wales information © Natural Resources Wales and database right. Ordnance Survey license number 100019741. Contains Ordnance Survey data © Crown copyright and database right 2014

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Flood Consequence Assessment – Volume 5.2

Appendix F – Natural Resources Wales correspondence

79 Kristian Jackson

From: Victoria Robinson Sent: 30 October 2014 15:40 To: Colin Whittingham; Kristian Jackson Subject: FW: Brechfa Forest Connection - Flood Risk/Hydrology call follow up

-----Original Message----- From: Watkins, David [ mailto:[email protected] ] Sent: 30 October 2014 11:02 To: Victoria Robinson Cc: [email protected] ; Miles, Bonnie; Williams, Huw Subject: RE: Brechfa Forest Connection - Flood Risk/Hydrology call follow up

Victoria,

Thank you for the email regarding the above matter.

Both Rachel and Tony have confirmed they are happy with the submitted plans and minutes of your meeting.

We have no objection regarding the temporary welfare facilities being located within the flood plain, particularly as the contractor will sign up to receive flood alerts and warnings and a suitable evacuation plan will be put in place as stated in the minutes. It is evident that you and the contractors fully appreciate the implications of locating at this site.

We also confirm that the following flood defence consents will be required for the works shown in the submitted plans:

- Crossings under the River Towy, Abergwilli Mill Leat and Bwlch Stream will all require separate flood defence consents.

- Temporary works required for the open cut works in the Abergwilli Mill Leat and Bwlch stream will also require separate temporary flood defence consents.

- If any part of the cable is laid within 7m from the top of bank of a main river this will also require a flood defence consent.

Regards, Dave

Eich Enw/ David Watkins Teitl swydd/Job title Senior Development Planning Advisor. Cyfoeth Naturiol Cymru / Natural Resources Wales Ffôn/Tel: (01792) 325577 E-bost/E-mail: [email protected] [email protected] Gwefan / Website: www.cyfoethnaturiolcymru.gov.uk / www.naturalresourceswales.gov.uk Ein diben yw sicrhau bod adnoddau naturiol Cymru yn cael eu cynnal, eu gwella a'u defnyddio yn gynaliadwy, yn awr ac yn y dyfodol.

1 Our purpose is to ensure that the natural resources of Wales are sustainably maintained, enhanced and used, now and in the future.

______From: [email protected] [[email protected]] Sent: 24 October 2014 12:27 To: Watkins, David Cc: [email protected] Subject: RE: Brechfa Forest Connection - Flood Risk/Hydrology call follow up

Hi David,

Could you let me know when NRW may be able to respond on this?

Kind regards,

Victoria

From: Victoria Robinson Sent: 20 October 2014 12:40 To: 'Watkins, David'; Miles, Bonnie Cc: Colin Whittingham; 'Kenyon, David'; '[email protected]'; '[email protected]'; '[email protected]'; '[email protected]' Subject: Brechfa Forest Connection - Flood Risk/Hydrology call follow up

David/Bonnie,

Following on from our flood risk/hydrology conference call with your colleagues Rachel Thomas and Tony Brown, please see attached for your review:

· Plans of the infrastructure in relation to flood zones (The Towy underground section and three poles west of Pontarsais)

· Follow up comments to the table distributed prior to the call and discussed during the call.

We would appreciate your response/view on the points discussed and current proposals. In addition, it is likely that there will be a requirement for temporary welfare facilities for the Towy undergrounding section while the drilling is underway, this is likely to be near the drill sites. What would your view be on this if it is within the floodplain?

If you would like to clarify any part of the attached information, please do not hesitate to contact me.

Many thanks

Victoria

Victoria Robinson-Moltke Principal Environmental Consultant EIA, Planning & Design RSK The Old School, Stillhouse Lane, Bedminster, Bristol, BS3 4EB, UK Switchboard: +44 (0)117 947 1006 Fax: +44 (0)117 947 1009 Direct dial: +44 (0)117 300 4287 Mobile: +44 (0)7768 8413 92 email: [email protected]

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