WENTLOOGE COUNCIL

Chairman: Cllr Brian Miles Clerk: Mrs Maria Mulcahy

Peterstone Village Hall Wentlooge CF32TR

Dear Inspector

Wentlooge community wouId like to forward this response to Planning applicatioll DNS/3216558

lIt is disturbing to see how this application has been handled right from the start with . regards to the public consultation. This advertised by a posted notification in no more than 3 locations one of which has no public exposure and only 24 hours prior to the public event taking place. This meant that the attendance was exceptionally low. The press release was put into a local magazine that is distributed to every address iII the area but not until well after the event had taken place. This again was a way not to engage with the local community. From a Community Council point of view as supported by the Local alithority the scale of the consultation was too narrow and did not cover the whole area effected. This has now been followed up with the application being submitted during the COV[D crisis making it difficult to hold any sort of public meetings or to have a meaitingful working group.

We would draw your attention to several issues and anomalies in this application such as surveys not completed on the ground for both ivildlife and construction. These are detailed in the section within this file submission which I will summarise now with more detail is included in the relevant section.

Flooding. Our submission shows clearly that the area proposed for this development is . prone to flood and the details supplied in the applicauon neglect to address tlae ood water that travels down to the Levels but concentrates on the tidalissue which in itself is not like the previous development OIl tile east ofNewport that has been built. It is much closer proximity to the sea and also has the flood effect from rain water flow on the high ground and hills to the north.

Wildlife. The reports submitted only deal with the area of development and not its surroundings. In this section we will show the extent of the wildlife and the negative effects this development will have. And how the living levels projeet has increased the amount of breading and migratory birds in this are amongst other things.

Historical. This is an area of significant historical value with not least the last remain Roman Field structure left ht the UK.

Visual impact. The photographs within the application are very economic with the views and we supply evidence showing this together with live images on how the visual impact really is. There is also an omission of the 180 container units and 3 turbines. Construction. This again is confusing in the application as it does not meet the statements on construction, wildlife and Local Authority support made by the representatives to the small number of public that did manage attend the presentation. There is no reference to the large fencing surrounding the site that is detrimental to wildlife as has been shown in previous applications in this area. The plans fall short of the requirements of buffer zones and hedgerow protection. We also highlight error within the application which identifies that the surveys are flawed, the application is not in relation to the area that it is intended to cover.

Ground effect. We will show how the ground underneath the panels will deteriorate very quickly especially when at the public meeting the representatives confirmed that the sun will only impact the ground under the panels twice peryean We will show the scale of construction rising concrete and hardcore covering the grolind to accommodate the 180 battery units.

Noise. There is no reference the application on the noise impact ofthe turbines or the humming of the transformers on the local area of Peterstone, St Brides and Marshlield together with the effects to wildlife.

. Local imnact. We will show in this section how a development of this nature will affect local tourism, local businesses and bee breeders (honey producers). We will also demonstrate the negative impact this will have on the All Coastal Path,

Living Levels. This area is part ofthe living levels project and as such is part of a multimillion-pound project to protect and enhance this area for the protection of nature and the quality of life to the people who live here. It would raise a large question ifthis investment were ignored.

Danger to aircraft. This section shows the glare that can endanger aircraft and mus be considered as the area in question is a flight path for Bristol Airport, Heliport and low level tourism pleasure flights.

Effects of solar Danels 011 bee and insect life. We detail the effects these panels have on this type ofwildlife.

Area status. A development as Iarge as this wouId seriously effect the make up of the area and threaten the Green Belt and Green Wedge status that now exists. This would . also bring with it an open door for industry that would see the Wentlooge Levels disappear.

Tourism this section looks at the negative effects this would have.

Lithium Battery risk we demonstrate the risks of Ire and flood in this section

Local Authoritv LDP we highlight how this application conflicts with this.

Previous applications this section shows how elements of this development have been refused in other applications.

NRW response to pre-application showing concerns

Amitv report this report carries numerous points on why this site is not suitable.

More details of the points above are in the relevant sections of the submitted le. We take the care of Our environment very seriously especially due to the details below and the area being of Green belt/Green Wedge. We cannot except that this development could even be considered against the detrimental impact to the environment.

We are unsure as to why brownfield sites in the area are not considered. Cardiffs solar farm has taken advantage of the redundant land fill site 3 miles to the west ofthe proposed site. Newport also have a redundant landfill site approximately 5 miles to the east of the proposed site so surely this would be the better option. No issues with wildlife and no trees or hedgerows. Or is the developer purely looking at the cheapest option and discounting the more environmentally friendly option.

The area of Peterstone St Brides is open countryside, a designated Site of Special Scientific Interest (SSSI), a Cadw/ICOMOS UKRegistered Landscape ofOutstanding Historic Interest, an Archaeologically Sensitive Areas adjacent to the new Wales Coastal Path and to the internationally important RAMSAR site of the Severn Estuary.

The Levels are a Special Landscape Area (SLA) is recognised nationally and internationally (NCC LDP Policies SPS and 8).

. Planning Policy Wales (PPW) 10 sets out that "planning authorities must seek to maintain and enhance biodiversity in the exercise of their functions. This means that development should not cause any significant loss of habitats or populations of species, locally or nationally and must provide a net benefitfor biodiversity" (para 6.4.5 refers). This policy and subsequent policies in Chapter 6 ofPPW 10 respond to the Section 6 Duty of the Environment (Wales) Act 2016*.

It is important that biodiversity and ecosystem resilience considerations are considered at an early stage in development plan preparation and when proposing or considering development proposals. Planning authorities should be proacuve and embed appropriate policies into local development pIans to protect against biodiversity loss and secilre enhancement.

The attributes of ecosystem resilience (PPW para 6.4.9 refers) should be used to assess the current resilience of a site, and this must be maintained and enhanced post development. Ifthis cannot be achieved, permission for the development should be refused.

. Yours faithful

Wentlooge Community Council Covering letter

Flooding

Wildlife

D Historical

Visual

Construction

Ground effect . Noise Local impact

living levels

Dangers of glare

Area status

Tourism

Battery risks

PQ Newport LDP

. Previous applications in the area

S 14 RW response

Amity Consultants

Newport City Council Local Biodiversity Action Plan

VW Legacy of old solar panel ( Toxic issue when recycleing) stockpiling Local Authority respose does not support thepresentation to the XYZ public

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