The Mid Wales (Powys) Conjoined Public Inquiry

into 5 Windfarm Applications

and a 132kV Overhead Electric Line Connection

Session 4

Matters in Common/Cumulative Effects

Proofs of Evidence on Transport Matters

made jointly by

Cyngor Cymuned Carreghofa Community Council

(Inquiry Reference OBJ-001)

Cyngor Cymuned Llandysilio Community Council

(Inquiry Reference OBJ-849)

Cyngor Cymuned Llandrinio and Arddleen Community Council

(Inquiry Reference OBJ-157)

page 1 of 27 1 Introduction

1.1 The three Community Councils presenting this evidence, Carreghofa, Llandysilio and Llandrinio & Arddleen, all lie along the A483, the principle trunk road to be used for conveying windfarm traffic, particularly the “abnormal loads” of turbine parts. In order to avoid repetition of evidence to the Inquiry, the Councils have agreed to present their evidence jointly.

1.2 The Councils are deeply concerned with the impact which the transportation of windfarm components, together with additional HGV and other traffic, will have on our local communities. While we have confined our evidence to the 158 turbines that are now the subject of this Inquiry, we are mindful of the fact that a total of over 800 turbines, either granted, applied for or pending, have been proposed for mid-Wales.

1.3 While we are three Welsh Community Councils, we cannot limit our evidence solely to the Welsh part of the A483, from Llanymynech southwards. We need to look at what happens on the English side of the border before the southbound windfarm components reach us.

1.4 The extent of the A483 that will be covered in the evidence is from Oswestry to the north and Welshpool to the south, specifically between the junction with the A5 (Mile End roundabout) and the junction with the A458 (Buttington roundabout) to the south with particular emphasis on the section between Llynclys crossroads and the Four Crosses roundabout.

1.5 Appendix A shows a map of the route from the Mile End roundabout to the Buttington roundabout and Appendices A1 to A8 show photographs of the major junctions along the route.

page 2 of 27 2 The schemes that are the subject of this Inquiry

Electricity Act 1989 (Sections 36, 37, 62(3) & Schedule 8) Town and Country Planning Act 1990 (Section 90)

Application by Vattenfall dated 30 November 2007 for consent to construct and operate a 59.5MW wind turbine generating station in Powys, Mid Wales (“Llanbadarn Fynydd”)

Application by Fferm Wynt Llaithddu Cyf dated 7 May 2008 for consent to construct and operate a 66.7MW wind turbine generating station in Powys, Mid Wales (“Llaithddu”)

Application by Celtpower Limited dated 9 May 2008 for consent to construct and operate a 126MW wind turbine generating station in Powys, Mid Wales (“Llandinam”)

Application by RES UK & Ireland Limited dated 27 March 2009 for consent to construct and operate a 100MW wind turbine generating station in Powys, Mid Wales (“Llanbrynmair”)

Application by RWE NPower Renewables Limited dated 11 December 2008 for consent to construct and operate a 130-250MW wind turbine generating station in Powys, Mid Wales (“Carnedd Wen”)

page 3 of 27 3 History

3.1 All three Councils are attendees of the Montgomeryshire Local Council Forum which has considered all aspects of the applications and has been a key objector to all windfarm development in Montgomeryshire.

3.2 Each of the three Councils has also, in their own right, objected to windfarm development in Montgomeryshire.

3.3 Llandysilio Community Council completed a survey of residents in January 2013; 84% of respondents said they were worried about the large lorry convoys coming through the community.

3.4 Llandrinio and Arddleen Community Council completed a survey of residents in January 2013; 88% of respondents said they were worried about the large lorry convoys coming through the community.

3.5 Carreghofa Community Council completed a survey of residents in January 2013; 97.85% of respondents said they had not been consulted regarding transport movements through Llanymynech.

3.6 Appendices B1 to B3 show the full results of each of the Community Council’s surveys.

page 4 of 27 4 Abnormal Indivisible Loads

4.1 The Strategic Traffic Management Plan (sTMP) has been developed by Grontmij and approved by Welsh Assembly Government, Powys County Council, Shropshire Council, Police, Highways Agency and Wind Farm Developers who are signatories to the Plan.

4.2 South Wales ports have been discounted due to distance from the sites which is supported by the Highways Agency Water Preferred Policy document, paragraph 3.6.1 (Appendix B) and the Welsh Assembly Government. On this basis we understand that routing for all AILs for the five windfarm proposals covered by this Inquiry, a total of 158 turbines, will be from Ellesmere Port via Wrexham, Oswestry and Welshpool along the A483.

4.3 We have studied the sTMP, section 2: Ellesmere Port to Welshpool, (the Plan) submitted by Renewable UK Cymru and consider that the Plan seriously understates the anticipated delay times which will be experienced by our residents, as well as through traffic, by abnormal indivisible loads required for the construction of the windfarms.

4.4 The A483 between the junction with the A5 (Mile End roundabout) to the north and the junction with the A458 (Buttington roundabout) to the south is already a busy single carriageway road. The Department for Transport’s Annual Average Daily Flow (AADF) figures for 2012, the latest available on their website, show that for the 13 miles of the A483 between the Mile End and Buttington roundabouts:

 the annual average number of all motor vehicles is 10,257 per day  the annual average number of all HGVs is 960 per day, representing 9.63% of the total

See Appendix C for a summary of this data.

4.5 There are 8 major junctions along this route:

A5/A483 (Mile End roundabout), Oswestry B5069 (Morda) A495/B4396 (Llynclys crossroads) B4398 (Llanymynech crossroads) B4393 (Four Crosses roundabout) B4393 (Maerdy Bridge) B4392 (Arddleen) A483/A485 (Buttington roundabout), Welshpool

In addition we have counted a further 25 minor roads and 102 private drives between Llynclys and Four Crosses alone. These provide access principally to individual domestic properties as well as to farms and small businesses.

page 5 of 27 4.6 Using the figures agreed between Montgomeryshire Local Council Forum and windfarm developers, each turbine will require nine AILs. According to the sTMP Overview Report, paragraph 5.2.3, “At present, the police are prepared to escort convoys of up to two vehicles. It is therefore proposed to trial convoys of only two abnormal load vehicles initially, with a view to increasing the convoy size to three abnormal load vehicles if the delivery system is found to work well”. As an increase from two to three loads per convoy is currently hypothetical, we are working on a total of 1422 AILs in 711 convoys from Ellesmere Port.

4.7 According to the sTMP Overview Report, paragraph 7.1:

 initially convoys are planned to move through Newtown before 7am on a weekday  no more than one convoy per day will be moved through Newtown between 7am and 7pm on a weekday  convoys are planned to move through Welshpool between the morning and lunchtime peaks on a weekday  no more than one convoy per day will be moved through Welshpool between 7am and 7pm on a weekday  convoys may also be moved through Welshpool before 7am and through Welshpool and Newtown at weekends or after 7pm on a weekday

However in paragraph 7.2.3:

 convoys travelling on via Welshpool will depart the Mile End layover area at around 9.30am to pass through Welshpool before the afternoon peak period  convoys travelling on via Newtown will depart Ellesmere Port at around 9.30am to stop at the Abermule layover area before lunchtime

Conversely, in the notes associated with Table 2-3 of the Plan, note 1 states “Convoy assumed to depart Mile End layover area at approximately 9.30am”. This implies application to all convoys regardless of their subsequent destination.

4.8 While the information outlined in 4.7 above is contradictory in some of its detail, it would appear that convoys are planned to travel between the Mile End roundabout and the Buttington roundabout during the morning to lunchtime period on a weekday. We are unclear whether the possible weekend convoys through Welshpool and Newtown would entail weekend convoy movements between Oswestry and Welshpool which would critically impede other traffic both along and across the A485 and surrounding roads.

4.9 The sTMP Overview Report, paragraph 7.2.2 states: “More than one convoy may be moved during any one day between Ellesmere Port and the layover areas if appropriate.” Without knowing which layover areas are being referred to, we are unclear whether this will mean more than one convoy per day is intended to travel between Oswestry and Welshpool.

page 6 of 27 4.10 In the notes associated with Table 2-3 of the Plan, note 2 states “Average speed of convoy assumed to be 30mph”.

4.11 All of the loads are classified as abnormal loads under the Road Vehicles (Authorisation of Special Types) (General) Order 2003 (STGO). STGO paragraphs 28(2) defines a load of exceptional width as exceeding 4.3 metres and paragraph 30(2) sets a speed limit for these wide loads of 30mph on roads other than motorways or dual carriageways.

4.12 STGO defines three categories of abnormal loads:

Category 1 up to 50 tonnes gross weight, maximum speed on roads other than motorways or dual carriageways 40mph

Category 2 from 50 to 80 tonnes gross weight, maximum speed on roads other than motorways or dual carriageways 30mph

Category 3 from 80 to 150 tonnes gross weight, maximum speed on roads other than motorways or dual carriageways 30mph

While some loads may fall within Category 1, convoys will be mixed and can only go as fast as the speed limit for Category 2 and 3 vehicles. We therefore assert that 30mph is the maximum legal speed of the majority of convoys.

4.13 The width of the A483 between the proposed passing place at Llynclys crossroads and the next passing place at Four Crosses is often less than 7 metres, and narrows to below 6.5 metres in several places. This is insufficient to allow opposing traffic to progress at the same time that an AIL convoy travels this section. Paragraph 4.2.2 of the Plan acknowledges that opposing traffic will need to be held at Four Crosses for a convoy travelling southbound from Llynclys.

4.14 With the full width of the carriageway available, abnormally wide loads should be able to negotiate this section without too much difficulty, although we do not anticipate them reaching anywhere near the maximum speed of 30mph, particularly through the more built up areas of Pant and Llanymynech.

4.15 The abnormally long loads carrying the blades, each up to 45 metres long, will have greater difficulty in negotiating bends. In particular, the sharp bend between Pant and Llanymynech will need to be passed extremely slowly. Three replacement 32 metre blades were transported to Cefn Croes on 1 May 2012; one vehicle was videoed and timed as taking 1 minute 12 seconds to complete the manoeuvre.

4.16 We therefore consider the seven minutes projected in Table 2-3 of the Plan for the 3.6 miles between Llynclys and Four Crosses to be unrealistic, particularly when this calculates to 31mph, above the speed limit for the loads.

4.17 Paragraph 4.2.2 of the Plan states: “The passing place at Four Crosses does not have sufficient width to permit following and opposing traffic to pass the

page 7 of 27 convoy at the same time. It is assumed that opposing traffic will be allowed to clear before following traffic once the convoy is at the passing place so that individual vehicles will not be delayed by more than 10 minutes.” However the Summary for Section 2 states: “Individual vehicles may be delayed more than 10 minutes if opposing traffic is allowed to clear before following traffic overtakes”, which is borne out by the total section duration of 11 minutes in Table 2-3 of the Plan.

4.18 In view of the above we consider both the travel times and the queue lengths and times allowed to clear opposing and following traffic for the section between Llynclys and Four Crosses passing places set out in the Plan and summarised in Table 2-3 to be flawed .

4.19 While we have not studied the other sections between Oswestry and Mile End in such detail we believe they will show similar optimistic timescales, for example the calculated speed to achieve the 1.7 miles from Mile End to Morda in three minutes and the following 1.7 miles from Morda to Llynclys, also in three minutes, is 34mph, above the speed limit for the loads.

4.20 In addition to the convoys detailed in this evidence, and we accept this may be outside the scope of this Inquiry, further AIL convey movements will be needed in future to replace blades.

page 8 of 27 5 Non-AIL windfarm traffic

5.1 Using the figures agreed between Montgomeryshire Local Council Forum and windfarm developers, each turbine will generate around 1,000 other HGV, van or car movements to and from the windfarms.

5.2 This means that the 158 turbines included in this Inquiry will generate approximately 158,000 additional outward and return vehicle movements.

5.3 In order to understand how this relates to existing traffic flows we have used the Department for Transport’s AADF figures for 2012. However, AADF figures represent an average flow over a 24 hour period: traffic levels are undoubtedly higher, both overall and for HGVs, between the hours of 7.00am and 7.00pm than from 7.00pm to 7.00am.

5.4 The Cumulative Impact Assessment of non-AIL Construction Traffic on the Strategic Road Network states in paragraph 3.3: “The trip distribution has been based upon the information presented within the environmental statements regarding the predicted routes for both construction staff and materials for all sites based upon the key routes given above. Where a route choice is available traffic has been distributed proportionally based on routes within the local area and population centres.”. This implies that not all windfarm-associated traffic will travel along the strategic route.

5.5 It is impossible for us to tell how much of the non-AIL traffic will travel along the A483 between Mile End and Buttington roundabouts. Appendix D illustrates the average increase in traffic movements over construction periods of one to eight years but we anticipate that there will inevitably be peaks and troughs of volumes over any construction period.

5.6 Equally it is impossible for us to tell how much of the non-AIL traffic will travel along other major and minor roads in our area, travelling through villages such as Llandrinio (B4393) or Arddleen (B4392). This will be dependent on factors such as the vehicles’ starting points.

5.7 In addition, and we accept this may be outside the scope of this Inquiry, further non-AIL movements are likely to be needed in future to support maintenance activities such as replacement blades.

page 9 of 27 6 Other traffic

6.1 There will be additional traffic arising from:

 the construction of lay-bys for AILs together with any other works required to the carriageway along the route  the construction of the Cefn Coch Substation  the construction of the 132kV Llandinam line  the construction of the connection from the windfarms to the grid, comprising the proposed pylons and 400 kV power line and the underground section at Meifod

The volume and nature of this traffic is for us at this stage unquantifiable.

7 Effect on our local communities

7.1 The 158 turbines which are part of the scope of this enquiry will generate up to 1422 AIL loads as 711 convoys producing delays throughout our communities which at best will be disruptive and at worst catastrophic for local residents, for businesses and for tourism.

7.2 If, as the Plan states, convoys will be travelling on the A483 every weekday, our communities will be affected each working day for 143 weeks, see Appendix D. This is a period of 2 years 9 months.

7.3 Furthermore, thousands of additional vehicles will be travelling not only on the area’s trunk roads but on local B and C roads, many of which are not designed for high volumes of traffic.

7.4 We envisage the effects of this to include:

 frustration leading to accidents as drivers, both commercial and private, try to make up for lost time  local businesses which depend on passing trade will be severely affected because drivers will try and avoid the route, resulting in loss of revenue  local businesses will experience additional expense due to the delays, and local deliveries, both to businesses and homes, will take longer  essential social and medical visits will be disrupted, such as meals on wheels, nurse and doctor visits and social care  school and college transport runs may be affected, since these buses need clear roads between 7:30 and 9:15 am and from 2:30 to 4:00 pm.  this is a farming area with two large livestock markets in Oswestry and Welshpool; delays may mean additional stress caused to animals being transported.

page 10 of 27 7.5 The increase in traffic volumes will bring with it an increase in noise, in vibration and in emission pollution.

7.6 The increase in traffic volumes will generate additional wear and tear on our roads. While the trunk roads are maintained by the Highways Agency (England) and Welsh Assembly Government (Wales), local roads are maintained by the local authority, in our case Powys County Council. We are concerned that with the ongoing cuts to public funding in Wales there will be insufficient resources available to keep our roads in good condition.

7.7 Llanymynech bridge over the Vyrnwy is a Grade II* structure. With the present traffic flow there are already signs of movement. A single AIL passing over the bridge will put the full weight of its load on the structure. If the windfarm applications are successful we consider it essential that an independent condition survey and structural assessment of loading capacity is carried out.

page 11 of 27 This statement of case has been prepared by Cllr Martin Clare (Carreghofa), Cllr Frances Buckingham (Llandysilio) and Cllr Alec White (Llandrinio and Arddleen) on behalf of:

Cyngor Cymuned Carreghofa Community Council

Chair Cllr Martin Clare Clerk Mrs Janice Stanistreet, Chapel View, Wern, Llanymynech, SY22 6PD

Cyngor Cymuned Llandysilio Community Council

Chair Cllr Mark Foulkes Clerk Mrs Carol Davies, The Crest, Four Crosses, Llanymynech, SY22 6QZ

Cyngor Cymuned Llandrinio and Arddleen Community Council

Chair Cllr Brian Foulkes Clerk Mrs Carol Davies, The Crest, Four Crosses, Llanymynech, SY22 6QZ

February 2014

page 12 of 27 References

Strategic Traffic Management Plan for Mid Wales Wind Farms dated August 2012, in particular: sTMP section 1: Overview Report http://www.llanbrynmairwindfarm.co.uk/media/1062221/2012%20sei%20(5)%20- %20renewableuk%20cymru%20strategic%20traffic%20management%20plan%20se ction%201%20overview.pdf sTMP section 2: Ellesmere Port to Welshpool Public Inquiry document reference CD/FWL/TRA/003

Cumulative Impact Assessment of non-AIL Construction Traffic on the Strategic Road Network dated December 2013 http://www.vattenfall.co.uk/en/file/Appendix_D_Mid_Wales_Non_AIL_Cumulative_Im pact_Assessment_Report.pdf_49738122.pdf

Highways Agency Water Preferred Policy: guidelines for the movement of abnormal indivisible loads Public Inquiry document reference CD-COM-TRA-005

Road Vehicles (Authorisation of Special Types) (General) Order 2003 http://www.legislation.gov.uk/uksi/2003/1998/made?view=plain

The Department for Transport’s Annual Average Daily Flow (AADF) – two data sets were used from which we extracted the 2012 information:

Powys: http://www.dft.gov.uk/traffic-counts/area.php?region=Wales&la=Powys Shropshire: http://www.dft.gov.uk/traffic- counts/area.php?region=West+Midlands&la=Shropshire

page 13 of 27

page 14 of 27 APPENDIX A1

1 Mile End roundabout (A5)

page 15 of 27 APPENDIX A2

2 Morda junction (B5069)

page 16 of 27 APPENDIX A3

3 Llynclys crossroads (A495/B4396)

page 17 of 27 APPENDIX A4

4 Llanymynech crossroads (B4398)

page 18 of 27 APPENDIX A5

5 Four Crosses roundabout (B4393)

page 19 of 27 APPENDIX A6

6 Maerdy Bridge junction (B4392)

page 20 of 27 APPENDIX A7

7 Arddleen junction

page 21 of 27 APPENDIX A8

8 Buttington roundabout (A485)

page 22 of 27 APPENDIX B1

CYNGOR CYMUNED LLANDYSILIO COMMUNITY COUNCIL

The count for the Community Council’s Wind Farms, Transport, Power Lines and Pylons survey was carried out on January 28 2013 and independently verified by Robert Robinson FRICS AILCM, Town Clerk of Welshpool Town Council.

A total of 350 people responded – a return of 38.46% of the current 910 registered electors – and the detailed results are shown below.

Yes No Don’t Know Wind Farms Do you support the proposal to 34 305 10 construct large numbers of wind turbines in the Powys uplands? 9.71% 87.14% 2.86% Power Lines Are you concerned about the plans 312 35 2 & Pylons to construct a 400 kV power line on 180ft pylons from the proposed sub- 89.14% 10.00% 0.57% station at Cefn Coch, via our community, to West Felton in Shropshire? Transport Are you worried about the large lorry 294 47 8 convoys coming through our community? 84.00% 13.43% 2.29% Property Are you concerned about the effect 290 48 11 Values this proposed project may have on property values? 82.86% 13.71% 3.14%

There was one spoilt paper (0.29% of the total responses).

page 23 of 27 APPENDIX B2

LLANDRINIO AND ARDDLEEN COMMUNITY COUNCIL

The count for the Community Council’s Wind Farms, Transport, Power Lines and Pylons survey was carried out on January 17 2013 and independently verified by Robert Robinson FRICS AILCM, Town Clerk of Welshpool Town Council.

A total of 503 people responded – a return of 43.50% of the current 1149 registered electors – and the detailed results are shown below.

Yes No Don’t Know Wind farms 38 453 12 Do you support the proposal to construct large numbers of wind turbines in Mid Wales? 7.55% 90.06% 2.39% Power Lines & Pylons 26 466 11 Do you approve of National Grid’s plans to construct a 400 kV power line from a proposed sub-station at Cefn 5.17% 92.64% 2.19% Coch to West Felton in Shropshire, as well as the feeder lines from wind farms to the substation? Transportation of major equipment 441 59 3 Do you have concerns about large lorry convoys an additional vehicle movements on roads in Mid Wales 87.67% 11.73% 0.60% to transport all the equipment? Information and consultation 140 324 39 Do you feel lyou have been consulted adeqately by National Grid on their proposals? 27.83% 64.41% 7.75% Impact on property values 438 51 14 Do you have concerns about the impact that wind farm and pylon construction may have on property and 87.08% 10.14% 2.78% business values?

page 24 of 27 APPENDIX B3

CARREGHOFA COMMUNITY COUNCIL

SURVEY QUESTIONS

Please vote by ticking the appropriate box.

Also for electoral reasons we would also ask you for your address with your post code

Address......

......

Question Yes No

Wind Farms Do you support proposals to

construct large wind farms in the Q1 uplands of mid Wales? 7.33% 91.81%

Power Lines Do you approve of National Grids proposal to construct a 400kV Q2 and power line from Cefn Coch to 0.86% 97.85% Lower Frankton via Llanymynech Pylons and Pant?. Transport Have you been informed or Consultation consulted by the wind farm companies regarding vehicle 3.00% 95.71% Q3 transportation through Pant and Llanymynech?

Travelling Will the frequent daytime disruption and closure along the Q4 A483 affect your travel plans? 88.84% 9.87%

Tourism, Are you concerned that the Economy and proposed projects will affect the Q5 Property local tourism, economy and 88.84% 9.44% Values property values in the area?

The survey count will be independently monitored and results publicly announced. The survey will form part of the evidence to be submitted to the public inquiry this year

Survey carried out on 10th February 2013 and verified by Robert Robinson FRICS AILCM, Town Clerk, Welshpool Town Council on 12th February 2013

page 25 of 27 APPENDIX C

ANNUAL AVERAGE DAILY FLOW - 2012 count description all motor all all other percent point vehicles HGVs vehicles HGVs

18352 A483 from junction with A5 12553 965 11588 7.69% (Mile End roundabout) to junction with B5069 (Morda turn-off) 8366 A483 from junction with B5069 11985 1006 10979 8.39% to junction with A495/B4396 (Llynclys crossroads)

17161 A483 from junction with 11571 987 10584 8.53% A495/B4396 to Shropshire boundary (Llanymynech)

74093 A483 from Shropshire 8701 925 7776 10.63% boundary to Shropshire boundary (part North Road, Llanymynech) 30558 A483 from Shropshire 8701 925 7776 10.63% boundary to junction with B4393 (Four Crosses roundabout) 548 A483 from junction with B4393 8029 954 7075 11.88% to junction with A458 (Buttington roundabout)

average 10257 960 9296 9.63%

page 26 of 27 APPENDIX D

PROPOSED WINDFARM TRAFFIC VOLUMES abnormal indivisible loads - wind turbine parts based on 158 turbines each requiring 9 abnormal loads travelling in convoy 2 loads at a time equals 1422 abnormal loads in 711 convoys in total assuming one convoy of two abnormal loads per working day (5 per week)

711 convoys = 143 weeks 33 months 2.75 years other windfarm traffic each turbine will generate around 1000 other HGV, van or car movements to the windfarms based on 158 turbines this will mean 158000 additional vehicle movements in total

2012 average AADF 10257 construction average average average average percentage period movements movements movements movements increase years per year per month per week per day in traffic 1 158000 13167 3038 433 4.22% 2 79000 6583 1519 216 2.11% 3 52667 4389 1013 144 1.40% 4 39500 3292 760 108 1.05% 5 31600 2633 608 87 0.85% 6 26333 2194 506 72 0.70% 7 22571 1881 434 62 0.60% 8 19750 1646 380 54 0.53%

page 27 of 27