BLACKBERRY LANE SOLAR PARK
REQUEST FOR SCREENING/SCOPING OPINION
JANUARY 2020
Abbreviations
AC alternating current AOD Above Ordnance Datum AONB Area of Outstanding Natural Beauty DC direct current EIA Environmental Impact Assessment km Kilometres kV Kilovolts ha hectare LDF Local Development Framework MW Megawatt m Metres PPG Planning Policy Guidance PV Photovoltaic SAM Scheduled Ancient Monument SSSI Site of Special Scientific Interest UK United Kingdom £ Pounds Sterling
1. INTRODUCTION
1.1 Overview Wessex Solar Energy propose to submit a planning application for the development of a solar park located approximately 0.7 kilometres (km) south east of Cosheston, and approximately 2.5 km north east of Pembroke. The site is within the within the jurisdiction of Pembrokeshire County Council (the Council), and the relevant Community Council is Cosheston.
The development is classed as a Development of National Significance (DNS) and as such would be determined by the Planning Inspectorate Wales (PINS Wales). 1.2 Wessex Solar Energy Wessex Solar Energy is a company involved with the development of Solar Park projects in the United Kingdom (UK). The company has developed 18 Solar Parks in the UK so far and is looking at a portfolio of sites across England and South Wales for development of similar projects. The proposed site has been identified as being an ideal candidate.
Wessex Solar Energy draws on the expertise of a group of dedicated engineers, environmental scientists and financiers who have many years of experience in the renewable energy and conventional power generation sector.
Wessex Solar Energy is committed to developing projects in an environmentally responsible and sustainable manner. 1.3 The Planning and Assessment Process Solar Park developments are not specifically listed under either Schedule 1 or Schedule 2 developments of the Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017, referred to as the EIA Regulations. However, the regulations do state that energy development, including “industrial installations for the production of electricity” covering an area exceeding 0.5 ha, are considered to be Schedule 2 developments.
As not all Schedule 2 developments require a full EIA to be undertaken, a Request for a Screening Opinion was submitted to Pembrokeshire County Council in September 2013 to determine the need, or otherwise, to conduct a full EIA for the proposed Solar Park. In their Screening Reply, issued on 8 November 2013, the Council stated: “the Screening Opinion attached has determined that an Environmental Impact Assessment is not required for the proposed development”. However, the Council did state that some specific environmental information should be submitted with the application for Planning Permission.
A copy of the Screening Reply from the Council is included in Appendix A.
Some time has passed since this screening opinion was received and in that time the Town and Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016 has come into force. This implements the Welsh Government’s requirements for Developments of National Significance. The Welsh Government considers proposals that generate above 10 MW of energy to be a Development of National Significance (DNS).
Pre-application advice and EIA screening form an important part of the DNS process, allowing early feedback from consultees on a proposed development and providing an opportunity to agree the scope of any studies, surveys and reports which should accompany any subsequent planning application.
This document has been prepared by Wessex Solar Energy to inform Pembrokeshire County Council of their proposal to construct a Solar Park at “Blackberry Lane”, located approximately about 0.7 km to the south east of Cosheston at the nearest point.
Wessex Solar Energy now seeks, a Screening Direction from PINS Wales as to whether an EIA would be required for the project.
It is expected that the scoping direction will set out:
Topics to be covered; Identified constraints; Comments on the methodology proposed (including bodies to consult); and Cumulative developments identified.
The process of scoping assists in defining the key topic areas and information to be included in the assessment and can identify where matters could be scoped out or reduced in scope, if there are no likely significant environmental effects.
To assist PIN Wales in their decision a Preliminary Environmental Appraisal (PEA) has been completed for the proposed site. This scoping document should be read in conjunction with the PEA.
Should PINS Wales consider that an EIA is required we would ask that they treat this document as a formal request for a Scoping Opinion.
Whether or not a full EIA is required Wessex Solar Energy does propose that some specific environmental studies should be undertaken in support of any future planning application.
For areas where studies are considered necessary we have provided a methodology / scope for the proposed works. For areas that we do not consider further investigation to be required these are identified and the reasons for discounting them provided.
2. THE PROJECT AND PROJECT SITE
2.1 Key Elements of the Project The Project will be capable of exporting up to 22 MW of electricity from solar energy into the regional electricity grid. The key elements of the proposed development are summarised in Table 2.1. TABLE 2.1: KEY ELEMENTS OF THE PROJECT
Element of Proposed Scheme Details
Approximate Number of Crystalline 66,000 PV Panels (PV Cells) Indicative Nominal Power (per 400 W Panel) Number of Inverters Up to 22 Number of Transformers Up to 22
Inverter / Transformer Cabin 8.5 m (length) by 2.5 m (width), and 3 m (height). Dimensions (m)
Control Building Dimensions (m) 5 m (length) by 5 m (width), and 4.5 m (height).
Perimeter / Security Fence (m) 2 to 3 m (height) The PV Cells will require interconnection within the proposed Solar Park site to Inverters that will convert the low voltage DC to low voltage AC. In turn, the Inverters will connect to Transformers that will convert the low voltage AC to higher voltage AC (33 kV) for export to the regional Electrical Connection electricity grid. Electricity will be exported to the regional electricity grid via an underground cable to the existing Golden Hill 33 / 132 kV Substation located approximately 2.3 km to the south west. This is operated by Western Power Distribution, the local network operator. The onsite access track would likely be constructed from compacted stone Onsite Access Track or aggregate. The total length of the onsite access track is as yet unknown. The Temporary Site Compound / Laydown Area would be approximately 900 m2 and would comprise an area of hard standing / gravel which will Temporary Site Compound / , house a temporary office and welfare facility (including a port-a-loo). This Laydown Area Compound / Area will also be used for the parking of staff vehicles and the storage of construction equipment / vehicles / materials
2.2 Description of the Project Solar energy is an unlimited energy resource, and can be harnessed (through solar radiation) to either directly generate hot water for heating, known as ‘solar thermal’ projects, or generate electricity. Solar energy can be used to generate electricity in two ways, either using PV Cells or by arranging reflective surfaces to focus sunlight onto a single point, which then heats water to produce steam to drive steam turbines, known as ‘concentrated solar power’ projects. For the purposes of this Project, PV Cells would represent the preferred technology. PV Cell technology is uncomplicated (indeed, it is found on most modern calculators) and is relatively unobtrusive when compared to other developments, such as wind farms, which can be highly visible over many miles. PV Cells can be used to generate electricity on a large scale, and are increasingly used on rooftop or ‘building integrated’ schemes in the UK to reduce the carbon footprint of housing or other developments. PV Cell technology has also been commercially proven on large scale multi-MW power generation projects since the 1990’s, with the UK now having over 13,000 MW of solar PV capacity, much of which is made up of solar parks.
The PV Cells (or PV Panels) would convert the solar energy in sunlight into electrical energy by generating Direct Current (DC) which would then be converted to Alternating Current (AC) for export to the regional electricity grid. As per Table 2.1, Crystalline Panels are being considered for the proposed Solar Park. Crystalline Panels are of the order of 1600 mm (length) by 1000 mm (width), and 50 mm (depth). The indicative dimensions and designs of Crystalline Panels are provided in Figure 2.1. The PV Panels are positioned at an angle of between 20° and 35°, and would have a height of no more than 3.5 m from the ground to the top of the PV Panel. Accordingly, taking irradiation into account, the proposed Solar Park would comprise approximately 66,000 individual panels. To ensure that the PV Panels remain in their proper position they will be fixed onto steel frames. Insert 2.1 shows an example of PV Panels in situ.
INSERT 2.1: AN EXAMPLE OF PV PANELS IN SITU
The PV Cells will require interconnection within the proposed Solar Park site to Inverters that will convert the low voltage DC to low voltage AC. In turn, the Inverters will connect to Transformers that will convert the low voltage AC to higher voltage AC (circa 33 kV) for export to the regional electricity grid. A network of cables would connect the Transformers to a set of switchgear from which electricity would be exported to the regional electricity grid. The Inverters and Transformers would be housed in dedicated Inverter / Transformer Cabins, and the switchgear would be housed in a dedicated Control Building. Indicative elevations of an Inverter / Transformer Cabin and a Control Building are shown on Figure 2.2a and Figure 2.2b respectively. It should be noted that the final selection of the exact type and size of PV Panels and associated equipment will be subject to confirmation through a competitive tendering process (which will determine the manufacturer / supplier of the PV Panels and associated equipment) which will be undertaken following the receipt of Planning Permission. However, whilst there are a number of manufacturers / supplier of PV Panels with the required power output, for the purposes of this Environmental Report an upper limit in terms of dimensions and land take has been quoted so that the final design (which would be agreed with the Council as part of a Planning Condition) would be less than that considered within the accompanying PEA Report. From the Control Building, it is proposed that electricity will be exported to the regional electricity grid via an underground cable to the existing Golden Hill 33 / 132 kV Substation located approximately 2.3 km to the south west. This is operated by Western Power Distribution, the local network operator. Site access would be along the A447, turning onto the access road to Lower Nash Farm and entering the site via an existing access point in the south west corner of the south western most field. During construction, onsite access tracks would be approximately 3 m wide and would be placed to avoid known ground hazards, environmental constraints and steep gradients. The proposed new onsite access track would not be extensive, and would link the site access point to the various fields and buildings that make up the proposed Solar Park. This onsite access track would likely be constructed from compacted stone or aggregate. An indicative cross-section of an onsite access track is shown in Figure 2.3.
It is also possible that a permanent 2 to 3 m tall security fence would be installed (behind any existing onsite hedgerows), with an access gate at the point of access, to ensure there is no unauthorised access to the proposed Solar Park site. Indicative security fence details are shown in Figure 2.4. 2.3 The Project Site The Solar Park will be located approximately 0.7 kilometres (km) south east of Cosheston, and approximately 2.5 km north east of Pembroke. There are a small number of scattered houses in the vicinity of the proposed Solar Park site. The closest of these is Nash Villa (located approximately 130 m south west of the proposed site boundary at the nearest point). The location of the proposed Solar Park site is shown in Figure 1.1, and the site boundary (and indicative site layout) is shown in Figure 1.2. The proposed Solar Park site is centred at Ordnance Survey (OS) Grid Reference 201645, 203240. The proposed site comprises 8 fields (pasture), covering a total area of approximately 36.9 hectares (ha). The proposed Solar Park site falls within the jurisdiction of Pembrokeshire County Council (the Council), and the relevant Community Council is Cosheston. There are no public footpaths or bridleways that cross the proposed site. The nearest footpaths form the western site boundary. The site is flat for the most part, with a north-south slope which is more exaggerated in the northern part of the site. The site altitude varies from approximately 35 m Above Ordnance Datum (AOD) to approximately 20 m AOD. The nearest landscape designation (or at least designation with landscape implications) is the Pembrokeshire Coast National Park, located approximately 120 m to the north of the proposed site. Further information on potential landscape and visual impacts is provided in Section 5 (Landscape and Visual). The proposed Solar Park site is not located within any internationally, European or nationally designated ecological sites. The closest are the Pembrokeshire Marine / Sir Benfro Forol Special Area of Conservation (SAC) (approximately 1 km to the west at its nearest point) and the Milford Haven Waterway Site of Special Scientific Interest (SSSI) (approximately 650 m to the north east at its nearest point). Further information on ecology and ornithology is provided in Section 6 (Ecology and Ornithology). There are no World Heritage Sites within 5 km of the proposed site. There is a Registered Park / Garden located approximately 510 m to the north east of the proposed site. There are no Scheduled Ancient Monuments within the proposed Solar Park site boundary. The closest Scheduled Ancient Monument is located approximately 1.5 km to the south. Further information on cultural heritage / archaeology is provided in Section 7 (Cultural Heritage / Archaeology). Site access would be along the A447, turning onto the access road to Lower Nash Farm and entering the site via an existing access point in the south west corner of the south western most field. These roads are used frequently by large farm vehicles and HGVs. 2.4 Safety Construction The selection of the Construction Contractor(s) and Specialist Sub-contractors would include an assessment of their record in dealing with environmental issues and require the provision of evidence that they have incorporated environmental requirements into their Methods Statements and Working Practice Procedures. Wessex Solar Energy would require that the selected Construction Contractor(s) to nominate an Environmental Site Manager and Site Waste Manager for the duration of the construction and commissioning phases. During construction, Wessex Solar Energy would require the Construction Contractor to provide his own skips which would be clearly labelled and designated for a specific type of waste. All skips would be kept covered to reduce dust being blown around the site. Wherever possible, any recyclable waste would be taken off site for reprocessing. The Construction Contractor would also be responsible for training its personnel in spill prevention and control and, if an incident occurs, would be responsible for containment and clean-up. Any leaks
/ spills would be addressed in accordance with the agreed Method Statements and Working Practice Procedures. An information board would be displayed in a publicly accessible location at all times and would give the name and telephone number of the Construction Contractor’s Environmental Site Manager. Furthermore, warning signs would be erected to inform and protect members of the general public of the construction works being undertaken. Operation PV Panels are inherently safe. They have no moving parts, they are held firmly in position by steel / zinc-plated supports and they are designed to ensure that the PV Panels cannot become detached (even in the strongest winds). The Inverters and Transformers would be designed to meet stringent electricity industry standards. The oil filled Transformer would have a specifically designed containment system (i.e. a bund) to ensure that any accidental fluid leak does not result in a discharge to the environment. The Transformer would also be equipped with an oil level indicator to detect potential leaks / spills. If the oil level inside the Transformer dropped due to a leak / spill, an alarm would be activated on the remote control panel and a maintenance engineer would be despatched to investigate and remedy the situation. Any waste fluids would be taken off site for disposal by a licensed collection service for recycling or disposal at a suitable registered facility. Warning signs would be installed to alert the public to the danger of entering the Inverter / Transformer Cabins and the Control Building. It is also possible that a permanent 2 to 3 m tall security fence would be installed (behind any existing onsite hedgerows), with an access gate at the point of access, to ensure there is no unauthorised access to the proposed Solar Park site. In addition, the proposed Solar Park site may be continuously monitored by CCTV cameras. Furthermore, the proposed Solar Park would be equipped with a computer control system that would continuously and automatically monitor variables such as electrical voltage and current from a central off-site host computer or from a remote personal computer. The computer control system would be able to ensure that the proposed Solar Park always operates efficiently and safely. In the event of a fault, the system would be able to automatically alert off-site staff. If necessary, the modular design of PV Panels allows them to be rapidly replaced. Decommissioning The selection of the Decommissioning Contractor(s) and Specialist Sub-contractors would include an assessment of their record in dealing with environmental issues and require the provision of evidence that they have incorporated environmental requirements into their Methods Statements and Working Practice Procedures. The details of the Method Statements and Working Practice Procedures would be agreed not less than 12 months prior to the commencement of decommissioning. It is likely that this would be the subject of a Planning Condition. 2.5 Construction of the Project Following receipt of Planning Permission, a competitive tendering process would be undertaken for the contract for the supply, construction and commissioning of the Solar Park. The award of the construction contract may be made to one or more Construction Contractors, who may in turn appoint Specialist Sub-contractors. The main Construction Contractor(s) and Specialist Sub-contractors would be responsible for the detailed design, manufacture and supply, delivery to site, off-loading, site preparation, civil construction, erection / installation and commissioning of the PV Panels, Inverters, Transformers and associated equipment / structures. Accordingly, following receipt of Planning Permission and award of construction contracts, it is anticipated that it could take as little as 6 months to construct the proposed Solar Park. Initially, a Geotechnical Survey of the proposed Solar Park site would be undertaken in order to identify the underlying geology which would be used to inform the design of the PV Panel, Inverter / Transformer Cabins and Control Building skid mounts / foundations. The Geotechnical Survey would also be used to inform the locations of the underground electrical cables, onsite access roads and other miscellaneous equipment / infrastructure. The principal activities for the construction of the proposed Solar Park would be undertaken in the following order:
1) Constructing limited Onsite Access Tracks and a Temporary Site Compound / Laydown Area. 2) Excavating and Constructing the Skid Mounts and Foundations for the PV Panels (if needed) and the Inverter / Transformer Cabins and Control Building. 3) Installing / Constructing the PV Panel Support Structures and the Inverter / Transformer Cabins and Control Building. 4) Assembling the PV Panel Mounting Systems. 5) Mounting the PV Panels. 6) Installing the Underground Electrical System. 7) Commissioning and Energising the Solar Park. 8) Site Reinstatement, including undertaking any Enhancement Measures. In order to minimise disturbance, onsite access tracks and a Temporary Site Compound / Laydown Area would be constructed first. This is estimated to take between one to two weeks. The Temporary Site Compound / Laydown Area would require the creation of a small area of hard standing / gravel which would house a temporary office and welfare facility (including a port-a-loo). This Compound / Area would also be used for the parking of staff vehicles and the storage of construction equipment / vehicles / materials. If necessary, a temporary wheel / chassis washing facility would be installed at the site access point to prevent the transfer of soil onto nearby public roads. Once the onsite access tracks and Temporary Site Compound / Laydown Area are in place, excavation for and construction of the skid mounts and foundations would commence. This is estimated to take approximately 4 weeks. It is not anticipated that soils would need to be removed from the proposed Solar Park site during / following the excavations for the skid mounts and foundations. Instead, following the completion of construction, these soils would be used for any site re-instatement works. Following completion of construction, the onsite access tracks and Temporary Site Compound / Laydown Areas would be restored as closely as possible to their original condition. Construction work would likely be restricted to the following hours. Monday to Saturday: 08:00 to 18:00 No construction work would be undertaken on Sundays or Bank Holidays. Any deviations from these hours would be agreed in advance with the Local Planning Authority. During construction, a workforce of up to 50 personnel is expected. However, it is not expected that all personnel would be onsite at the same time. Indeed, the workforce would peak with the most labour intensive construction activity, when multiple disciplines are required simultaneously. Local contractors would be encouraged to tender for the construction works. In addition and if deemed appropriate, Wessex Solar Energy could retain the services of specialist advisors with regards to ecology and archaeology for the duration of the construction period. 2.6 Operations and Maintenance The proposed Solar Park is expected to have an operational life of approximately 40 years, and would be unmanned during typical day-to-day operation. The availability of the PV Panels will be close to 100 per cent of daylight hours. However, forced outages may occur due to the malfunction of mechanical or electrical components or computer controls, although this would be very infrequent. The Solar Park would be equipped with a computer control system that would continuously and automatically monitor variables such as electrical voltage and current from a central off-site host computer or from a remote personal computer. The computer control system would be able to ensure that the proposed Solar Park always operates efficiently and safely. Twice every month the Solar Park site would be visited to ensure the equipment was working correctly, undertake routine visual inspections and undertake general maintenance activities (i.e. grass cutting / strimming). Once every 3 years the Solar Park site would be visited to undertake servicing activities (i.e. testing and calibration of the equipment) would require a short break in
operation. As far as is practical, maintenance / servicing activities would be undertaken during winter months to minimise the impact on electricity generation. The operation of the Solar Park would be undertaken in accordance with an Operational Environmental Management Plan (EMP). 2.7 Decommissioning Following 40 years of operation, it is anticipated that it could take as little as 10 weeks to decommission the proposed Solar Park. Compared to other power generation technologies, Solar Parks can be easily and economically decommissioned and removed at the end of their economic life. Following decommissioning and removal, the site can then be restored close to its original condition such that there would be little (and in some cases no) trace that a Solar Park had existed. Decommissioning would take account of the latest environmental legislation at the time. Notice would be given to the Local Planning Authority in advance of the commencement of the decommissioning work, and any necessary Licences / Consents / Permits / Permissions would be acquired. In addition, Wessex Solar Energy would develop a decommissioning plan. Following the production of the decommissioning plan, a competitive tendering process would be undertaken for the contract for the decommissioning of the Solar Park. The award of the decommissioning contract may be made to one or more Decommissioning Contractors, who may in turn appoint Specialist Sub-contractors. The first step of decommissioning would be to make the site safe for work in accordance with the prevailing Environmental Legislation, Regulations, Standards and Guidance at the time of decommissioning. The Solar Park would be de-energised in conjunction with the Distribution Network Operator (DNO). Once the site is completely de-energised and disconnected, it will be handed over to the Decommissioning Contractor(s) to complete the decommissioning and removal work. The principal activities for the decommissioning of the proposed Solar Park would be undertaken in the following order: 1) Removal of PV Panels, Inverter / Transformer Cabins and Control Building (including Support Structures) and Onsite Access Track. 2) Removal of Underground Electrical System. 3) Reuse / Recycling / Disposal of the Solar Park Structures / Equipment. The PV Panels, Inverter / Transformer Cabins and Control Building would be demolished and removed. Any support structures (i.e. skid mounts and foundations) would be removed to a depth of 1 m below grade or else entirely removed. All soil surfaces would be restored (as close as possible) to its original condition. Disturbed areas would be re-vegetated as appropriate. Decisions on reuse / recycling / disposal of Solar Park structures / equipment would be made at the time of decommissioning in the light of the available technology, and environmental / economic considerations at the time. However, it is probable that most of the Solar Park structures / equipment would be at the end of their useful operating life, and would be obsolete and unsuitable for further use. Therefore, they would need to be dismantled for recycling or disposal. A small crane would be required to dismantle the equipment. Unsalvageable material would be disposed of at a licensed landfill, only via appropriate and authorised routes. Decommissioning would be timed to minimise any potential environmental impacts (i.e. by avoiding the Breeding Bird season).
3. Legislative and Planning Policy Context
As stated above the project is considered to fall under Schedule 2 of the EIA Regulations as an installation for the production of electricity covering an area exceeding 0.5 hectare (ha). However, it is not considered by Wessex Solar Energy that a full EIA is required for the proposed development. Wessex Solar Energy understands that this is consistent with advice on other solar projects to date from other councils.
Relevant national, regional and local planning policies and targets will be addressed by the planning application and information will be provided to show how the proposal relates to such policies.
It is understood that the relevant planning policy for the area is contained in the Pembrokeshire Development Plan adopted in 2013. An initial review suggests that there are no policies directly relevant to the area of the site. However more general policies contained in the plan will no doubt be of relevance. These will be discussed in the environmental report, as appropriate as well any policies relevant at a national level (Welsh Government and UK).
4. Environmental Considerations
4.1 Introduction
A Preliminary Environmental Appraisal (PEA) has been completed as part of the pre-application and EIA screening/scoping process and should be referred to alongside this document.
The PEA has been completed in order to identify any potential development constraints and any potentially significant environmental impacts. It also provides a basis for determining the proposed scope of any surveys and further assessments.
Within the PEA report the potential environmental impacts of the construction, operation and decommissioning phases of the proposed Solar Park are assessed and discussed separately for each aspect of the environment studied. Wherever relevant, the assessment also addresses the impacts of the proposed Solar Park prior to the application of mitigation measures, and draws conclusions in relation to any potential residual environmental impacts. The assessments have been carried out in accordance with the relevant Regulations, Standards and Guidance for each aspect of the environment studied.
Given the previous screening opinion provided by Pembrokeshire County Council and the findings of the PEA, it is suggested that the proposed development does not constitute EIA development but that any subsequent planning application will include an Environmental Report that will cover environmental aspects as detailed below.
The proposed scope of assessment takes into account the findings of the PEA and sets out any additional assessments, surveys and studies which are considered necessary.
4.2 Landscape and visual amenity
A detailed landscape and Visual Appraisal has been completed and is provided as Appendix B of the PEA. A summary of the findings is presented below.
The proposed addition of PV solar panels into these fields would result in the short term temporary loss of the current landscape fabric during the construction period with land under the PV panels returned to grazing during the operation. The current medium to small scale field pattern would be retained and existing hedgerows strengthened with supplementary planting as necessary. They would be managed at an increased height of 3.5 m to aid visual containment of the site. The modern form of development would accord with large electricity pylons, modern farm buildings and other solar farms within the surrounding landscape.
Effects on character of the host landscape (LCA 25 Hundleton and Lamphey) would be Slight in magnitude of change and the potential level of effects would be Minor and Adverse. The effects on the landscape character of the Pembrokeshire Coast National Park to the north (LCA 28 Daugleddau) would be Slight in magnitude and are likely to be of a Moderate level and Adverse in nature. Beyond these areas effects on the wider landscape character would be limited and would tend towards Negligible.
Visual effects would be greatest for the closest receptors to the west including those to the south east of Cosheston, and minor road and PRoW users to the north and north east of the site within the National Park. The panels would form new man made features within views for these receptors, in part filtered by intervening tree vegetation, likely resulting in a Moderate/Slight magnitude of change and Moderate levels of effect. Intervening tree vegetation and built form would restrict visibility from Mayeston and Cosheston and effects would be Slight/Negligible in magnitude and Minor level of effects. The closest A roads including the A4075 and A477 to the south of the site are likely to have a Slight to Negligible magnitude of change and Minor to Negligible levels of effect respectively. Where open views towards the site are possible from receptors in the wider landscape to the south, the grain of the landscape would be retained. Likely effects would be Moderate/Slight in magnitude and of a Moderate level of effect.
Long term effects on the purposes of designation of the National Park would be Medium/Small scale and Limited in extent. Effects would be Slight/Negligible magnitude, Minor and Adverse.
Given the Long term yet temporary nature of the proposals, potential operational effects would be reversible. Residual effects on the landscape fabric would likely be beneficial as the hedgerow improvements would be permanent.
The Milford Haven Waterway, CADW Registered Historic Landscape is located within northern parts of the study area, broadly following the national park boundary and extending to the west of Cosheston. Whilst designated as Outstanding, the Registered Historic Landscape report record does not materially add to information on the historic landscape provided within the Pembrokeshire Council Landscape Character Assessment. The proposed development site would have little influence on this designation and as it is located over 1km from the site, the proposals would not affect its fabric and no significant effects are anticipated.
There are a number of Registered Landscape, Parks and Gardens within the study area, the nearest of which is Upton Castle Gardens approximately 0.9 km north of the site. There would be little to no visibility of the Proposed Development and no significant effects are anticipated.
Assessment methodology
It is proposed that a detailed Landscape and Visual Impact Assessment (LVIA) is undertaken for the project that would include a Landscape Masterplan. The methodology for this assessment would follow that set out within Appendix B of the PEA.
Taking into consideration the findings of the PEA we welcome the views of the PINS Wales and Pembrokeshire County Council on the appropriateness of the suggested viewpoints, whether any additional viewpoints should be chosen and whether photomontages from key viewpoints would be necessary, or whether photographs simply showing the extent of the solar farm would be sufficient.
In undertaking the assessment due consideration would be given to relevant planning policy at a local level as set out in Appendix B of the PEA.
An assessment of glint and glare effects will also be completed. The assessment will include the use of a 3 dimensional model which allow the identification of the potential for glint at any receptor point as a result of a proposed Solar PV development.
As part of the assessment potentially sensitive receptors would be identified within 5km of the site such as residential properties, roads and footpaths. Using our model, we would then determine whether glint effects may occur at these receptor locations as a result of the proposed facility, and if so, the duration, time of the day and time of year of such effects. The model generates data at minute intervals for an entire year allowing us to accurately determine potential glint effects. A qualitative assessment will then be completed to determine the screening effects of existing vegetation and buildings.
A report would be prepared which explains glint and glare effects and the circumstances under which they may occur. The assessment methodology would then be described and the sensitive receptors shown on an accompanying plan. The results for each receptor would be set out in a summary table and the screening effects of topography, existing vegetation and existing buildings at each receptor would be discussed. For any receptors which are identified as having the potential to experience glint effects after the existing conditions are taken into account, the effectiveness of any proposed site landscaping to reduce such effects would be assessed. Where this landscaping is shown to be insufficient, further mitigation measures would be proposed if appropriate.
4.3 Ecology
A Preliminary Ecological Appraisal (PEcA) has been completed for the proposed Blackberry Lane Solar Park and is presented as Appendix C of the PEA.
The purpose of the PEcA is to identify:
the major habitats present within the site and immediate vicinity; the potential for legally protected and / or notable species to be present; and the need for additional specialist ecological surveys.
The PEcA does not constitute a full survey for protected species to standard survey methodologies but is used as a tool to determine the potential of a site to support protected/notable species and to determine whether any additional specialist species surveys are likely to be required, to inform a mitigation strategy.
The construction of the panels will involve the disturbance of a small area of land for civil works such as foundations, roads and the cable routing. There will also be limited disturbance from hardstanding and laydown areas needed for construction. With the exception of land-take by electrical buildings and the access roads, all disturbances will be temporary in nature.
There is the potential that the limited earthworks could potentially result in:
Habitat removal; and Disturbance to, or loss, of species (including, potentially, rare and sensitive species).
The results of the PEcA and subsequent Ecological Impact Assessment will be used to ensure that civil works are designed and positioned in a manner that minimises damage to the local ecology and to recommend any mitigation that may be necessary to prevent harm to vulnerable species.
Access points and roads will be designed to minimise hedgerow removal and land take.
Changes in hydrology arising from site draining may have an indirect impact on flora and fauna of the surface water, on and off-site. As such, construction methods would be employed to safeguard the surface water identified on and in the vicinity of the site and prevent run off from the site affecting any water body. In particular, mitigation measures will also be employed to minimise oily water or cement in the surface water run-off.
Further to the impacts of construction, there would be no additional habitat disturbances, severances or losses. The overall long-term footprint of the structures on the land would be smaller than that of construction.
Assessment methodology
A development specific Ecological Impact Assessment (EcIA) will be completed using the results of the desk study and Extended Phase 1 Habitat Survey completed for the PEcA. This will consider the potential impacts of the detailed design of the proposed solar park on the habitats identified across the site and the protected species which they may support.
Taking into consideration the findings of the Extended Phase 1 Habitat Survey and PEcA, no protected species surveys are proposed, but should the detailed design have the potential to impact upon existing trees located across the site then an arboricultural survey will be completed.
4.4 Cultural Heritage An Archaeological Desk Based Assessment (DBA) has been completed for the proposed Solar Park utilising cartographic, documentary and photographic sources and a site walkover. A geophysical survey of the site has also been completed. Both the Archaeological DBA and the geophysical survey are presented in Appendix D of the PEA. A review of the available baseline evidence shows that the study site has a high potential to contain archaeological remains. The geophysical survey of the study site has revealed the presence of archaeological features which currently remain undated, although a number of these are likely to be Prehistoric in origin. These consist of probable hut circles and an irregular ditched enclosure. Other
findings include field boundaries, trackways and various ditch-like features which may be representative of modern land management practices but could be earlier in origin.
The impact of the proposed development on the study site is likely to be very limited, comprising a total below ground impact of less than 1% of the study site area. The “H”-piles which would be used would result in localised impacts, and no large-scale ground reduction or landscaping is planned.
Despite this, it is recognised that the study site has clear evidence of containing buried remains that are likely to represent occupation features of local to regional significance. While the significance of many archaeological features is largely unaffected by small impacts which would result from a solar farm, occupation sites have the potential to contain more sensitive remains, such as burials and domestic or industrial evidence, whose significance could be degraded. Furthermore, some impacts such as for cable trenches and access roads, can also impact buried remains.
While there is no potential for the operation of the proposed solar park to physically impact on archaeology, once in situ, there is potential for the operation of the solar park to affect designated heritage assets visually. Potential for impacts to such assets within the immediate vicinity of the site will therefore be addressed as appropriate.
Assessment methodology
In addition to the DBA and geophysical survey already completed a Settings Impact Assessment (SIA) will also be undertaken to identify any potential impacts upon designated heritage assets (listed buildings, scheduled monuments or designated sites) within the study area.
Heritage assets and potential impacts will be assessed using best practice, including that set out in the Cadw Setting of Historic Assets in Wales (2017). The heritage assets which require assessment will be selected with reference to Cadw records on designated heritage assets, as well as information held by the LPA on conservation areas and heritage assets. A basic search radius of 5km from the study site boundary will be used to establish which heritage assets required assessment for impacts, which is usually sufficient to ensure all assets which require consideration are properly assessed. The only exception is grade II listed buildings and conservation areas, where a 1km search radius is considered appropriate. The SIA will describe assets which may be affected by the proposed development and will assess the relationship of the study site to those assets.
Not all designated heritage assets within this radius will require full assessment for impacts; where a designated heritage asset has been excluded, a clear justification will be provided, for example if the asset is sufficiently far, and well screened from the study site. Also, not all assets will require the same level of assessment; the level of detail will be sufficient to inform the nature and degree of effect of development within the study area on the significance of the heritage asset in question, as set out in TAN 24 (paragraph 1.15).
The assessment of the overall impact of the proposed solar farm on the significance of heritage assets will be evaluated by taking into account both the heritage significance of the heritage asset and the magnitude of the predicted effect on that significance. To ensure the planning balance is appropriately informed effects are categorised as substantial, medium or low depending on the degree of harm. This results in a spectrum of potential effects on the significance of heritage assets which ranges from no impact up to substantial harm. This spectrum of effects is summarised in Table 4.1, below, along with brief descriptions of the terms used.
Assessments of the level of effect on the significance of heritage assets is based upon the extent to which factors that contribute to the significance of the assets would be affected by the proposed development. This process is not quantitative but relies upon professional judgement at each step. However, the factors considered in informing these judgments and in arriving at the various rankings of value and magnitudes of impacts are observable facts (i.e. numbers of assets, spatial relationships, designations, impacts).
Table 4.1: Criteria for appraisal of level of harm on heritage assets Level of effect Description
Table 4.1: Criteria for appraisal of level of harm on heritage assets Level of effect Description Substantial harm - Total or substantial loss of the significance of a heritage asset. - Harm to a heritage asset through effects to its setting, such that the significance of the asset would be totally lost or substantially reduced (e.g. the significance of a designated heritage asset would be reduced to such a degree that its designation would be questionable; the significance of an undesignated heritage asset would be reduced to such a degree that its categorisation as a heritage asset would be questionable). Medium - Moderate harm to a heritage asset, such that the asset's significance would be materially affected/considerably devalued, but not totally or substantially lost. Low - Low level of harm to the significance of a heritage asset. - This could include the removal of fabric that forms part of the heritage asset, but that is not integral to its significance (e.g. the demolition of later extensions/additions of little intrinsic value). - Low level of harm to the heritage asset’s significance through effects to its setting. Negligible - A change to a heritage asset or its setting that involves no loss of significance or any harm. No Impact - No change to a heritage asset or its setting.
The assessment will be informed by a model Zone of Theoretical Visibility (ZTV) for the surrounding area.
A Landscape and Visual Impact Assessment (LVIA) will also be produced for the study site, in conjunction with this assessment. Taking into consideration the findings of the Landscape and Visual Appraisal, no significant impacts on heritage assets are expected.
In addition, a programme of archaeological works will be completed to inform the detailed design of the proposed solar park. The initial stage of evaluative works have helped define the areas of archaeological interest within the study site and will be followed by a staged programme of archaeological works. The scope of this work will be pre-agreed with relevant consultees and is expected to comprise a programme of trial trenching, targeted on the results of the geophysical survey. This will allow the extent and nature of the remains to be better understood, and will also inform the scope of any mitigation measures. The trenching would be followed by the incorporation of mitigation measures into the detailed design of the proposed development in order to protect the archaeological interest of the buried remains. The mitigation measures could comprise a number of different options, such as:
Exclusion of the areas from development; Use of specialist foundations, such as concrete feet over some areas; and A programme of archaeological mitigation works.
It is considered that despite the potential presence of important archaeological features, a combination of the above measures would allow the archaeological interest of the remains to be secured while enabling the site to be developed.
4.5 Noise and vibration Section 6 of the PEA presents information regarding the potential noise impacts associated with the proposed Solar Park on nearby sensitive receptors.
The assessment concludes that considering the temporary and changing nature of the proposed construction works, the current noise environment, and the distances between the proposed construction activities and noise sensitive receptor locations, the impact of construction noise is not predicted to be significant. PV developments are inherently quiet. Noise emissions from PV plant are limited to noise associated with the inverters and transformers. No significant operational noise impacts are expected due to likely separation distances of this equipment from the limited number of properties that could be affected and inherent mitigation associated with the equipment and the structures in which they are housed. Notwithstanding the above, Wessex Solar Energy would require its construction contractors to minimise the impact of construction activities through successful implementation of an agreed Construction Environmental Management Plan (CEMP).
Assessment methodology
Taking into consideration the findings of the PEA it is not proposed that any background noise measurements will be undertaken for the project as the potential for noise creation and impacts is low.
The preliminary noise assessment will be updated as appropriate to include consideration of any design specific elements which may affect the potential for noise impacts, such as the positioning of inverter/transformer cabins.
4.6 Hydrology, hydrogeology and geology Section 7 of the PEA presents information regarding the potential impacts of the proposed Solar Park on hydrology, hydrogeology and geology of the proposed site and nearby sensitive receptors.
A summary of the PEA findings is detailed below:
Geology and Soils The attribute importance of the underlying geology and soils at the site have both been assessed as medium as they are of varying agricultural value. No mining activities have been proposed for the site and the development of the site is not considered to represent a sterilisation of any mineral assets as all infrastructure proposed for installation will be removed after about 40 years operation. Additionally, although the outline site boundary is approximately 36.9 ha in size, the foundations for the PV panels and electrical buildings will only take up small, localised areas of the site. The disturbance of underlying deposits will be limited to the first 1.5 m. Any impacts will therefore be limited. Impacts on near-surface soils would be within the construction footprint, laydown areas and access roads only. Overall, the construction of the PV panels will have negligible impact on the underlying geology and soils of the site. The significance of effect is deemed potentially slight adverse.
Water Use and Disposal and Hydrology Construction activities on any site may, if uncontrolled, cause changes to surface and water drainage due to: Runoff from stockpiles;
Increased runoff from compacted soils caused by e.g. movement of heavy equipment; Removal of vegetated top soil; The introduction of foundations and cable trenches; and The provision of access tracks. A small amount of water will be required each day for the general construction works and hygiene, which will likely be brought to site by bowser. This water will be required for road construction and also dust suppression/wheel-washing facilities. Nearby surface water quality has the potential to be affected by increased sedimentation if proposed protective measures are not taken. Silt can cause lasting damage to surface water biology and can also build up to cause flooding. The site comprises 8 fields and is likely drained by the tributaries which are located to the south and south west of the site. An ecological assessment of site and its surroundings has not found any notable species of interest although recommendations have been made to minimise any potential ecological impacts. The attribute importance of watercourses has been assessed as medium. The potential impact on this resource has been assessed as minor adverse due to the limited extent of groundworks. Therefore, the overall significance of effect has been assessed as potentially slight adverse. The groundwater beneath the site has been classified as a major aquifer and part of the site is located within a source protection zone 1. Therefore, it has been assessed as being of high sensitivity. There is considered to be a potentially minor impact on groundwater at the site as earthworks are likely to be temporary and limited in extent. Therefore the overall significance of effect has been assessed as potentially moderate adverse. The construction of access tracks, PV panels and the electrical buildings will result in some interception of natural surface water drainage routes. Of these the PV panels cover the greatest area by far, however, the gaps between the panel sections will allow run off to the ground below, such that there will be a negligible impact on groundwater recharge and the volume of run-off flowing into the river draining the site to the south. There is the potential for minor adverse impacts on the major aquifer underlying the site which is or medium to high sensitivity. These potential impacts would result from the interruption to lateral drainage as a result of the installation of the foundations of the electrical buildings and the on-site cable trenches, although no significant issues in this regard are expected. Flooding The Natural Resources Wales Development Advice Map shows that the site does not fall within the Development Advice Zones C1 or C2 (Used to indicate that development can take place subject to application of justification test, including acceptability of consequences). The detailed mapping indicates that the entire site falls outside of the 0.1% flood level and is therefore not as risk of flooding. Despite the above, it is acknowledged that as the development site is over 1 hectare (ha) in area, any application for planning permission must be accompanied by a Flood Consequence Assessment. The findings of the FCA will inform the detailed design of the proposed solar park and will include a sustainable urban drainage system which will ensure that the impact of the development on the runoff from the site will not be significant. The impermeable area introduced across the site will be small and a dedicated drainage network will allow the interception and infiltration of the flows from new areas of hardstanding, further reducing potential impacts upon the surrounding area. The introduction of small amounts of hardstanding and the PV panels onto the site is not anticipated to have a large impact on the overall drainage regime at the site. The access tracks would be permeable and should not have any significant effects on drainage patterns at the site. Therefore, there is not considered to be a risk from flooding at the site or a risk of the development causing flooding to surrounding sites.
Assessment methodology
The preliminary hydrology, hydrogeology and geology assessment will be updated as appropriate to include consideration of any design specific elements which may affect the potential for construction and operational impacts, such as the positioning of the site compound or the need for additional mitigation relating to the increase in surface water run-off. The updated assessment will also be informed by the detailed findings of the Flood Consequence Assessment (FCA).
4.7 Traffic and infrastructure Section 8 of the PEA presents information regarding the potential impacts of the proposed Solar Park on hydrology, hydrogeology and geology of the proposed site and nearby sensitive receptors.
Site access routes for construction traffic would be determined by the source of the materials brought to site. Deliveries are anticipated to approach the site along the A447, turning onto the access road to Lower Nash Farm and entering the site via an existing access point in the south west corner of the south western most field.
These routes are frequently used by large vehicles and the suitability of the access points has been assessed as part of the PEA
Construction of the Solar Park would require the delivery of items of plant and equipment to the site, in addition to the deliveries of aggregate, concrete and Geogrid for the construction of access tracks and foundations for the electrical buildings. The construction phase is expected to require of the order of 582 visits over the 6 month construction period. Additionally, there would be approximately 60 traffic movements per day associated with construction staff during peak periods of construction activity. These traffic movements are not anticipated to have a significant effect on existing traffic levels in the vicinity of site. No construction vehicles would be allowed to deposit mud on the roads with wheel washing facilities used if required. The operational phase of the project would require very few, infrequent visits to site by maintenance staff (approximately two visits every month). These maintenance visits would have a minimal impact on the road network of the surrounding area.
Assessment methodology
Taking into consideration the findings of the PEA it is not considered that a detailed traffic assessment is required for the purposes of the application given the short duration of the construction period and the relatively few construction vehicle movements that would be required.
The preliminary assessment will be updated as appropriate to include consideration of any design specific elements which may affect the potential for construction and operational impacts. This will include details of any improvements to the existing site entrance and consideration of the impacts of these works.
A Construction Traffic Management Plan will be prepared to accompany any planning application which will detail any development specific mitigation measures and restrictions to ensure that there are no unacceptable impacts upon the local road network.
4.8 Environmental Aspects not for further consideration Given the limited environmental impacts associated with the development it is not proposed that any detailed information is provided on the following aspects of the project (some discussion may however be provided where appropriate).
Socio-economics: It is considered that the project will have a beneficial impact with regard to socio-economics in the wider area. The proposed development represents a total investment of the order of up to £13 million in isolation, a proportion of which will be spent in the local area, primarily on civil and electrical contractors.
Air quality: It is not considered that the project will have any significant impacts on air quality in the area during the construction or operational phases. Whilst the environmental report will therefore detail how dust creation during construction and other
such issues will be mitigated it is not proposed that the application includes any substantial discussion of the air quality baseline and other such matters.
4.9 Cumulative Effects The Environmental Report will include a description of the likely significant effects of the development on the environment resulting from ‘existing and / or approved projects, taking into account any existing environmental problems relating to areas of particular environmental importance likely to be affected or the use of natural resources’. The projects which require a cumulative impact assessment will be identified at the time of the report preparation.
Appendix A - Figures