On behalf of

Mynydd Lluest y Graig Wind Farm

-Scoping Report-

March 2014

Mynydd Lluest y Graig Wind Farm, Strategic Search Area B, Powys, Wales

- VATTENFALL -

Scoping Report

Request for a Scoping Opinion under Regulation 8(1) of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009, as amended

March 2014

Mynydd Lluest y Graig Wind Farm Scoping Report

Table of Contents

1 INTRODUCTION ...... 5 1.1 BACKGROUND ...... 5 1.2 THE APPLICANT ...... 6 1.3 PURPOSE OF THE SCOPING REPORT ...... 6 1.4 CONTENT AND STRUCTURE OF THIS SCOPING REPORT ...... 8 2 PLANNING AND ENERGY POLICY CONTEXT ...... 10 2.1 RELEVANT PLANNING POLICY FRAMEWORK ...... 10 2.2 NATIONAL POLICY STATEMENTS ...... 10 2.3 WELSH GOVERNMENT PLANNING POLICY ...... 12 2.4 LOCAL PLANNING POLICY FRAMEWORK ...... 13 2.5 UK AND WELSH RENEWABLE ENERGY POLICY ...... 13 3 DESCRIPTION OF THE POTENTIAL DEVELOPMENT...... 14 3.1 SITE LOCATION ...... 14 3.2 HISTORY OF THE SITE ...... 14 3.3 NATURE AND PURPOSE OF THE PROPOSED DEVELOPMENT ...... 15 3.4 SITE IDENTIFICATION ...... 15 3.5 ACCESS ...... 16 3.6 WIND FARM INFRASTRUCTURE ...... 16 3.7 OUTLINE OF MAIN ALTERNATIVES CONSIDERED TO DATE ...... 19 3.8 DESIGN APPROACH ...... 21 3.9 CUMULATIVE ASSESSMENT ...... 22 3.10 INDICATIVE MITIGATION AND ENHANCEMENT MEASURES ...... 25 4 ENVIRONMENTAL BASELINE FOR THE SITE AND SURROUNDS, METHODOLOGIES AND POTENTIAL SIGNIFICANT ENVIRONMENTAL EFFECTS ...... 26 4.1 INTRODUCTION ...... 26 4.2 LANDSCAPE CHARACTER AND VISUAL AMENITY ...... 27 4.3 RESIDENTIAL VISUAL AMENITY ...... 34 4.4 ECOLOGY AND NATURE CONSERVATION ...... 35 4.5 ORNITHOLOGY ...... 47 4.6 ARCHAEOLOGY AND CULTURAL HERITAGE ...... 53 4.7 NOISE ASSESSMENT ...... 61 4.8 ACCESS TRANSPORT AND TRAFFIC ...... 65 4.9 HYDROLOGY , HYDROGEOLOGY AND GEOLOGY ...... 69 4.10 PEAT ...... 76 4.11 ELECTROMAGNETIC INTERFERENCE (EMI), AVIATION AND SHADOW FLICKER ...... 79 4.12 FORESTRY ...... 81 4.13 SOCIO -ECONOMICS , RECREATION AND TOURISM ...... 86 4.14 SUGGESTED PLANNING ISSUES TO BE SCREENED OR SCOPED OUT ...... 93 5 DRAFT OUTLINE OF THE ENVIRONMENTAL STATEMENT AND OTHER DOCUMENTS ...... 96 5.1 ENVIRONMENTAL STATEMENT ...... 96 5.2 OTHER DOCUMENTS ...... 97

FIGURES

Figure 1: Location of Proposed Mynydd Lluest y Graig Wind Farm

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Figure 2: Proposed Development Consent Order Boundary for the Mynydd Lluest y Graig Wind Farm

Figure 3: Proposed Development Consent Order Boundary in relation to Designated Sites and Planning Boundaries

Figure 4: TAN8 Strategic Search Areas B, C and D and Wind Farms within 35km of the Proposed Development Consent Order Boundary

APPENDICES

Appendices 1-5: Ecology Appendices A1-A5

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1 Introduction

1.1 Background 1.1.1 The Mynydd Lluest y Graig Wind Farm proposal is located in Powys, Wales, to the west of Welshpool and Newtown and between the A458 and A470, as shown on Figure 1. The site is located approximately 3 miles north-east of Talerddig and 2 miles south west of the village of Llanerfyl. 1.1.2 The Proposal site comprises upland grazing land and commercial forestry at its western end and is currently entirely used for farming and forestry purposes. The altitude of the site ranges from approximately 320m to 425m at its highest points at both its eastern and western ends. 1.1.3 The Proposal is considered to constitute a Nationally Significant Infrastructure Project (NSIP), under the definitions set out in Section 14 and 15 of the Planning Act 2008 as it is for an onshore generating station with a capacity greater than 50MW. 1.1.4 The proposed Development Consent Order (DCO) boundary, as shown on Figure 2, lies fully within Strategic Search Area B (SSA B), as defined in the Welsh Government policy document Technical Advice Note 8 (TAN8). TAN 8 sought to define the spatial distribution of large wind farms in Wales and is discussed further in Section 2.3 of this document. 1.1.5 The land contained within the proposed DCO boundary has been the subject of two previous wind farm developments. 1.1.6 The first, located on the land to the east of E299000 was known as Mynydd Waun Fawr and was submitted as a planning application with accompanying Environmental Statement (ES) to Powys County Council (PCC) in 2007 with Supplementary Environmental Information in 2009 – this proposal was withdrawn from the planning system in July 2013. 1.1.7 The second, located on the land to the west of E299000 was known as Rhyd Ddu and although never submitted as a planning application was subject to a Scoping exercise and ensuing Environmental Impact Assessment (EIA) works in 2009. 1.1.8 Accordingly, a substantial level of understanding of the site's environmental characteristics exists from prior survey although it is not thought that this will negate the need for further original survey specific to the current Proposal.

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1.1.9 Additionally, due to its central location within SSA B, there are a number of neighbouring wind farm proposals both within the planning system and consented, and so a large amount of environmental information exists within the public domain pertaining to the wider area.

1.2 The Applicant 1.2.1 The Applicant is Vattenfall Wind Power Ltd (Vattenfall). Vattenfall is registered in England (company number 06205750) and forms part of the Vattenfall Group, the ultimate parent company of which is Vattenfall AB, a Swedish public limited liability company owned by the Swedish state. The Vattenfall Group has a significant track record in the development and operation of wind farms in both the onshore and offshore sectors. The company works in all parts of the energy value chain; from generation through to distribution and sales, the Vattenfall Group currently operates 545MW of onshore wind capacity and 836MW of offshore wind across northern Europe. 1.2.2 Vattenfall is committed to meeting society’s need for energy in a responsible and sustainable manner. Vattenfall operates and invests in energy solutions that support sustainable development: economically, environmentally and socially. 1.2.3 Many stakeholders have very high expectations of Vattenfall, and they often represent varying interests and conflicting needs. Listening to, understanding, and balancing the varied and sometimes conflicting priorities of different stakeholders is a core part of Vattenfall’s corporate social responsibility, and interaction with stakeholders is an on-going process in almost every part of Vattenfall’s operations. 1.2.4 Vattenfall has appointed an independent renewable energy specialist consultancy, Dulas Ltd., to advise them on the scope of EIA work and environmental issues, draw up preliminary conceptualisations of the proposed wind farm, and to provide sufficient environmental information to enable the formulation of an Environmental Statement which will accompany an application for development consent for the Proposal.

1.3 Purpose of the Scoping Report 1.3.1 This Scoping Report supports a request for a Scoping Opinion to the Major Applications and Plans Directorate of the Planning Inspectorate under

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Regulation 8(1) of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (hereinafter referred to as ‘the Regulations’), as amended. This Scoping Report presents relevant provisional information which describes the location and nature of the development, and the potential significant environmental issues that may arise from the construction, operation and decommissioning of the proposed wind farm scheme. The formulation of this information has been guided by the requirements set out in Regulation 8(3) and (4) of the Regulations and with respect to Advice Note 7: Environmental Impact Assessment: Screening and Scoping, published in April 2012 by the Planning Inspectorate. 1.3.2 Advice note 7 sets out that a scoping report should contain the following information: o an outline of the main alternatives considered and the reasons for selecting a preferred option; o results of desktop and baseline studies where available; o guidance and best practice to be relied upon, and whether this has been agreed with the relevant bodies (for example the statutory nature conservation bodies or local authorities) together with copies of correspondence to support these agreements. It would also be helpful to provide the additional information described above in section 3 of this advice note; o methods used or proposed to be used to predict impacts and the significance criteria framework used; o any mitigation proposed and predicted residual impacts; o where cumulative development has been identified, how the developer intends to assess these impacts in the ES (for example, a high level review of the grid connection where this does not form part of the NSIP proposal for a power station); o an indication of any European designated nature conservation sites that are likely to be significantly affected by the proposed development and the nature of the likely significant impacts on these sites; o where a developer seeks to scope out matters, a full justification for scoping out such matters, preferably supported by evidence of agreement with the

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relevant bodies (it would also be helpful if the matters to be scoped out could be presented in a table format); o key topics covered as part of the developer’s scoping exercise; and o an outline of the structure of the proposed ES. 1.3.3 The purpose of this Scoping Report is to inform the Planning Inspectorate and Statutory Consultees on relevant aspects of the proposal prior to the formulation of a formal Scoping Opinion. The information contained herein is indicative only and several iterative alterations to the design and layout of the proposed wind farm are likely to be considered before they are finalised prior to completion of the application documentation. 1.3.4 It is stressed that this is an early stage in the project development and therefore only brief technical details and a provisional site boundary are provided. This is to allow comment and feedback from consultees, together with information from the environmental assessment, to guide the most appropriate design and layout of a wind farm at this location. 1.3.5 The Scoping Opinion anticipated to be provided by the Planning Inspectorate will be used to inform the scope and focus of the Environmental Impact Assessment for the proposed NSIP.

1.4 Content and Structure of this Scoping Report 1.4.1 On the basis of the information requirements set out in paragraph 1.3.2 above, this Scoping Report presents the following information and data on the site, its environs and potential effects. 1.4.2 Section 2 provides a brief overview of the relevant planning policies including the relevant National Policy Statements, devolved Welsh Government planning policy, and details of the local planning authority’s relevant development plan. 1.4.3 Section 3 provides an overview of the proposal, including a brief description of the nature and purpose of the proposed development. In addition an outline of the main alternatives considered and an explanation of preferred options is presented, where available. 1.4.4 Section 4 describes the baseline environment in and around the potential development area and an outline of the potential significant effects of the development along with any potential mitigation measures already identified. The principal environmental disciplines that are likely to be addressed are explained, along with proposed methodologies of assessment, relevant

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guidance and best practice guidelines. This includes how potential cumulative effects will be addressed. Any potential effects to European designated nature conservation sites will be described. Further, any matters that the Applicant believes should be scoped out will be presented, resulting in the definition of the key topics to be addressed as part of an EIA. 1.4.5 Section 5 sets out a description of the proposed structure of the Environmental Statement (ES). 1.4.6 Figure 1 shows the location of the site of the proposed development and Figure 2 demonstrates the proposed DCO boundary, while Figure 3 shows the proposed DCO boundary in relation to Designated Sites and Planning Boundaries. It should be noted that the proposed DCO boundary is currently indicative and may be refined during the EIA and consultation processes. 1.4.7 Figure 4 indicates the other wind farm developments within a 35km radius of the proposed DCO boundary and their status.

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2 Planning and Energy Policy Context

2.1 Relevant Planning Policy Framework 2.1.1 The relevant planning and energy policy framework which will be set out in the ES will include: o Overarching National Policy Statement (NPS) for Energy (EN-1); o NPS for Renewable Energy Infrastructure (EN-3); o Relevant UK and Welsh Government renewable energy policy; o Relevant national planning policy produced by the Welsh Government (WG); and o Relevant provisions of the applicable statutory Development Plan and any relevant Supplementary Planning Guidance. 2.1.2 Relevant aspects of the NPSs, which will inform the EIA process, are referred to below as are key aspects of other relevant policy documents. The relevant aspects of the above documentation will be set out fully within the ES and a referenced in more detail under some of the topic based headings within Section 4 of this document.

2.2 National Policy Statements NPS EN-1 2.2.1 For NSIP projects it is stated within paragraph 1.1.1 of NPS – EN1 that “this NPS, when combined with the relevant technology – specific energy NPS, provides the primary basis for decisions by the Infrastructure Planning Commission (IPC)”. 2.2.2 Part 3 of the NPS sets out the need for new nationally significant energy infrastructure projects (NSIPs). 2.2.3 With regard to the urgency of the need, Paragraph 3.3.15 sets out that “in order to secure energy supplies that enable us to meet our obligations for 2050 there is an urgent need for new (and particularly low carbon) energy in NSIPs to be brought forward as soon as possible…..” . 2.2.4 Paragraph 3.4.3 identifies that “future large – scale renewable energy generation is likely to come from the following sources:- 2.2.5 Onshore Wind – Onshore Wind is the most well established and currently most economically viable source of renewable electricity available for future large- scale deployment in the UK“

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2.2.6 Part 4 of NPS EN-1 refers to assessment principles and states at Paragraph 4.1.2 that “given the level and urgency of need for infrastructure of the types covered by the energy NPS’s set out in part 3 of this NPS, the IPC should start with a presumption in favour of granting consent to applications for energy NSIPs that presumption applies unless any more specific and relevant policies set out in the relevant NPSs clearly indicate that consent should be refused” . 2.2.7 Paragraph 4.1.4 acknowledges that the IPC should take into account environmental, social and economic benefits and adverse impact, at national, regional and local levels. 2.2.8 In terms of grid, paragraphs 4.9.2 and 4.9.3 are relevant and the Applicant will adhere to this advice in providing their assessment of the potential grid connection. NPS EN-3 2.2.9 The role of NPS EN-3 is described at paragraph 1.2.1 of the document. It states: “This National Policy Statement (NPS), taken together with the Overarching National Policy Statement for Energy (EN-1), provides the primary basis for decisions by the Infrastructure Planning Commission (IPC) on applications It receives for nationally significant renewable energy infrastructure…”. 2.2.10 The ‘Onshore Wind’ technology specific section of EN-3 (part 2.7) identifies what it terms as ‘key considerations’ that influence the siting of onshore wind farms. These are listed as: o Predicted wind speeds; o Proximity of site to dwellings; o Capacity of a site; o Electricity Grid connection; and o Access. 2.2.11 In terms of technical considerations, these are listed as including: o Access tracks; o Project lifetimes; o Flexibility in the project details; o Micrositing; and o Repowering.

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2.2.12 In terms of potential on-shore wind farm ‘impacts’ EN-3 sets out a number of ‘impact assessment principles’; which are summarised by topic as follows and will inform the EIA process: o Biodiversity and geological conservation: collision risk with bats and birds, impact on peat, habitat disturbance and matters specified in Section 5.3 of EN-1; o Historic Environment: direct and setting impacts on heritage assets giving due consideration to temporary effects. Section 5.8 of EN-1 to be considered; o Landscape and Visual: acceptance of significant landscape and visual effects, minimise effects within parameters of technical and operational siting, residential impact and requirements of Section 5.89 of EN-1 to be considered; o Noise and Vibration: refers to detailed policy advice in Section 5.11 of EN-1 and recommends the use of ETSU-R-97 for the assessment of wind turbine operational noise; o Shadow Flicker: generally occurs within 10 rotor diameters and assessments required within this distance. Shadow flicker dependent on wind speed, cloud cover and wind direction; and o Traffic and Transport: Refers to general policy advice within Section 5.13 of EN-1, requires assessment of traffic impact on routes, including bridges, and the identification of required route improvements. Cumulative transport impacts may also require to be considered. 2.2.13 In terms of grid, policy advice is provided in addition to that within EN-1 at paragraph 2.7.8 and as above the Applicant will have regard to this.

2.3 Welsh Government Planning Policy Technical Advice Note 8 2.3.1 Technical Advice Note 8: Planning for Renewable Energy (TAN 8) was published in 2005 and provides technical advice to supplement Planning Policy Wales. TAN 8 provides Strategic Search Areas (SSAs) for wind energy development in Wales, each with indicative development capacities. The proposed development is located within SSA B. Significant landscape effects are recognised as the inevitable consequence of Tan 8.

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2.3.2 Whilst TAN 8 is clearly a relevant consideration, the Applicant will follow the approach taken by the Inspector at para 4.171 (3rd bullet) of his report on the Brechfa wind farm NSIP where he confirms that "While TAN8 is a relevant material consideration the main policy considerations are the national policy statements (NPS EN-1 and NPS EN-3) which identify the need for additional capacity". Other Policy 2.3.3 Other Welsh Government planning and energy policy that will be taken into account through the EIA process will include Planning Policy Wales (PPPW) Edition 6 (2014) and Practice Guidance: Planning Implications of Renewable and Low Carbon Energy Development (February 2012).

2.4 Local Planning Policy Framework 2.4.1 In terms of the local planning policy framework, the proposed development is located within the administrative area of Powys County Council. The Powys County Council Development Plan consists of: o The Powys Unitary Development Plan 2001 - 2016 (adopted 2010) 2.4.2 Powys County Council is also in the process of preparing a Local Development Plan and it is expected that a deposit plan will be published in the summer of 2014. 2.4.3 The EIA process will take account of the relevant provisions of the above plans, read in the context of the NPSs referred to above.

2.5 UK and Welsh Renewable Energy Policy 2.5.1 There are a number of policy statements at the UK and Welsh Government levels that are of relevance to the delivery of renewable energy development. Such policy statements are not of core relevance to EIA beyond setting the framework for the need case for renewable energy development (as noted above, need is further clarified within NPS EN-1). The EIA will make appropriate reference to the full suite of UK and Welsh renewable energy policy.

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3 Description of the Potential Development

3.1 Site Location 3.1.1 The Mynydd Lluest y Graig Wind Farm proposal is located in Powys, Wales, to the west of Welshpool and Newtown and between the A458 and A470, as shown on Figure 1. 3.1.2 The Proposal is largely comprised of upland grazing land with commercial forestry at its western end and is currently entirely used for farming and forestry purposes. The altitude of the site ranges from approximately 320m to 425m at its highest points (at both the eastern and western ends). The upland landscape comprises a mix of areas of open moorland, mixed and mono crop coniferous forestry, marshy grassland, wet modified bog and improved agricultural grazing land. 3.1.3 The closest large towns to the Proposal are Welshpool, approximately 16km to the east, Newtown, approximately 15km to the south east and Machynlleth approximately 18km to the west (distances to proposed DCO boundary). 3.1.4 The closest villages to the Proposal are Llanerfyl and Talerdigg, both approximately 5km from the site centre to the south west and north east respectively. Numerous other villages and hamlets lie within 10km of the proposed DCO boundary, mostly located along and around the A458 and A470. 3.1.5 In terms of human settlement the area immediately around the proposed DCO boundary is characterised by isolated dwellings and farmhouses located on, or accessed from, the minor C class road network, the primary spine of which is the C2031 running between Llanerfyl and Talerdigg. 3.1.6 As with the land within the proposed DCO boundary, the land within 10km of this is largely given over to grazing land and commercial forestry, the latter owned both privately and by the Forestry Commission.

3.2 History of the Site 3.2.1 The land at Mynydd Lluest y Graig has been considered by the Vattenfall Group as a potential area for wind farm development since 2004. The land contained within the proposed Development Consent Order (DCO) boundary has been the subject of two previous wind farm proposals. These previous wind farm development opportunities were explored by Nuon UK Ltd, another company within the Vattenfall Group.

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3.2.2 The first, located on the land to the east of E299000 was known as Mynydd Waun Fawr and was submitted as a planning application with accompanying Environmental Statement (ES) to Powys County Council (PCC) in 2007 with Supplementary Environmental Information in 2009 – this proposal was withdrawn from the planning system in July 2013. 3.2.3 The second, located on the land to the west of E299000 was known as Rhyd Ddu and although never submitted as a planning application was subject to a Scoping exercise and ensuing Environmental Impact Assessment (EIA) works in 2009. 3.2.4 In 2013 the Applicant took the decision to merge both sites into Mynydd Lluest y Graig Wind Farm proposal and to progress this as a Nationally Significant Infrastructure Project (NSIP).

3.3 Nature and Purpose of the Proposed Development 3.3.1 The proposed wind farm would generate renewable electricity from wind power. Wind power, in contrast to many other conventional forms of electricity generation, does not produce waste, emissions to air, or contribute to global environmental problems, and has the potential to reduce carbon dioxide (CO2) emissions through the displacement of fossil fuel derived generation. 3.3.2 The potential wind farm scheme, if installed, would provide benefits in respect of: o bringing about reductions in greenhouse gases associated with conventional power plant; o contributing to renewable energy targets; o installing a diverse energy generation plant which supports the security of UK embedded power production; o allowing a useful income stream to the landowners thereby diversifying the activities on the farms; and o providing regional and local economic and community benefits.

3.4 Site Identification 3.4.1 As described in section 3.2, the Mynydd Lluest y Graig Wind Farm has been formed by the amalgamation of two earlier wind farm proposals.

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3.4.2 The Applicant identified both these sites through an earlier site selection process which sought to avoid areas of high environmental sensitivity whilst choosing sites which are technically, environmentally and economically viable. 3.4.3 Detailed desktop studies informed the initial understanding of technical and environmental constraints that were then examined further in a series of site visits and meetings with landowners and a range of interested stakeholders to inform preliminary wind farm designs for Mynydd Waun Fawr. In 2007 Nuon UK Ltd began assessing neighbouring land at Rhyd Ddu for wind farm suitability adopting the same methodology and both sites were taken forward into development as separate sites. 3.4.4 The site falls within the boundary of Strategic Search area B (SSA B) as identified within TAN8 in 2005 and within the revised SSA B boundary identified by Arup in 2008 and as such spatial planning policy has influenced the site identification process.

3.5 Access 3.5.1 Currently it is proposed that wind turbine components would be delivered using specialist delivery vehicles from a port to the north, either Ellesmere or Liverpool and transported to the site using the agreed Renewable UK Cymru Strategic Transport Route via the M53, A55, A483, A5, A483 and A458. 3.5.2 Access from the A458 will be examined in detail and the optimum solution presented in the application for a Development Consent Order as integral to the proposed Mynydd Lluest y Graig scheme. They will also be assessed within the ES. 3.5.3 A full route review will be undertaken and the details included within the application documents.

3.6 Wind Farm Infrastructure 3.6.1 It is currently expected that three bladed horizontal axis machines wind turbines with a power rating of up to 3.5MW could be used at this site and that the wind farm could comprise up to 35 turbines, with an installed wind farm capacity of up to 122.5MW. The turbine parameters to be used for the purposes of the assessment assume a hub height in the region of 80m and a rotor diameter of up to 104m; an overall blade tip height envelope of up to 135m is assumed.

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3.6.2 Other infrastructure items which are expected to be included are: o turbine foundations; o crane hard-standing areas at each turbine location; o associated low to medium voltage transformers at each turbine; o a series of on-site tracks; o a network of buried electrical cables (likely to follow the route of on-site tracks); o a sub-station compound containing a control building and outdoor equipment including high voltage transformer and switchgear; o 2 free-standing meteorological masts; o borrow pits (for the extraction of stone on site); and o temporary construction compounds. 3.6.3 Turbine foundations will be formed in excavations up to 3m deep, depending upon localised ground conditions and the depth to suitable load bearing ground. They will be steel reinforced octagonal tapered concrete foundations up to 21m diameter. Prior to excavation, topsoil (and in particular peat, where this is present) and existing vegetation will be lifted and carefully stored. After completion of the foundation works, they will be backfilled with excavated material and vegetation will be reinstated. 3.6.4 It is likely that the concrete for turbine foundations and other site infrastructure will be brought in from off-site being sourced as locally as possible; on-site concreting batching will be considered. 3.6.5 Crane hardstandings are required to provide a stable bearing surface for the mobile cranes required for turbine erection. Two cranes are typically used and the hardstanding specifications vary between turbine manufacturers; however they will typically require an area of approximately 45m by 25m and are formed by excavating and infilling with compacted stone. 3.6.6 Existing tracks within the proposed DCO boundary will be utilised wherever reasonably practicable for construction and on-going turbine access and servicing after commissioning. New and upgraded tracks will provide the required access between the site entrance, turbines and the other infrastructure. They will typically have a running width of 5m with widening at corners and will have turning heads and passing places where required. Track verges will be reinstated after construction.

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3.6.7 Transformers are required to increase the voltage at which the turbines generate (typically 690V) to 33kV in order to prevent excessive losses in the on- site cabling. The transformers can either be located within the turbine or externally in cabins at the base of the turbine, dependent upon the specific turbine installed. 3.6.8 The turbines will be connected to the site sub-station by means of 33kV on-site cabling. These cables will be laid underground in trenches, in most cases running adjacent to the site tracks; in the same manner as the foundations these trenches will be backfilled with excavated material and have the original vegetation reinstated. 3.6.9 The 33kV electrical cabling will terminate at the site sub-station compound, comprising switchgear and transformers to increase the voltage to 132kV for export on the electricity network owned by the Distribution Network Operator (DNO). 3.6.10 The area required for the onsite sub-station will be in the region of 75m x 75m and will accommodate a control building and basic welfare facilities. Typically the control building will be approximately 30m x 15m x 7m high and finished in an appropriate vernacular design. 3.6.11 The 2 free-standing meteorological mast(s) will be of a steel lattice construction and will accommodate anemometers and wind direction vanes at various heights up to and including the turbine hub height. 3.6.12 Borrow Pits will be required to provide stone for various purposes, but primarily track and hardstanding construction. The number and size of borrow pits will be determined through site investigation and, within the constraints of acceptable environmental impact and available stone quality, the Applicant will endeavour to source adequate stone for construction purposes from within the proposed DCO boundary. 3.6.13 Temporary construction compounds will be required to house temporary portacabins to be used for site offices and welfare facilities; store fuels, tools, small parts and materials required during construction; provide parking space for cars and construction vehicles and a receiving area for incoming vehicles; and refuel construction vehicles. The largest of these will be up to approximately 75m x 50m, although the majority will be smaller than this.

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3.6.14 The location of all infrastructure will be clearly identified for the DCO application in the form of suitably detailed plans with grid coordinates for each element, and unless particular environmental or technical constraints dictate otherwise, a micrositing tolerance of up to 50m will be sought. 3.6.15 The construction period is likely to be up to 30 months, including time required for felling and for ground clearance and preparation. The principal construction activities (in likely order of works) will include, but not be limited to, the following: o Highway improvement works; o Felling; o Site entrance construction; o Construction of temporary construction compound(s); o Existing track upgrades and new track construction; o Construction of turbine foundations and associated hardstandings; o Construction of onsite substation and associated control building; o Construction of meteorological mast(s); o Cable laying; o Delivery and erection of wind turbines; o Connection of electrical cables; o Commissioning of site equipment; and o Site demobilisation and restoration. 3.6.16 Some activities will be carried out concurrently in order to reduce the construction time period where possible, and restoration will be carried out as early as the construction process allows. 3.6.17 A clear indication of the overall construction period, and that of the component activities outlined above, will be provided in the ES.

3.7 Outline of Main Alternatives Considered to Date 3.7.1 Prior to commencing proposals at both of the separate sites (Mynydd Waun Fawr and Rhyd Ddu), Nuon UK Ltd undertook national and regional scale site finding exercises and considered a large number of potential sites. Mynydd Waun Fawr and Rhyd Ddu, along with a number of other sites across the UK were selected on the basis of the site selection process described in Section 3.4 and expanded upon below:

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Step 1 - Desktop Work 3.7.2 In 2003 Nuon UK Ltd acquired an interest in a large number of potential wind farm sites across England and Wales. In order to assess the suitability of these sites and to identify other potential sites a Geographical Information System (GIS) based methodology was developed. A specific GIS was built up which incorporated a large number of constraints to wind farm development, which were mapped on a county by county basis. This included environmental constraints to development such as national and international designated areas, housing and roads. Technical constraints included the necessary wind speed threshold for economic viability, exclusion of areas with unacceptably steep slopes, proximity to a viable grid connection point, proximity to microwave links, and likelihood of interference with Ministry of Defence and Civil Aviation Radar. The resulting output provided locations that fitted this set of technical criteria and were situated away from areas with specific environmental constraints. Any sites which did not meet these criteria were rejected. Mynydd Waun Fawr is a potential site whose suitability as a wind farm has been considered since 1995. Step 2 - Site Visit 3.7.3 Nuon UK Ltd contacted the key landowners to determine their interest in a wind farm development and to enable a site visit to further verify the desktop research. The initial site visit confirmed that the local topography of the area is such that the majority of settlements are located within narrow, steep sided valleys that may restrict the number of views to a potential wind farm at the site. Furthermore the initial site visit was used to confirm the absence of a relatively high number of properties in close proximity as well as the feasibility of accessing the site from the trunk road network. Initial findings were then examined in more detail and initial designs were worked through to provide an indication of likely wind farm size and the theoretical zones of visibility that a potential wind farm may have on receptors such as the Snowdonia National Park. Step 3 – Initial Consultation 3.7.4 Nuon UK Ltd met with the relevant planning authority to discuss the Mynydd Waun Fawr site and to seek further information on local policy and political constraints which may affect likely planning success.

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Step 4 – Policy Direction 3.7.5 In 2005 the Welsh Assembly Government (WAG) issued TAN 8 Planning for Renewable Energy. This document provides national planning policy guidance for the consideration of renewable energy schemes in Wales. It places emphasis upon the development of on-shore wind farms to increase the proportion of renewable energy generated in Wales and it identifies seven Strategic Search Areas (SSAs) where major wind farms (those defined as being of 25MW or over) should be located. The SSAs are considered to be relatively unconstrained with availability of existing or planned electrical grid infrastructure; Mynydd Waun Fawr is located within Area B, Carno North. The identification of the Carno North Strategic Search Area was considered to reinforce the site selection process undertaken by Nuon UK Ltd in the identification of the site. Step 5 – Project Development 3.7.6 As a result of the criteria based assessment, initial consultation and publication of TAN 8 Nuon UK Ltd concluded that the site provided suitable scope to design a project that would make a substantial energy contribution without compromising the local environment and recreational amenity of the area. Rhyd Ddu 3.7.7 Following the development work undertaken at Mynydd Waun Fawr and interaction with that project’s landowners, the opportunity to develop a further wind farm at Rhyd Ddu arose in 2007. Appraisal of the potential for a wind farm at Rhyd Ddu generally followed the same process as outlined above. 3.7.8 The decision to combine both sites was made in 2013, with the aim of reducing cumulative impact and maximising community benefit.

3.8 Design Approach 3.8.1 During the development phase of a wind farm Vattenfall works within the framework of a Design Process. This process ensures that information relating to the site, such as environmental or technical constraints are taken into account when finalising the wind farm for the design freeze, prior to an ES being drafted. 3.8.2 The Design Process necessitates that information is gathered from the relevant experts, such as civil and electrical engineering, wind resource, GIS, financial, aviation, generation, communications and health and safety. Typically these experts will be in-house, but this does not have to be the case. In addition,

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experts from other fields will contribute information relating to the site conditions and potential impacts. These experts would include, but may not be limited to, the disciplines of ecology, ornithology, hydrology, cultural heritage, noise and landscape and visual. 3.8.3 In addition to the internal Design Process inputs outlined above there will be ongoing dialogue with external stakeholders whose considerations may also influence some aspects of the wind farm design and be accounted for as part the Design Process. 3.8.4 During the Design Process there may be a number of iterative steps that enable the information collected on the project to influence the design decisions. Initially constraints will be collected in a GIS database and a preliminary desktop design and a wind farm layout will be generated. Subsequently, EIA baseline survey work will be conducted and, at a suitable point, a Design Workshop will be arranged with the disciplines outlined in 3.8.2 attending. Each specialist will present the constraints that exist on the site which they have determined by survey and an agreement will be reached as to how the constraints will be dealt with in the design. The result of this process is a new wind farm layout. 3.8.5 Additional Design Workshops will be undertaken as necessary (though usually no more than two or three, sometimes involving external stakeholders as appropriate) until a Design Freeze is reached. Responses to consultation of both a non-statutory and statutory nature will also be used to inform the design evolution. 3.8.6 At Design Freeze, the wind farm layout will be fixed for the purpose of the final environmental assessments and planning application. It will specify wind turbine positions, wind turbine design envelope (dimensions and noise characteristics), site road alignments, and all other associated infrastructure locations identified, such as water crossing points, temporary compound(s), borrow pits, met mast(s), control building and sub-station etc., as required.

3.9 Cumulative Assessment Wind Farms 3.9.1 As noted in paragraph 1.1.4 and 1.1.9 the Proposal is located with SSA B and there are a large number of wind farms, both within the planning system, consented and operational, with which cumulative effects could reasonably be expected to occur.

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3.9.2 Figure 4 shows the other wind farm developments currently within a 35km radius of the proposed DCO boundary and their operational status. It can be seen from Figure 4 that there are a significant number of wind farms currently within the consenting process in or around SSAs B, C and D and in operation within the counties of Powys, Ceredigion and Gwynedd. These wind farm developments are listed below:

Number of Hub Height Tip Height Wind Farm Status Turbines (m) (m) Braich Ddu Farm Operational 3 60 90 Bryn Titli Operational 22 30 48.5 Bryn Titli Extension Design/Scoping 12 Unknown Unknown Bryngydfa Application Submitted 12 80 126.5 Carnedd Wen Conjoined Inquiry 50 90 137 Carno I Operational 56 31.5 54 Carno II Operational 12 49 80 Carno III Application Submitted 18 80 126.5 Cefn Croes Operational 39 55 90 Cemmaes 2 Operational 18 40 66 Cemmaes 3 Appeal/Public Inquiry 12 80 115 Dyfnant Forest Design/Scoping 32 100 145 Esgair Cwmowen Application Submitted 18 80 125 Garreg Lywd Hill Appeal/Public Inquiry 23 80 126.5 Hirddywell Application Submitted 9 80 125 Llaithddu Conjoined Inquiry 27 80 115.5 Llanbadarn Fynydd Conjoined Inquiry 17 80 126.5 Llanbrynmair Conjoined Inquiry 30 80 126.5 Llandinam Operational 103 31 45.5 Llandinam Repowering Conjoined Inquiry 34 80 121.2 Mynydd Clogau Operational 17 40 66 Mynydd Gorddu Operational 19 33 50 Mynydd Mynyllod Design/Scoping 24 Unknown 145 Mynydd y Gwynt Design/Scoping 27 80 125 Nant y Moch Design/Scoping 62 100 146.5 Neuadd Goch Bank Application Submitted 9 80 126 Rheidol Operational 8 45.5 45.5 Tirgwynt Consented 12 70 116

3.9.3 Five of these proposals are currently being determined within the Mid Wales (Powys) Conjoined Wind Farms Public Inquiry, while a number of others are the subject of applications to Powys County Council under the Town and Country

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Planning Act and three others are large enough to qualify as NSIPs but are not yet subject to determination. 3.9.4 In addition, there are ten existing wind farms within 35km of the proposed DCO boundary and one of the wind farms (Tir Gwynt) has planning consent from PCC but has yet to be built. 3.9.5 It is apparent that a complex cumulative wind farm landscape exists in planning and EIA terms which will evolve during the development and EIA stages of the Mynydd Lluest y Graig Wind Farm proposal prior to application for a DCO. 3.9.6 With this in mind, the Applicant intends to keep abreast of all relevant wind farm development within Powys, Ceredigion and Gwynedd as described in paragraphs 3.9.9 and 3.9.10 and reflect the current cumulative situation accurately within the final DCO and ES submission. 3.9.7 In order to be able to do this effectively the Applicant will seek to agree with the relevant consultees a cut-off date beyond which no further developments (e.g. revision to layouts, refusal, granting of consent, etc.) amongst other wind farms will be taken into account within the cumulative assessments of the various relevant chapters of the ES. 3.9.8 The way in which cumulative assessment will be dealt within each ES chapter is described in the relevant sub-sections of section 4. 3.9.9 The status of wind farms (operational, consented, subject to application for consent or other) which are considered to be relevant to the cumulative assessment for the Landscape and Visual Assessment are provided in 4.2.22 - 4.2.24 and the exact details (turbine numbers and their location, tip and hub heights) will be sourced from public domain documents where available and other wind farm developers where required. 3.9.10 Wind farms relevant to the cumulative assessment for other disciplines (e.g. noise) will be drawn from the same list, although are likely to be more limited in number, being more localised to the proposed DCO boundary. Other Grid Infrastructure 3.9.11 The grid connection for this proposal will not be included within the application for a Development Consent Order (DCO) for the Mynydd Lluest y Graig Wind Farm. Obtaining the consent for the grid connection will be the responsibility of the relevant DNO, Scottish Power Energy Networks (SPEN).

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3.9.12 In addition, National Grid (NG) are currently proposing a new transmission line and associated hub sub-station, currently envisaged to be located approximately 2km to the south of the proposed DCO’s southern boundary, and to which SPEN will connect the majority of the currently proposed wind farms in SSAs B, C and D which proceed to construction. 3.9.13 The Applicant will be mindful of both the SPEN and NG proposals and present information based on the most contemporary information available at the time the ES and DCO documentation is prepared. A high level cumulative assessment of these proposals in relation to the Mynydd Lluest y Graig Wind Farm will be provided within the ES.

3.10 Indicative Mitigation and Enhancement Measures 3.10.1 Mitigation will, in the first instance, be inherent in the iterative design process followed during the Environmental Impact Assessment. Historic data from the previous proposals and new baseline data will provide constraints to the location of all wind farm infrastructure. This, along with the technical constraints and requirements of the wind farm, will be used to reposition each of the wind farm infrastructure elements described in Section 3.6 to reduce environmental impacts as required. The relative importance of each environmental constraint will be balanced with other salient issues, such as the ability to develop designs which can be constructed safely, and detailed proposals discussed with the relevant consultees in order to arrive at a final design which minimises environmental impacts as far as is reasonably possible. 3.10.2 Where significant environmental impacts are still predicted to occur, site specific mitigation techniques, consistent with industry best practice will be developed in order to mitigate these. Some indication of the form these may take are presented in the relevant paragraphs of Sections 4.2 - 4.13 3.10.3 In addition to these currently broad, but later detailed, forms of relevant mitigation, pertinent environmental enhancement programmes will be developed in conjunction with consultees that will seek to provide a net environmental benefit to the assets within the proposed DCO boundary.

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4 Environmental Baseline for the Site and Surrounds, Methodologies and Potential Significant Environmental Effects

4.1 Introduction 4.1.1 This Section presents overview details of the general environmental characteristics of the site and its surrounds. Such baseline details are drawn from the previous studies into the site. Arising from the identification of the baseline factors, the principal environmental disciplinary matters are identified that have the potential to be significantly affected by the proposed development. A description of the methods to be employed in the assessment of potential significant effects is presented, along with details of any salient guidance or best practice in addressing and mitigating such effects. 4.1.2 This Section is also structured to present the general approach to surveys to establish the environmental baseline for the site area, the typical impacts associated with this form of development (during the construction, operation and decommissioning phases of the Proposal) and how predictions of effect are to be undertaken. Information is also provided on initial features or sensitivities that may be relevant to each environmental discipline e.g. landscape, ecology etc. It is proposed that the methodologies of assessment to be applied would follow those typically used for wind energy schemes details of which are presented under each heading. 4.1.3 Each ES assessment chapter will seek to predict the potential impacts of the Proposal during the construction, operation and decommissioning phases and will identify robust mitigation for such potential impacts as and when appropriate. As well as identifying likely significant impacts, each will set out whether those impacts are positive or adverse, and explain how these conclusions are arrived at. 4.1.4 Each section of the ES will have regard to the relevant sections of Part 5 (Generic Impacts) of EN 1, and Part 2 (Assessment and technology-specific information) of EN 3 in particular and relevant planning policy as detailed in Section 2 of this report.

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4.2 Landscape Character and Visual Amenity

Introduction 4.2.1 A Landscape and Visual Impact Assessment (LVIA) of the Mynydd Lluest y Graig Wind Farm will be conducted by LDA Design. Having undertaken feasibility studies and LVIAs for approximately 150 proposed wind farm developments, LDA Design has considerable experience in the assessment of wind energy developments, including a number of projects in Wales, and an involvement in the Mid Wales SSA C Public Inquiry (PI). 4.2.2 The landscape and visual assessment will define the existing landscape and visual baseline environments; assess their sensitivity to change; describe the key landscape and visual related aspects of the proposed development; describe the nature of the anticipated change upon both the landscape and visual environments; and assess the magnitude and significance of the changes for the construction, operational and decommissioning stages. A study area of 30km radius from the site boundary is proposed with a wider cumulative search area to be agreed with the statutory consultees and informed by a detailed zone of theoretical visibility (ZTV) for the proposed wind farm. 35km is suggested as agreed previously with PCC for the Mid Wales PI. 4.2.3 In summary the landscape and visual assessment will: o Be carried out in accordance with established methodology and guidance; o Focus on where significant effects are likely to occur; and o Establish the extent and importance of potentially significant landscape and visual effects.

Published Guidance and Approach 4.2.4 The LVIA will follow recognised best practice including: o Landscape Institute and Institute of Environmental Management and Assessment (2013) Guidelines for Landscape and Visual Impact Assessment (3rd Edition) Spon Press. (GLVIA 3); o NRW (2013) LANDMAP Guidance note Guidance for Wales Using LANDMAP for Landscape and Visual Impact Assessment of Onshore Wind Turbines; o Scottish Natural Heritage (2006) Visual Representation of Windfarms: Good Practice Guidance*;

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o Landscape Institute (2011) Advice Note 01/11: Photography and Photomontage in Landscape and Visual Assessment; o Landscape Character Assessment Guidance for England and Scotland, Topic paper 9 – Climate change and natural forces, the consequences for landscape character, SNH/CA; o SNH (March 2012), Guidance: Assessing the Cumulative Impact of Onshore Wind Energy Developments; and o Siting and Designing Windfarms in the Landscape, SNH, 2009. *It is noted that the SNH Visualisation guidance which is widely adhered to by landscape assessors, is currently being updated and due to be published in the near future. SNH has confirmed that, whilst a draft updated document is publically available, all visualisation material should continue to be prepared and submitted consistent with the 2006 guidance until formal publication of the updated guidance. If the updated guidance is published before the Mynydd Lluest y Graig assessment stage commences, the visualisations will be produced to comply with any changes, with agreement from Powys County Council (PCC) and National Resources Wales (NRW). 4.2.5 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The LVIA will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

Assessment Methodology 4.2.6 The detailed assessment methodology will be agreed with PCC and NRW. In summary the methodology will follow the following stages: o Consultation with relevant parties including PCC and NRW to agree the assessment methodology, the scope of the assessment, the extent of the study and cumulative search areas and relevant schemes to include, the number and location of both specific and representative viewpoints to be utilised within the assessment, and the scope of the cumulative assessment; o Consideration of those planning policies from national to local levels pertinent to landscape and visual issues; o Baseline assessment, site survey, viewpoint photography and identification of the sensitivity of all receptors, both landscape and visual;

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o Design iteration and amendment of scheme to ensure embedded mitigation by design. This will include a consideration of turbine layouts, associated ancillary equipment, access tracks, areas of hardstanding and substations; o Assessment of effects upon the landscape character and visual amenity (including in relation to residential properties - see Section 4.3) for the construction, operation and decommissioning stages of the development. The assessment will:

• Identify the magnitude and significance of effects upon the landscape character, designated and recreational landscape and the existing visual environment;

• Determine whether each identified effect is positive, neutral or adverse using an informed professional judgement; and

• be supported by accompanying plans and graphics. o Recommendation of further mitigation measures where appropriate; o Assessment of residual effects; and o Assessment of all cumulative effects, including cumulative ZTV production and wireframe visualisations. This will include discussion with PCC and NRW to reach agreement on the cumulative scope and the identification of which wind developments (e.g. single turbines) can be scoped out of the assessment allowing the cumulative assessment to clearly focus upon potentially significant cumulative effects.

Significance Criteria 4.2.7 The process of forming a judgement of significance of impact is based upon the assessment of the magnitude of the impact and the sensitivity of the receptor, in order to come to a professional judgement of how important this impact is. 4.2.8 Sensitivity is rated within the range of High-Medium-Low-Negligible and is assessed by combining the considerations of susceptibility and value (as defined within GLVIA 3). Magnitude is also rated within the range of High-Medium-Low- Negligible and is assessed by combining the considerations of scale, duration and extent of impacts (as defined within GLVIA 3). A glossary of terminology will be provided within the submitted LVIA ES Chapter.

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4.2.9 The judgement of significance is illustrated by the diagram below (based on EIA significance evaluation matrix, IEMA Special report 2011):

4.2.10 Impacts that are Major-Moderate or Major are considered to be significant. Impacts of Moderate significance or less are “ of lesser concern ” (GLVIA 3, para 3.35). It should also be noted that whilst an effect may be significant, that does not necessarily mean that such an impact would be unacceptable, or should necessarily be regarded as an “ undue consequence ” (GLVIA 3, para 5.40).

Baseline Landscape 4.2.11 The baseline will be established by reference to the LANDMAP database. All 5 spatial datasets (Geological Landscape, Landscape Habitats, Visual and Sensory, the Historic Landscape and the Cultural landscape), will be used, with reference to mapped aspect areas, and their published Collector survey records. The visual and sensory description for the aspect area which includes the site states the area to be: “An extensive area of upland grazing with a patchwork vegetation cover of rough grazing, heather and bracken, irregular field patterns

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running with the topography and intermittent small blocks of coniferous and mixed woodland. Exposure and wind are dominant features with isolated more intimate areas with small irregular hedged fields in sheltered areas to the edge of the area. ” 4.2.12 In addition to the NRW LANDMAP database, the Landscape character assessment for Powys will also be referenced, along with information regarding Snowdonia National Park (SNP). Visual 4.2.13 The upland moorland and plantation are the key visual features of the Site, in what is generally a featureless upland landscape. The elevated and open nature of views allows long panoramic views over the surrounding countryside, set against the backdrop of the Cambrian mountains on the horizon to the south west. 4.2.14 There are a number of wind farms currently extant within the locality of the Site. The closest include: o Mynydd Clogau wind farm approximately 5km southeast (17 turbines); o Carno A and B wind farm approximately 5km to the southwest (56 turbines); o Carno Extension wind farm, approximately 5km to the southwest (12 turbines); and o Mynydd y Cemmaes approximately 8km to the west (18 turbines) 4.2.15 These will be considered as part of the baseline environment in accordance with best practice, along with schemes in construction and other approved schemes, subject to the date of the planning submission.

Impact Prediction and Mitigation 4.2.16 The principal effects to landscape character that could occur as a result of the development are: o Loss of features such as plantation woodland or open moorland that contribute to the landscape character within the site; o Addition of features to the landscape such as turbines, forestry distribution and access routes; o A change to the landscape character of the site; and o A change to the landscape character of the surrounding landscape. 4.2.17 The principal visual receptors that could be affected by the development are: o Scattered private dwellings and farmsteads;

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o Walkers on Glyndwr’s Way National Trail; o Users of local Public Rights of Way (PRoW); o Residents at Llanbrynmair and Llanerfyl; o Receptors on the A470 and A 458; and o Receptors on the Newton to Machynlleth railway line. 4.2.18 The assessment of effects will consider the effects to landscape character and visual amenity based on the approach taken in LANDMAP Guidance Note 3 and GLAVIA 3. Visual receptors will be assessed through the use of representative and (where appropriate) specific viewpoint locations. Locations identified as part of the previous Mynydd Waun Fawr ES will be used where appropriate. Site assessment, ZTV analysis, and wireframes will inform the assessment. Photomontages will be used to illustrate the appearance of the windfarm in the landscape and in views, but will not be used as a basis for assessments. 4.2.19 The assessment of effects will take account of the susceptibility and value of receptors, and thus sensitivity, and the magnitude and duration of effects. A judgement on the significance of identified effects will be given. The scheme is not yet fixed. The final layout will be informed by consideration in terms of landscape and visual effects and potential effects on residential visual amenity (see Section 4.3), in line with policy as set out by Planning Policy Wales (5th Edition) and TAN 8.

Residual Effects 4.2.20 Residual effects are those remaining after the successful implementation of embedded mitigation measures and will be identified within the assessment. Given the nature of the development proposals, mitigation by design is important in seeking to reduce any potentially adverse effects upon the landscape and visual resource that might potentially occur. 4.2.21 The assessment will focus on operational effects as these are occur for the longest period of time and will be the most significant in landscape and visual terms. However, some effects may also occur during the construction and decommissioning phase such as the loss of vegetation or movement of construction traffic and mitigation measures may be suggested and deployed where appropriate to reduce these where possible.

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Cumulative Assessment 4.2.22 The cumulative search area will be agreed with PCC and NRW. 4.2.23 In terms of selecting which other wind farm/turbine proposals within the search area should be included, SNH Guidance 'Assessing the Cumulative Impact of Onshore Wind Energy Developments', (March 2012) advises that: "An assessment of cumulative impacts associated with a specific development proposal should encompass the effects of the proposal in combination with: o existing development, either built or under construction; o approved development, awaiting implementation; and o proposals awaiting determination within the planning process with design information in the public domain. Proposals and design information may be deemed to be in the public domain once an application has been lodged, and the decision-making authority has formally registered the application." [para. 26] - note that this category also includes recently refused applications which may yet be appealed. 4.2.24 Schemes which are in scoping are also noted, but will not be included within the assessment unless they become active applications before the LVIA is submitted, with the exception of schemes where reliable information is available with respect to the scheme design, and the application is known to be imminent. 4.2.25 The cumulative assessment examines the same groups of landscape and visual receptors as the assessment for the main scheme, though different viewpoints may be used in order to better represent the likely range of effects arising from the combination of schemes. The assessment is informed by cumulative ZTVs, showing the extent of visual effects of the schemes in different colours to illustrate where visibility of more than one development is likely to arise. Cumulative wireframes will be prepared which show each of the developments in different colours so that they are each readily identifiable. 4.2.26 In addition, the effects on users of routes through the area, from which wind farms may be sequentially visible as one passes through the landscape will also be considered. This assessment is based on the desk study of ZTVs and aerial photography, and site visits from travelling along the routes being assessed, and may also make use of graphs indicating the proximity and visibility of wind farms along the route.

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4.2.27 Operational, under-construction and permitted wind farms will be treated as being part of the landscape and visual baseline as prescribed by SNH guidance. 4.2.28 The way in which the assessment will be described and presented will be tailored proportionally to convey to the reader the likely significant effects, in line with the SNH and LI/IEMA guidance. 4.2.29 A list of schemes and viewpoints will be agreed with PCC and NRW during the scoping process. It is proposed that single turbines of <50m blade tip will be considered where they lie within 3km of the site; and single turbines of <80m blade tip within 5km of the site.

4.3 Residential Visual Amenity 4.3.1 The visual amenity component of residential amenity will be assessed as a separate but related aspect to the LVIA, as recognised by GLVIA 3.

Published Guidance and Approach 4.3.2 There is no universally recognised guidance for the assessment of the visual component of residential amenity.

Assessment Methodology 4.3.3 As there is no universally recognised guidance for the visual element of a Residential Amenity Assessment (RAA), LDA Design will deploy its own methodology, developed from public inquiry and tested robustly at appeal, and founded on the ‘Lavender Test’. A study area of 1-1.5km is proposed, subject to agreement with PCC. 4.3.4 Each property within the study area will be assessed on site from publically accessible points, and via a review of aerial photography, so that the orientation of windows and gardens towards the wind farm and the degree of screening from intervening buildings and vegetation can be taken into account, along with the extent and nature of fenestration. This will enable a judgement to be formed as to whether the visual amenity will be affected to the degree that “the property concerned would come to be regarded as an unattractive and thus unsatisfactory (but not uninhabitable) place in which to live.” (quotation taken from the Poplar Lane wind farm appeal decision). It should be noted the significance of effect is not identified as part of a RAA. 4.3.5 The RAA will, as appropriate, include a detailed ZTV analysis and accompanying plans, including photography, vision splays and identification of key windows.

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This will help aid the assessment, informing the number of rooms and angle of view a residential receptor may have of the proposed development.

Baseline 4.3.6 There are a number of isolated dwellings and farmsteads scattered within the surrounding environment that may have views of the proposed development.

Impact Prediction and Mitigation 4.3.7 There is the potential for the proposed development to result in ‘overbearing’ and/or overwhelming’ effects to residential receptors. The RAA will establish if and where these are likely to occur.

Residual Effects 4.3.8 RAA residual effects will be identified. Note it is not the purpose of RAA to define if the effect is significant or not but to establish if it could result in the dwelling being considered an ‘unattractive’ place to live, on the basis of visual effects.

Cumulative Assessment 4.3.9 The potential cumulative effect of cumulative schemes will be considered as part of the RAA.

4.4 Ecology and nature conservation

Introduction 4.4.1 The Ecological Assessment of the Mynydd Lluest y Graig Wind Farm on flora and fauna (birds are considered separately under Section 4.5) will be conducted by EDP with input from additional specialists as required. The assessment will: o Be carried out with reference to established methodology and guidance; o Focus on valued ecological and biodiversity resources (at national, regional and local levels); and o Establish the extent and importance of potentially significant ecological effects. 4.4.2 In addition, the assessment will pay attention to any mitigation and enhancement measures established during the site EIA and design stage and examine the scope for further mitigation and enhancement in terms of residual effects and decommissioning.

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4.4.3 The scope of the assessment has been informed by existing ecological appraisals of the Rhyd Ddu (RD) and Mynydd Waun Fawr (MWF) Wind Farm proposals which, in combination, make up the current proposal and site area to be evaluated. A review of the historical survey data relating to these sites is provided in Appendix A.2.

Published Guidance and Approach 4.4.4 The assessment methodology will make reference to recognised best practice guidance - ‘Guidelines for Ecological Impact Assessment‘(2006) produced by the Chartered Institute of Ecology and Environmental Management (CIEEM). New guidance is due for release in 2014 and will be duly adopted if available prior to the ecological impact assessment (EcIA) being completed. The current guidelines propose an approach to valuing and assessing impacts on features that involves professional judgement based on available guidance and information. In addition, the assessment will take account of relevant legislation and guidance, where applicable, as detailed further in Appendix A.1 4.4.5 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The ecological assessment will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

Assessment Methodology 4.4.6 Sites of nature conservation value and pertinent protected or notable habitat and species sensitivities present within the site and surrounding area, have been identified through an ongoing desk based assessment, initiated in October 2013. This has included a review of extant survey data, online resources and information derived from statutory and non-statutory bodies, principally the Powys and Brecon Beacons National Park Biodiversity Information Service (BIS). 4.4.7 Mynydd Lluest y Graig Wind Farm comprises two historical wind farm proposals for which a wealth of floral and faunal survey data exists. While much of this survey information is a number of years old (ranging between 2005 and 2012) it provides a good indication of the habitats and species present and has therefore been reviewed as part of the desk study to inform the scope of

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further survey work to inform the current proposal. A summary of the historical survey data is provided in Appendix A.2. 4.4.8 The baseline conditions will be further established through the ongoing desk study and field surveys for habitats and protected/notable species (see paragraphs 4.4.26-4.4.27 for further details). Different survey methods and search areas/buffers will be utilised, with reference to best practice guidance and professional judgement, in order to provide a robust baseline on which to base the assessment of potential impacts. 4.4.9 The following statutory and non-statutory consultees have been and will be further consulted as part of the EcIA process (this list may be added to as species interests/sensitivities emerge): o Natural Resources Wales (NRW); o Montgomeryshire Wildlife Trust (MWT); o Powys and Brecon Beacons National Park Biodiversity Information Service (BIS); o Powys County Council Ecologist; and o Local wildlife groups where applicable (e.g. bats, badgers and red squirrel). 4.4.10 Early and regular consultation is seen as an integral part of the EcIA process. 4.4.11 Following desk studies and field surveys, and in light of consultations, the issues of concern and Valued Ecological Receptors (VERs) (including species, communities, habitats and ecological processes) will be identified. Definitions will be derived for the importance of each VER and the magnitude of direct and indirect impacts, in line with current CIEEM guidance (2006). 4.4.12 Once a potential significant impact is identified as likely to affect the integrity/favourable conservation status of a potential VER, the value of the receptor is then used to help determine the geographical scale at which the impact is significant. The significance of the potential impacts upon VERs will be assessed both before and after consideration of additional mitigation measures. The latter represents the assessment of the residual impacts of the project. In addition, the potential for cumulative impacts to arise from the in combination effects with other development proposals will be assessed. 4.4.13 Further information on the criteria used to identify and evaluate VER’s is provided in Appendix A.3.

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Baseline Statutory Nature Conservation Designations 4.4.14 The site does not contain any statutory sites for nature conservation. 4.4.15 However, four statutory nature conservation designations (three of the designations relate to the same area) are present within the wider landscape as illustrated on Figure 3 and outlined below: o Berwyn and South Clwyd Mountains Special Area of Conservation - the largest area of upland European dry heath and the most extensive tract of near-natural blanket bog in Wales, located approximately 7.3km north of the site boundary at its closest southerly point. The majority of the 2,733 ha SAC lies at far greater distances from the site as it extends to the north east away from the site boundary along the Berwyn upland range. This site has also been designated as a Special Protection Area (SPA) for the internationally important populations of breeding raptors it supports (see paragraph 4.5.11 for further details). In addition, parts of the site, including the closest point to the site boundary, have been designated as Y Berwyn National Nature Reserve; and o Gweunydd Dolwen SSSI - a 2.3ha site designated for the acid and neutral grassland and dense gorse scrub it supports, located adjacent to the north west boundary of the site. 4.4.16 Subject to the completion of field surveys it is considered to be unlikely that the proposals will result in significant effects on these designated sites owing to their spatial separation from the site and/or interest features. However, the need for a Habitat Regulations Assessment will be screened once the baseline conditions on site have been collected, analysed and reviewed. Non Statutory Nature Conservation Designations 4.4.17 There are two non-statutory local wildlife sites (LWS) within 1km of the site, known as Hafod y Beudy LWS - a 2.5ha area of semi-improved marshy grassland pasture present within the north western extension of the site adjacent to the proposed access route; and Lyn Hir LWS - a 7.5ha low nutrient upland lake adjacent to the sites eastern boundary. Habitats 4.4.18 The site has previously been subject to Extended Phase 1 Habitat Surveys to inform the Rhyd Ddu (RD) and Mynydd Waun Fawr (MWF) wind farm proposals

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as detailed further in Appendix A.2. Reconnaissance surveys undertaken in October and December 2013 were used to confirm whether any major changes in the land management and resulting habitat composition may have occurred in the interim. 4.4.19 The site is considered to be typical of the surrounding upland landscape, principally comprising of commercial coniferous plantation woodland and sheep grazed improved or species-poor semi-improved grassland and marshy grassland interspersed by minor watercourses and a small number of upland waterbodies. 4.4.20 Small areas of botanically important acid grassland and blanket bog are present including 11 important locations and approximately 123ha of deep peat within the western site compartment (RD), as identified by detailed National Vegetation Classification (NVC) surveys and Peat Depth Analysis undertaken in 2008 and 2009 respectively. Although the eastern extent of the site (MWF) has not historically been subject to NVC survey or peat depth analysis surveys an estimated 96ha of blanket bog habitat was identified during Extended Phase 1 Habitat Surveys. 4.4.21 The coniferous plantation woodland which makes up the western extent of the site is predominantly composed of homogenous blocks of dense sitka spruce ranging from young to mature with little or no understory or shrub layer. Broad- leaved semi-natural woodland is primarily restricted to thin belts adjacent to watercourses draining from the higher ground and along the valley bottom to the sites north. The small numbers of hedgerows present are generally species- poor and gappy in nature and none have been previously identified that qualify as important according to the Hedgerow Regulations (1997). 4.4.22 Owing to the plateau and steep terrain on which the site lies the watercourses are typically small fast flowing upland tributaries that feed into Nant Menial, Afon Cam and Nant Wythan which lie to the north of the site. There are five small upland lakes within or in close proximity to the eastern extent of the site, known as Lyn Hir, Lyn y Grinwydden, Llyn Newydd, Lyn Lort and Llyn y Bugail, and up to seven small ponds within the eastern extent. 4.4.23 While some habitats may not be considered to be ecologically important in their own right (e.g. coniferous woodland) they may be important to protected or notable species and require due consideration accordingly.

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Species 4.4.24 A number of records for protected and notable species have been retrieved during the course of the desk study and/or identified by previous ecological surveys (see Appendix A.2 for further details): o Badger ( Meles meles ): a number of setts and activity were recorded by previous surveys (2006 & 2008) predominantly along the riverine valleys within the northern extents of the site. o Red Squirrel ( Sciurus vulgaris ): a single historical record from 1965 exists within 1km of the site but no red squirrels were identified by surveys undertaken of the coniferous woodland in the western extent of the site in 2008. The coniferous habitats present were predominantly evaluated as being sub-optimal for this species owing to either the dominance of Sitka Spruce, the young nature of the plantations or their isolation from other suitable woodland. o Otter ( Lutra lutra ): numerous records exist within close proximity to the site, particularly along the river valleys to the sites north. Limited evidence of this species (e.g. tracks and spraints) was also recorded on or adjacent to the site in association with either the upland waterbodies or adjacent watercourses during surveys undertaken in 2006, 2008 and 2009. o Watervole ( Arvicola terrestris ): no records have been identified within 4km of the site or evidence recorded during surveys undertaken in 2006, 2008 and 2009. o Bats: records for brown long-eared ( Plecotus auritus ), common pipistrelle (Pipistrellus pipistrellus ), whiskered ( Myotis mystacinus ) and natterer’s (Myotis nattereri ) bat roosts are all present within 4km of the site. All of these species are considered to be at low or medium risk from turbine collisions and none of these roosts are present within close proximity to the site (1km). An assessment of structures with potential to support bat roosts (e.g. buildings, trees and quarries) on or within close proximity to the site and activity surveys (transect and static detectors) undertaken between 2008 and 2009 did not identify the presence of any bat roosts and only low level foraging/commuting activity predominantly by medium risk pipistrelle species. The high risk species Noctule ( Nyctalus noctula ) were also occasionally recorded in addition to Leisler’s bat ( Nyctalus leisleri ) on two

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occasions. Occasional myotis bat species recordings were also made but species identification not confirmed. o Other mammals: a number of brown hare ( Lepus europaeus ) and four polecat ( Mustela putorius ) records were returned during the course of the desk study from the wider landscape. A single dormouse (Muscardinus avellanarius ) record located approximately 3km east of the site was also identified however the habitats on site are not considered to offer significant opportunities for this species. o Great Crested Newts ( Triturus cristatus ): no records have been retrieved within a 1km radius of the site and previous habitat suitability index (HSI) assessments of the ponds on or within up to 500m from the site only identified 9 ponds with potential, albeit low, to support great crested newts. The need to survey the larger upland waterbodies within the western site extent (MWF) was scoped out under consultation with Countryside Council for Wales in 2008 following HSI, while only five of the ponds within the western extent (RD) were subject to detailed surveys in 2008 (two were dry at the time of survey and two could not be accessed). No great crested newts were recorded however palmate newt ( Lissotriton helveticus ), smooth newt ( Lissotriton vulgaris ) and common toad ( Bufo bufo ) were all identified. o Reptiles: records of common lizard ( Zootoca vivipara ) exist within close proximity to the site and a number of sightings were incidentally made during other ecological investigations on site associated with both proposals. Slow worm ( Anguis fragilis ) is the only other reptile species that has been recorded within 1km of the site. No previous surveys for reptiles have been undertaken. o Invertebrates: four notable species of invertebrate have been recorded on or within close proximity to the site that are associated with the types of habitats present namely the butterfly species small pearl-bordered fritillary (Boloria selene ), marsh fritillary ( Euphydryas aurinia ), high brown fritillary (Argynnis adippe ) and large heath ( Coenonympha tullia ). 4.4.25 Of the species highlighted above, red squirrel, otter, pipistrelle bats, brown hare, dormouse, great crested newt, slow worm, common lizard, common toad and the butterfly species named are all subject to either local and/or UK Biodiversity Action Plans (BAPs).

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Scope of Ecology Surveys 4.4.26 In light of the baseline identified to date, the extant survey data and the nature of the potential impacts arising from the proposals (see paragraph 4.4.28) the following scope of field surveys is proposed to further inform the EcIA: o Extended Phase 1 habitat survey: an update habitat survey of the site to identify and map any changes in the presence and/or distribution of different habitat types and dominant plant species present. This will include a review of important NVC communities previously identified and an assessment of any hedgerows that may qualify as important according to the Hedgerow Regulations (1997). The findings of this survey combined with the emerging turbine layout will be used to inform the need for subsequent detailed NVC and peat depth analysis surveys, particularly within the eastern extent of the site (MWF) which historically has not been subject to such detailed surveys. o Badger: an update survey identifying signs and sett locations within 50m of the proposed development footprint; o Bat Roosts: external inspections will be undertaken to reassess potential roost sites (e.g. buildings, trees, quarries and bridges) within the site and subsequent internal assessments/emergence/re-entry surveys carried out if considered necessary. o Bat Activity: In light of the low risk nature of the site (as identified by the baseline assessment to date i.e. small number of potential roost features and low quality upland foraging habitat) and low activity levels previously recorded, predominantly associated with species at low/medium risk of turbine collisions, the following scope of activity survey work is proposed to supplement the extant survey data from 2008/2009:

• Three transect surveys each walked on two separate occasions spread across the optimal survey season (May to September).

• Two automated detector surveys comprising 4 static detectors being deployed at the most sensitive locations during the optimal survey season. Based on previous survey results (i.e. the small number of high risk species records) surveys at height are not currently proposed.

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o Red Squirrels: no red squirrels were recorded on site during previous survey work and the only known record is 59 years old. The coniferous woodland plantation present is also considered to predominantly be of low suitability to this species, as confirmed by the reconnaissance surveys in 2013, and any potential impacts arising from the proposals are considered likely to be low owing to the scale of habitat loss. Furthermore, in the unlikely event that this species is now present the level of ongoing surveys, such as breeding bird woodland point counts, should ensure that if present they are identified. All surveyors will be briefed on red squirrel interests and any incidentally sightings or signs duly recorded and the need for survey revisited accordingly. o Otter and water vole: extant surveys and records suggest that otters are present and water voles absent from the site. Given that the upland waterbodies will be inherently protected by the proposal layout, the unsuitable nature of the upland tributaries within the site for all but the movement of this species through the landscape, the nature of predicted impacts are likely to be of low magnitude and principally restricted to access crossing points over water courses at the valley bottom. As such it is proposed that surveys targeting only the access points where they cross the larger streams are undertaken 50m up and downstream of these points to check for potential otter and water vole breeding sites to inform the likely need for licencing. o Pine martin: given the absence of records, relatively limited extent of suitable habitat and difficulties associated in surveying for this species no further surveys are proposed. Instead signs of their presence will be looked out for during other site work and any incidental scat recordings collected and sent for analysis. Such an approach will also assist in identifying the presence of polecats on site. o Great crested newt: a Habitat Suitability Index assessment will be undertaken of the two ponds previously not surveyed, provided access can be secured. Subject to the findings of this survey and confirmation by the Extended Phase 1 Habitat survey that the waterbodies present within 250m of the development footprint continue to be of poor suitability to support great crested newts no further surveys are proposed given the absence of

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records, previous survey findings and anticipated positioning of turbines away from waterbodies. o Reptiles: incidental sightings and records have confirmed that lizards and potentially slow worms are present within suitable habitats on site. The update Extended Phase 1 Habitat survey will be used to identify such suitable reptile habitat. However, since habitat losses are likely to be small and localised, instead of undertaking targeted surveys, presumed reptile presence will be used in the EcIA to guide a precautionary mitigation strategy. o Invertebrates: the need to survey for the notable butterfly species identified by the desk study was scoped out by previous ecological assessments of the site (MWF ES 2007 & RD Scoping Report 2009) owing to the low suitability of habitats present (e.g. an absence of the preferred food plants) and the low magnitude of potential impacts. These conclusions are still considered to be valid and no further surveys are proposed. 4.4.27 Consultation and on-going surveys may identify the need for such protected species surveys to be further considered as part of the EcIA process and will also be used to inform the scope of survey effort employed. All surveys will be undertaken with reference to applicable best practice guidance. Where the survey effort deviates from guidance, justification will be provided and agreement sought from statutory consultees.

Impact Prediction and Mitigation 4.4.28 Identifying potential effects on ecological receptors is an essential part of the EIA process allowing for the provision of appropriate mitigation measures and identification of residual impacts. A precautionary approach to potential effects on ecological receptors arising from the proposals during construction, operation and decommissioning has therefore been taken at this preliminary stage and is summarised below. The potentially significant impacts identified below have been used to inform the proposed scope of the EcIA and associated ecological surveys outlined above: o Direct loss of or damage to sensitive habitats from development footprint (e.g. tracks, turbine foundations, substations and temporary construction compounds) and vehicles / plant traffic etc;

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o Indirect loss of, or damage to, sensitive habitats and non-statutory sites through secondary changes to local hydrological conditions; o Direct pollution of the water bodies and courses; o Habitat fragmentation and severance where wind farm infrastructure creates barriers resulting in disruption to the movement of fauna; o Direct killing, injury or harm of protected/notable fauna and flora; o Disturbance and displacement of species resulting from the impacts of noise, light and human disturbance to species; and o Changes in land-use that may positively or negatively affect habitats and species. 4.4.29 The proposed turbine and infrastructure layout will be informed by previous and current ecological investigations of the site and as such include inherent mitigation to avoid or minimise ecological impacts through sensitive positioning that avoids the important features identified. In addition, all practical and reasonable measures which can be implemented to mitigate any detrimental impacts associated with construction and operation of the proposals shall be considered to ensure the protection, retention and management of valued features. 4.4.30 Opportunities for ecological enhancements on or in the vicinity of the site will be investigated and incorporated in the proposals as feasible and appropriate. Given the scale of the site and the predominance of habitats modified through agricultural and forestry practices, including the draining of wetland areas and bogs, the opportunities for ecological enhancement are notable. The development would therefore include ecological mitigation and enhancement measures such as the restoration of wetland habitats and the improvement of habitat diversity and structure. 4.4.31 Mitigation and enhancement measures will be detailed within the ES and delivered through the following mechanisms: o Iterative Design Process: alterations to the scheme layout and design will be made to avoid and minimise potential impacts on Valued Ecological Receptors (VERs) throughout the design process if additional species and habitat sensitivities emerge through the baseline assessment; o Ecological Construction Method Statement (ECMS): This will aim to set out in detail the measures which will require implementation with respect to

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VERs during the habitat clearance and construction phase of the proposed development. It is proposed that the methodologies prescribed within the ECMS will be overseen by an appointed Ecological Clerk of Works (ECW), whose scope and remit will be set out within the ECMS. Such measures should include: adherence to pollution prevention guidance and other water quality protection measures; and adoption of construction methods and timing that account for ecological sensitivities; and o Ecology Management Plan (EMP): This will set out the measures for the ongoing management, maintenance and monitoring of the VERs including the implementation of appropriate habitat and species management plans. It will also contain details to ensure the successful reinstatement of habitats to pre-construction conditions, or better where feasible, to maximise opportunities for biodiversity enhancement and gain. 4.4.32 The principles of the ECMS and EMP will be set out in the ES and it is anticipated that details will be provided post-consent by condition.

Residual Effects 4.4.33 Any ecological effects that remain following mitigation and enhancement, be they adverse or beneficial, will be identified in the ES.

Cumulative Assessment 4.4.34 Consideration will also be given to the proposals potential to have significant in combination effects with other existing and/or consented/proposed wind farm developments and associated infrastructure within the surrounding landscape, on sensitive habitats, fauna and flora. Such proposals that may warrant consideration within the EcIA (to be agreed with the relevant authorities), include: o Tirgwynt (consented), 1km south east, 12 turbines; o Llanbrynmair (subject to an application for consent), 1.3km west, 30 turbines; o Carnedd Wen (subject to an application for consent), 2.4km west north west, 50 turbines; and o Esgair Cwmowen (subject to an application for consent), 2.5km south, 18 turbines.

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4.5 Ornithology

Introduction 4.5.1 The Ornithology Assessment of the Mynydd Lluest y Graig Wind Farm on birds will be conducted by EDP with input from the ornithological specialists Turnstone Ecology as required. The assessment approach adopted will be broadly in line with that outlined under Section 4.3 Ecology and Nature Conservation.

Published Guidance and Approach 4.5.2 The assessment methodology employed will reflect the industries recognised best practice guidance - ‘Guidelines for Ecological Impact Assessment‘ (2006) produced by the Chartered Institute of Ecology and Environmental Management (CIEEM). The key references that have, and will, be used in combination with professional judgment, to guide the survey methodology and assessment process are: o Recommended bird survey methods to inform impact assessment of onshore wind farms (Scottish Natural Heritage 2013); o Windfarms and Birds: Calculating a theoretical collision risk assuming no avoiding action (SNH 2000); o Assessing Significance of Impacts from Onshore Windfarms on Birds outwith Designated Areas (SNH 2006); o Raptors: a field guide to survey and monitoring, 3rd edition (Hardey et al 2013); and o Bird Monitoring methods (Gilbert et al 1998). 4.5.3 In addition, the assessment will take account of relevant legislation and guidance, where applicable, as detailed further in Appendix A.1. 4.5.4 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The ornithological assessment will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

Assessment Methodology 4.5.5 Sites of nature conservation value to birds and pertinent protected or notable species sensitivities present within the site and surrounding area have been

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identified through an ongoing desk based assessment, initiated in October 2013. This has included a review of extant survey data, online resources and information derived from statutory and non-statutory bodies, principally the Powys and Brecon Beacons National Park Biodiversity Information Service and the Montgomeryshire County Bird recorder. 4.5.6 The Mynydd Lluest y Graig Wind Farm comprises two historical wind farm proposals for which a wealth of bird survey data exists. While much of this survey information is a number of years old (ranging between 2006 and 2012) it provides a good indication of the species present and has therefore been reviewed as part of the desk study to inform the scope of further survey work proposed, as detailed in Appendix A.2. In summary the baseline bird surveys previously undertaken include: o Vantage point surveys; o Winter transect surveys; o Winter and spring waterbody point counts; o Moorland breeding bird surveys; o Woodland breeding point counts; o Raptor walkover surveys; and o Targeted surveys for short-eared owl, barn owl, goshawk, hen harrier roosting sites, nightjar, snipe and curlew. 4.5.7 The baseline conditions continue to be established through the following ongoing field surveys, as agreed through consultation and undertaken according to best practice guidance: o Winter Vantage Points Survey: 36hr of survey from six different vantage points (VPs) undertaken between October and March (i.e. 6hr per VP per month with watches no longer than 3 hours). o Winter Transect Survey: three transect surveys undertaken in December 2013 and January and February 2014 that encompass all areas of the site, where access allows. o Waterbody Point Counts: eleven visits to the larger upland waterbodies present within or near to the eastern extent of the site including a single survey in October and twice monthly surveys until the end of March.

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o Hen Harrier Roost Survey: ten visits using a combination of VP and/or transects timed at dusk or dawn including a single survey in October and March with twice monthly surveys in between. 4.5.8 The baseline conditions will continue to be established from the ongoing desk study and field surveys. Different survey methods and search areas/buffers will be utilised, according to best practice guidance and professional judgement, in order to provide a robust baseline on which to base the assessment of potential impacts. 4.5.9 NRW and RSPB have been engaged in early consultation (Autumn 2013) to agree the scope of winter bird surveys currently being undertaken as detailed in Appendix A.4, including the number and location of vantage points. These organisations and other statutory and non-statutory groups will continue to be consulted throughout the EIA process to ensure that all species sensitivities are identified and subject to the appropriate level of survey. 4.5.10 The impact assessment will be undertaken in accordance with current CIEEM guidance (2006) as detailed under paragraph 4.4.11 - 4.4.13. In addition, the impact assessment will utilise the guideline set out by SNH with regard to calculating collision risk impacts. Further information on the criteria used to identify and evaluate ornithological VER’s is provided in Appendix A.3.

Baseline Nature Conservation Designations 4.5.11 The only statutory designated site designated for ornithological interests present within the wider landscape is Berwyn Special Protection Area (SPA). This SPA, which measures approximately 2,4187ha, is located approximately 7.3km north of the site boundary at its closest southerly point, with the majority of the SPA lying at much greater distances than this as it extends to the north east along an upland ridge. This site has been designated for internationally important breeding populations of hen harrier ( Circus cyaneus ) (14 pairs), peregrine falcon ( Falco peregrinus ) (18 pairs), and merlin ( Falco columbarius ) (14 pairs) it supports. . 4.5.12 It is provisionally considered to be unlikely that the proposals alone, or in combination with other proposals, will result in significant effects on the designated interests of the SPA owing to its spatial separation from the site.

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However, the need for a Habitat Regulations Assessment will be screened once the baseline ornithology data has been collected, analysed and reviewed. Non-statutory Nature Conservation Designations 4.5.13 Lyn Hir LWS, an upland lake adjacent to the sites eastern boundary is considered to have potential to support notable waterfowl and waders including historical records of Greenland White-fronted Goose ( Anser albifrons subsp. flavirostris ). Target Species 4.5.14 The site and surrounding landscape comprises predominantly of upland pastoral farmland and coniferous woodland dissected by small watercourses and occasional small upland lakes. These habitats provide breeding and foraging opportunities for a number of bird species of conservation concern and/or species that are potentially sensitive to a development of this nature, including raptors, waders and waterfowl. 4.5.15 In accordance with best practice guidance the surveys and subsequent assessment will focus on species drawn from the following three important lists: o EU Birds Directive (79/409/EEC) o Wildlife and Countryside Act (1981); and o Red-listed birds of Conservation Concern. 4.5.16 Species contained within these lists that by virtue of their breeding, feeding or migrating behaviour that may be sensitive to the proposals will be identified as target species for assessment purposes. Consideration will also be given to species identified locally as of conservation concern within Local Biodiversity Action Plans. 4.5.17 Based on the ongoing field surveys, the extant survey data (from both the former site proposals, see Appendix A.2, and adjacent wind farm proposals) and records received during the course of the desk study a preliminary list of target species has been drawn up as detailed in Appendix A.5. 4.5.18 In addition, a small number of conservation concern passerine species have been recorded breeding on or within the site (e.g. skylark) however best practice guide states that such species are generally not impacted by turbines and will therefore be excluded from the EcIA except where significant habitat loss/disturbance impacts could potentially arise.

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Scope of Ornithology Surveys 4.5.19 In light of the target species identified to date, the extant survey data and the nature of the potential impacts arising from the proposals (see section 4.5.22) the following field surveys are proposed to further inform the ornithology EcIA: o Vantage Point Survey for breeding birds: 36hr of breeding vantage point surveys from each of the six different VPs agreed for the winter surveys undertaken between April and July according to SNH guidance (2014). Attempts will be made to move VP locations if snipe or curlew breeding sensitivities are identified on the ground. o Moorland Breeding Bird Survey: four visits per breeding season (mid-April – early July) for two years (2014 & 2015) using an adapted Brown & Shepherd (1993) methodology as per SNH guidance (2013) to map the breeding territories of upland waders, principally snipe and curlew within a 500m radius of the site. o Woodland Point Count: three visits during the breeding season (mid-April – early July) targeting the blocks of coniferous habitat within the western extent of the site to record breeding woodland species (e.g. crossbill) in accordance with best practice guidance (Gilbert et al 1998; Bibby et al 2000). o Barn Owl Survey: an assessment of buildings and trees with nesting potential within 500m of the site boundary (where access allows) by a licenced ornithologist to confirm the current breeding status of the historical nest sites and identify any other breeding or roosting activity. The survey buffer has been reduced to 500m from the 1km proposed under SNH guidance for owl species owing to the presence of known nest sites in close proximity to the site and the low risk of barn owls from colliding with turbines due to their low flying behaviour. o Breeding Raptor Survey: comprising an initial desk based assessment of aerial photography to identify potential raptor nesting habitat (by target species) within up to 2km of the site followed by up to four surveys of potentially suitable habitat to record breeding activity in accordance with best practice guidance (SNH 2013 & Hardey et al 2013). Owing to the size of area requiring consideration a combination of driven and walking transects incorporating stationary watches will be used. The surveys will be undertaken during suitable weather conditions and timed to coincide with

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key periods in the breeding season between March and July. If a nesting territory appears to be unoccupied on the basis of the first two visits then further visits to that territory will be omitted. Visits to suitable upland moorland habitat will be timed to be either in the early morning or evening to coincide with the peak periods of activity by short-eared owls. o Targeted Goshawk Surveys: two early morning VPs overlooking the coniferous woodland within the western extent of the site will be undertaken in February and March to record the presence of displaying goshawks. 4.5.20 In light of the absence of records, historical survey findings and limited extents of suitable habitat targeted surveys for nightjar and black grouse are not currently proposed. 4.5.21 Consultation and on-going surveys may identify the need for additional protected species surveys to be further considered as part of the ornithology EcIA process and will also be used to inform the scope of survey effort proposed. All surveys will be undertaken in accordance with applicable best practice guidance. Where the survey effort deviates from guidance, justification will be provided and agreement sought from statutory consultees.

Impact Prediction and Mitigation 4.5.22 Identifying potential effects on ecological receptors is an essential part of the EIA process allowing for the provision of appropriate mitigation measures and identification of residual impacts. A precautionary approach to potential effects on ecological receptors arising from the proposals during construction, operation and decommissioning has therefore been taken at this preliminary stage and is summarised below. The potentially significant impacts identified have been used to inform the proposed scope of the ornithology EcIA and associated surveys outlined above. o Direct habitat loss and damage through construction of windfarm infrastructure (e.g. turbine bases, substation, borrow pits, access routes and other ancillary infrastructure); o Habitat fragmentation and severance where wind farm infrastructure creates barriers; o Displacement and disturbance resulting from construction activities and operation of the turbines, maintenance and decommissioning activities;

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o Direct killing or harm through turbine collisions or interaction with blades.

Mitigation 4.5.23 The approach to addressing, reporting and delivering mitigation of potentially significant impacts and providing enhancement will follow that set out within the Section 4.4.31 - 4.2.28 of this report.

Residual Effects 4.5.24 Any effects on ornithological interests that remain following mitigation and enhancement will be identified in the ES.

Cumulative Assessment 4.5.25 Consideration of the proposals potential to have significant in combination effects with other existing and/or consented/proposed wind farm developments and associated infrastructure (see paragraph 4.4.34 for further details) on target bird species will also be evaluated.

4.6 Archaeology and Cultural Heritage

Introduction 4.6.1 An Archaeological and Cultural Heritage Assessment of the Mynydd Lluest y Graig Wind Farm will be conducted by an accredited archaeologist. The assessment will: o Be carried out in accordance with established methodology and guidance; o Focus on valued archaeological and cultural heritage resources (at national, regional and local levels); and o Establish the extent and importance of potentially significant archaeological and cultural heritage effects. 4.6.2 In addition, the assessment will pay attention to any mitigation and enhancement measures established during the site EIA and design stage and examine the scope for further mitigation and enhancement in terms of residual effects and decommissioning. 4.6.3 The assessment will consider the sensitivity of the historic environment to effects. As set out in Planning Policy Wales Edition 5 Chapter 6 (2012), the historic environment comprises: archaeology and ancient monuments (scheduled and unscheduled), listed buildings, conservation areas, world

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heritage sites and historic parks, gardens and landscapes. Collectively, the latter are also referred to as heritage assets.

Published Guidance and Approach 4.6.4 The collation of baseline information will be undertaken in compliance with the guidance set out in the Institute for Archaeologists’ Standard and Guidance for historic environment desk based assessment (2012). 4.6.5 The assessment will also be informed by Cadw’s Conservation Principles (2011); in particular, the sections concerning understanding heritage values and assessing significance. English Heritage’s The Setting of Heritage Assets (2011) will also be used in the absence of specific Welsh guidance relating to setting. 4.6.6 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The archaeological and cultural heritage assessment will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA. 4.6.7 The assessment will consider potential effects on both the physical fabric of heritage assets and their setting. The scope set out here is informed by consultation correspondence, baseline and assessment reports produced in relation to the Rhyd Ddu and Mynydd Waun Fawr proposals. The assessment will re-use information collated during these assessments where there is no potential for new information to have been generated since it was collated. The baseline information gathered with relation to these two proposals will be updated where there is potential for relevant new information to be available; the proposed scope is set out in more detail below. 4.6.8 Initial contact has been made with the Clywd-Powys Archaeological Trust (CPAT) Development Control Archaeologist and the relevant contact in Cadw. Consultation with both shall be on-going throughout the assessment, to ensure the information contained within it is sufficient and that any proposed mitigation or enhancement measures are acceptable.

Assessment Methodology 4.6.9 The existing baseline data will be updated with regard to the following data sources:

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o Clywd-Powys Historic Environment Record (data relating to undesignated assets and conservation areas; including a visit to the HER if appropriate); o Cadw data downloads (data relating to designated assets); o Royal Commission on the Ancient and Historical Monuments of Wales (RCAHMW), including the National Monuments Record of Wales (NMRW); o Relevant published and unpublished material; and o The availability of existing LiDAR data will also be investigated (none was available at the time of the previous assessment). 4.6.10 The data will be updated with regard to three study areas: o Data related to undesignated assets will be retrieved for a study area that extends 1km from the application boundary and is intended to inform a consideration of potential effects on the physical fabric of heritage assets; o Data will be retrieved with regard to all scheduled monuments, listed buildings and conservation areas up to 5km from the application boundary to inform a consideration of potential effects on their settings; and o Data will be retrieved with regard to registered landscapes of historic interest, parks and gardens and world heritage sites up to 10km from the application boundary to inform a consideration of potential effects on their settings. 4.6.11 Walkover surveys of all accessible parts of the application areas were undertaken at Mynydd Waun Fawr and Rhyd Ddu (2008-2009); and the results were set out in Supplementary Environmental Information for Mynydd Waun Fawr and an internal baseline report for Rhyd Ddu in 2009 and 2013 respectively. The methodology of the surveys was agreed with CPAT and it is not proposed to replicate them, however, if any previously inaccessible areas have become accessible through forestry felling since the dates of the previous surveys (as informed by data gathered during the forestry assessment) they will be subject to a walkover survey undertaken as per the previous methodology. The baseline data will be combined and presented with reference to the new application area for ease of reference; during this process the baseline data regarding Rhyd Ddu will be checked and supplemented if appropriate. 4.6.12 The methodology will be as follows: a walkover over the whole previously un- surveyed area based on transects at 30m intervals. The record will include: a daily log of weather conditions and areas covered or noted as inaccessible,

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sketch plans, digital photographs, written descriptions and location to an accuracy of less than 10m of any historic features, or potential historic features, identified. The baseline data of the previous surveys will be combined with any new data and set out within the desk based assessment for ease of reference. 4.6.13 In light of existing baseline data it is not expected that any more detailed survey or intrusive evaluation will be required. If assets requiring further investigation are encountered during new survey, or are included within new areas of development, the scope of any such work will be agreed with CPAT. 4.6.14 In addition to the survey of any previously inaccessible areas, the proposed turbine locations and footprint of any related infrastructure will be visited to check the baseline condition of any previously recorded features. 4.6.15 The results of the examination of aerial photography, historic mapping and other archive material are also contained in the baseline data set out in 2009 and 2013 and it is not proposed to replicate examination of these data sources. The results, and any relevant data such as historic maps, will be integrated into the new assessment for ease of reference. 4.6.16 The assessment of potential effects on setting will be informed by the ZTV, desk-based assessment, site visits (to the nearest publicly accessible points) and suitable visualisations (wireframes and photomontages) where appropriate. Both views from, and views to, relevant assets will be considered.

Baseline 4.6.17 An initial appraisal has been undertaken using the existing baseline data and current Cadw data downloads. 4.6.18 There are no designated assets within the application boundary. 4.6.19 The existing baseline datasets include a combined total of 32 previously recorded undesignated assets within the application area. As well as upstanding remains relating to post-medieval exploitation of marginal land, a small number relate to prehistoric activity, notably an upstanding round barrow (Mynydd Waun Fawr Cairn; 4825). The walkover surveys recorded a further 145 upstanding assets (by far the larger number were in Mynydd Waun Fawr; presumably because of forestry in Rhyd Ddu). Most of the identified remains related to post-medieval exploitation and included former field boundaries and clearance cairns; there were also a number of former structures, including

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farmsteads. The associated reports noted that some of the latter could have medieval origins. 4.6.20 The Mynydd Waun Fawr assessment concluded that in addition to the identified upstanding remains there was some potential for further, sub-surface, features to exist within the proposed development area. Both reports noted a potential for palaeo-environmental remains to survive in boggy areas. 4.6.21 There are 17 scheduled monuments within 5km of the application boundary. The nearest is a root store at Bon-y-Maen (MG218), which is adjacent to the boundary. The most frequent type of monument within 5km is round cairns or barrows, of which there are eight. There are also four camps (defended prehistoric settlements). The closest camp is Moel Ddolwen Camp (MG149) 550m to the north. Other monuments include a stone circle, motte and bailey castle and section of Roman Road. Most of the monuments are to the north of the application boundary. 4.6.22 There are 61 listed buildings within 5km of the application boundary. Two of these are Grade II* and the remainder Grade II. The closest to the application boundary is Bryn-Coch Uchaf (17946) some 430m to the north. Both Grade II* buildings are over 4km from the application boundary (and include the Church of St Mary; 8679). Most of the listed buildings lie to the north of the application area, around the A458, and are domestic buildings, although they also include commercial buildings and other structures such as milestones and wells. 4.6.23 There is one registered park and garden within 10km of the application area; Gregynog (Grade I) some 9.3km to the south-east. There is one Landscape of Special Historic Interest within 10km; the Caersws Basin just over 9km to the south. Given the distance to the Caersws Basin, it is not expected that ASIDOHL (Assessment of the Significance of Impacts of Development on Historic Landscapes) will be required. There are no World Heritage Sites within 10km of the proposed development. 4.6.24 The previous surveys noted that there were no conservation areas within 5km of the proposed application areas; the data regarding conservation areas will be refreshed during the assessment to check that this remains the case. If any conservation areas have been created within 5km since the previous assessments they will be included.

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Impact Prediction and Mitigation 4.6.25 The construction of the proposed development has the potential to directly disturb the physical fabric of previously recorded or unrecorded heritage assets. The operation of the proposed development has the potential to affect the setting of assets in the vicinity. The following methodology will be used to assess the significance of direct effects upon heritage assets as well as to consider indirect effects upon their setting. 4.6.26 The assessment of an effect’s significance depends on the sensitivity of the asset affected and the magnitude of predicted change. The sensitivity of an asset to effects will be determined on the basis of designation and in the case of undesignated assets, with reference to existing information (such as HER categorisation) and the framework for assessing significance in Conservation Principles. Sensitivity to effects reflects the level of importance of the asset as presented below: Sensitivity Importance Description High National Nationally important designated assets (scheduled monuments, Grade I and II* listed buildings, Grade I and II* registered parks and gardens, and registered historic landscapes) or assets meeting the criteria for national importance. Medium Regional Grade II listed buildings, conservation areas and undesignated assets of regional importance. Low Local Undesignated assets of local importance.

4.6.27 The magnitude of change will be assessed with reference to the degree of change in an asset’s heritage significance. The term ‘heritage significance’ is as used in Conservation Principles; and is distinct from sensitivity and significance of effects (as used in standard Environmental Impact Assessment terminology). The heritage significance of an asset will be characterised by reference to one or more component values, namely: evidential, historical, aesthetic or communal.

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4.6.28 The heritage significance of each asset potentially affected will be described and the degree to which the overall significance of the asset is affected used to arrive at a magnitude of predicted change as set out below: Magnitude of Description Change Major Total loss or substantial alteration to key elements of the asset or its setting, such that post-development heritage significance of the asset will be fundamentally changed. For example, a change that resulted in substantial harm to a heritage asset's setting, such that its significance would be totally lost or reduced to such a degree that its designation would be questionable. Moderate Loss or alteration to one or more key elements of the asset or its setting, such that post-development heritage significance of the asset will be materially changed. For example, a change that resulted in considerable harm to a heritage asset’s setting, such that its significance would be devalued, but not totally or substantially lost. Minor Marginal shift away from the baseline conditions. Change arising from the loss/alteration will be readily detectable but not material: the asset’s heritage significance post

development will be slightly diminished. For example, a change that resulted in marginal harm to a heritage asset’s setting, but leaving the overall significance intact. Negligible Change in heritage significance barely detectable.

4.6.29 It should be noted that it is possible for appreciable change to occur in the setting of a heritage asset without there being any adverse effect upon its heritage significance. Where change occurs but this does not affect heritage significance it will be concluded that there will be no effect. 4.6.30 The sensitivity of the asset, together with the magnitude of change, will define the significance of the effect, as set out in the framework below. Where there is scope for two levels of effect (e.g. major or moderate), professional judgement

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will be used. Major and moderate effects will be considered significant in the context of the Regulations. Sensitivity Magnitude of Change Major Moderate Minor Negligible High Major Major or Moderate or Negligible Moderate Minor Medium Major or Moderate Minor Negligible Moderate Low Moderate or Minor Minor or Negligible Minor Negligible

4.6.31 Desk-based and walkover survey of the accessible areas of the entire development boundary has been undertaken to inform previous assessment of direct effects on the physical fabric of heritage assets during construction. This will be updated as set out above and the information used to inform layout design. Preferred mitigation will comprise the avoidance of any assets; this option will be particularly preferred for assets of high or medium sensitivity (for example, Mynydd Waun Fawr Cairn; 4825). Where avoidance is not possible other mitigation measures will be developed in consultation with CPAT; it is envisaged these may entail minimising disturbance by sensitive construction practices (for example, crossing former boundaries or other linear features at right angles) as well as archaeological recording. Previous experience suggests that such adjustments to design, provision for archaeological recording and sensitive construction practices will be sufficient to fully mitigate any significant direct effects on the physical fabric of heritage assets. 4.6.32 The assessment of potential operational effects on setting will be informed by the information collated as set out above. If significant effects are predicted the potential for mitigation through alteration to the design layout will be considered; any such mitigation will be developed in consultation with Cadw and CPAT.

Residual Effects 4.6.33 There will be no adverse effects on undesignated heritage assets preserved in situ within the development area. The assessment will explore the potential for enhancement and residual beneficial effects for such assets in consultation with

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CPAT; such beneficial effects could include measures to ensure assets’ preservation through improved land management or an increased understanding of such assets through the use of non-intrusive survey. 4.6.34 For any assets subject to a programme of archaeological recording prior to their whole or partial physical loss during construction; that loss will be mitigated through their preservation by record. Preservation by record is viewed as a less desirable outcome than preservation in situ and will therefore be assessed as an adverse residual effect. As noted above, previous experience suggests that adverse effects on assets of medium or high sensitivity can be avoided and therefore such effects are unlikely to be significant. 4.6.35 Any residual adverse operational effects on the settings of heritage assets in the vicinity will be set out in the assessment for due consideration in the planning process. Any such residual effects are likely to be entirely reversible on decommissioning.

Cumulative Assessment 4.6.36 There is potential for significant cumulative effects on the historic environment. Potential cumulative effects with other wind energy schemes (operational, consented and subject to an application for consent) within 10km of the site boundary will be assessed. The assessment will be informed by cumulative ZTVs and visualisations where appropriate. Any adverse cumulative effects will be set out in the assessment for due consideration in the planning process. This proposal’s contribution to any such effects is likely to be entirely reversible on decommissioning.

4.7 Noise Assessment

Introduction 4.7.1 Noise can arise from both the construction, operation and decommissioning of a wind energy scheme. During wind farm construction, noise can arise from both on-site activities such as the construction of access tracks, turbine foundations, substation buildings etc., and also from the movement of construction related traffic both on-site and travelling on public roads to and from the site. 4.7.2 During their operation, wind energy schemes have the potential to create noise effects through both aerodynamic noise and mechanical noise. Aerodynamic

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noise is caused by the interaction of the turbine blades with the air. Mechanically generated noise is generally caused by the operation of mechanical components, although in some instances a noise source may arise from the presence of transformers located outside the wind turbines. However, the level of both aerodynamic and mechanical noise radiated from current technology wind turbines due to improvements in blade design, and nacelle design and insulation is generally engineered to a low level. 4.7.3 Noise problems are now uncommon with modern wind turbines and noise can be minimised by careful site selection, turbine design and wind farm layout. 4.7.4 When assessing the potential noise impact of a proposed wind farm, it is appropriate to take account of the existing noise environment to be found at neighbouring noise sensitive receptors to a development. Therefore, as part of the assessment, noise measurements of the existing environment will be undertaken the results of which will be used to determine acceptable levels of operational wind turbine noise.

Published Guidance and Approach 4.7.5 The approach for assessing the potential noise impact of a proposed wind farm scheme will follow the advice and guidance within the following documents: o ETSU-R-97: The assessment and rating of noise from wind farms; o Institute of Acoustics: A Good Practice Guide to the application of ETSU-R-97 for the assessment and rating of wind turbine noise (IoA GPG) (May 2013); o Relevant Supplementary Guidance Notes to be published by the IoA in addition to the GPG; o World Health Organisation: Guidelines for Community Noise; o BS 8233: 1999: Sound insulation and noise reduction for buildings. Code of practice; and o BS 5228:2009 Part 1: Code of practice for noise and vibration control on construction and open sites. 4.7.6 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The noise assessment will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

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Assessment Methodology 4.7.7 The methodology to be adopted for determining the potential noise impacts associated with the proposed wind farm will follow the guidance within ETSU-R- 97 and the IoA GPG. 4.7.8 Preliminary noise predictions will be undertaken based upon a representative sound power level for the proposed generating capacity of the wind turbines envisaged for installation at the site. These preliminary noise predictions will inform the potential noise measurement locations for undertaking the background noise survey. During earlier survey work undertaken for the site, background noise measurements were undertaken but not all measurements were correlated with a mast that allowed for the effects of wind shear to be accounted for. Therefore, it has been proposed that a new background noise survey be undertaken that incorporates measurements of wind speed at suitable heights to ensure that wind shear may be account for in accordance with the IoA GPG. Discussion will be held with the Environmental Health Officer (EHO) for the need for additional noise measurements where noise survey data already complies with the requirements of the IoA GPG and especially where this additional information has formed the basis of agreed cumulative noise limits for consented developments. 4.7.9 Once the background noise data has been collected it will then be assessed in accordance with the guidance within ETSU-R-97 and the IoA GPG. This analysis will determine the prevailing noise environment at the measurement locations to allow determination of appropriate noise limits for the operation of the wind farm.

Baseline 4.7.10 It is proposed, on the basis of prior knowledge of the site and surrounding area, that between 12 and 15 measurement locations are considered appropriate to assess the existing noise environment at neighbouring noise sensitive receptors. This number provides a wide range of measurement locations such that where noise measurements are not undertaken at a specific assessment location, a proxy location may be used which represents the noise environment at the assessment location. 4.7.11 The exact locations will be agreed with the Local Authority EHO and it is proposed that each location is witnessed by the officer during the installation of

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the sound level meter. The need for repeating measurements at some locations where measurements have been undertaken in the past will be discussed. 4.7.12 Sound level meters, wind shields and calibration will comply with the requirements of IoA GPG and ETSU-R-97. 4.7.13 Wind speed measurements will be undertaken on site using anemometers located upon a free standing meteorological mast to allow determination of potential wind shear effects in accordance with the requirements of IoA GPG. Two masts are installed at the site which will inform the appropriate wind speed for use when determining noise limits for the neighbouring receptors. 4.7.14 Rainfall data will be collected using two rain gauges installed at either end of the site at receptor locations.

Impact Prediction and Mitigation 4.7.15 Predictions of operational noise will be undertaken using the model defined within ISO 9613-2 and identified within the IoA GPG. The atmospheric conditions identified within the IoA GPG will be used, i.e. a temperature of 10°C and Relative Humidity of 70%. Ground Conditions will be assumed to be mixed, i.e. G = 0.5. 4.7.16 Predictions of operational noise from the proposed wind turbines will be undertaken for all properties predicted to fall within the 35 dB LA90 noise contour for the proposal. 4.7.17 Each property will be access to determine whether operational noise will meet the requirements of ETSU-R-97. 4.7.18 Predictions of noise associated with the construction and decommissioning of the project will be undertaken in accordance with BS 5288:2009 Part 1. An assessment of appropriate noise limits for this activity will be undertaken using the noise data collected as part of the assessment of the existing noise environment at the site for operational noise. Predictions of construction activity will be compared with the derived noise limits for this activity as determined following the guidance within BS 5288:2009: Part 1.

Residual Effects 4.7.19 Following completion of the background noise survey and the predictions of operational noise, the potential noise impact will be determined. Where it is predicted that operational wind turbine noise may not be in accordance with

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the requirements of ETSU-R-97, then mitigation will be considered to reduce the potential for noise effects associated with the scheme. Such mitigation may take the form of revised turbine layout and/or alternative operational modes of the wind turbine to reduce emitted noise levels. 4.7.20 In the event that noise associated with the construction and decommissioning of the site is found to exceed the proposed noise limits derived in accordance with BS 5288: 2009: Part 1, then mitigation will be provided to reduce noise to an acceptable level. 4.7.21 The issue of Amplitude Modulation (AM) will be considered with reference to the 2013 RUK Study 1 and with the evolving GPG from the IoA in the form of a Supplementary Guidance Note (SGN). The IoA are undertaking a workshop on this issue in late March 2014 where further discussions are to be held to develop an additional SGN on this topic.

Cumulative Assessment 4.7.22 Cumulative noise associated with the operation of the wind turbines is considered within the IoA GPG. The guidance within this document will form the basis of identifying other wind farms which may have a cumulative noise impact with the proposed site. 4.7.23 The Mid Wales (Powys) Conjoined Wind Farms Public Inquiry has considered the issue of cumulative noise for SSA B & C. The proposed cumulative noise limit for both SSAs is the greater of 40 dB LA90 or Background + 5 dB. It would be on this basis that an assessment of the potential cumulative noise effects associated with the construction and operation of Mynydd Lluest y Graig will be assessed.

4.8 Access Transport and Traffic

Introduction 4.8.1 Given the scale of the proposed wind energy scheme there is the possibility of some significant transport effects during construction and decommissioning of the scheme, although it is anticipated that there are likely to be negligible transport effects during operation.

1 http://www.renewableuk.com/en/publications/reports.cfm/wind-turbine-am-cause-effects-briefing

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4.8.2 A preferred access route for all abnormal loads is identified in Section 3.5 of this scoping report. All other construction traffic is likely to arise within the locality of the scheme, particularly as the developer will express a preference for local suppliers in order to increase the benefits of the scheme and to reduce the effects of construction traffic on the wider network. 4.8.3 An access optioneering review will be undertaken to assess the optimum access route from the A458 to the site and a variety of options will be examined and reported on within the submission. 4.8.4 The application will also be accompanied with an Abnormal Load Traffic Management Plan and a framework Construction Transport Management Plan to assist in developing possible mitigation measures, compliance with Health & Safety regulations and to illustrate the more detailed points of network management during construction.

Published Guidance and Approach 4.8.5 A full review of the relevant transport planning policies, guidance notes and documentation will be undertaken and will include reference to the following: o National Transport Plan; o Regional Transport Plan - Trafnidiaeth Canolbarth Cymru (TraCC); and o Draft General Principles for the use of Trunk Roads in Wales for the Movement of Abnormal Indivisible Loads. 4.8.6 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The transport assessment will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

Assessment Methodology 4.8.7 A separate Transport Assessment (TA) will be prepared in line with the Proposal details will be produced with reference to the relevant policy and guidance documentation. 4.8.8 The TA will assess the traffic and transport impacts arising from the Proposal and will form a standalone report. This will be summarised into the appropriate chapter of the Environmental Assessment. 4.8.9 The TA will include:

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o A summary of relevant policy; o A summary of the methodology adopted for the assessment; o A description of the existing and future baseline conditions; o An estimate of trip generation during the construction, operational and decommissioning phases of the development; o An assessment of the impacts that are likely to occur; o Identification of appropriate mitigation measures; o A preliminary site access design; and o A Framework Traffic Management Plan. 4.8.10 The assessment will consider all three phases of the scheme; namely construction, operation and decommissioning. The operational phase will be the phase with the least impact on the study area and as such the assessment will concentrate on the construction phase as the worst case scenario. The decommissioning phase will be considered, however as elements of infrastructure may be left, this phase involves fewer trips and as such is not likely to be associated with traffic flows greater than that assessed for the construction phase. 4.8.11 Having estimated the number of trips associated with each phase of the development, the potential impact on the study area road network in terms of percentage increase will be determined. 4.8.12 From these calculations and using the Institute of Environmental Assessment (IEA) guidelines, the severity of impact on the affected communities / receptors will be determined. 4.8.13 The TA will outline the impact and severity of the proposed traffic on receptors and will propose mitigation works where necessary. 4.8.14 An assessment will be made of road safety in the local area using local accident data as a base which will be requested from the Welsh Government’s Transport Statistics section. 4.8.15 The Transport Assessment will include a detailed abnormal load review covering all abnormal access issues for all components. At this stage, alternative routes and Ports of Entry are being considered; these will be finalised before submission of the application.

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4.8.16 Reporting will include swept path assessments, a summary of consultation undertaken with all statutory bodies and a traffic management plan to illustrate the operational elements of the abnormal load movements.

Baseline 4.8.17 Observed traffic flows on the local road network will be established using traffic data sourced from new traffic surveys undertaken by Automatic Traffic Counters (ATC) located at suitable points agreed with Powys County Council and the Mid Wales Trunk Road Agency within the agreed study area. 4.8.18 The count data will be collected in vehicle classes with vehicle speeds per direction. The new counts may also be supplemented with data obtained from Traffic Wales’ Trunk Road Traffic Data Services and/ or the Department for Transport. 4.8.19 It is proposed that 2019 be taken as the year of completion and will be used for the base year of the assessment. 4.8.20 High growth factors from the National Road Traffic Forecast or observed local traffic growth estimates developed from first principles will be applied to the surveyed traffic flows to produce future year traffic for use in the assessment. Discussions with the relevant road authorities will determine the most appropriate level of traffic growth for use in the assessment. 4.8.21 Traffic flows associated with committed developments within proximity of the site will be included in the assessment as advised by Powys County Council. 4.8.22 Traffic flows associated with the construction, operation and decommissioning phase of the site will be established using a first principle approach of estimating traffic flows from construction volumes.

Impact Prediction and Mitigation 4.8.23 A high level IEMA assessment of the impact of construction and decommissioning traffic volumes against base flow data will be undertaken to review the likelihood for significant impact and the need for mitigation. 4.8.24 It is considered likely that the greatest impact will be on the local roads close to the site.

Residual Effects 4.8.25 It is considered likely that residual effects, if any, will be restricted to the construction period and will therefore be short term in nature. Impacts during

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these periods are highly likely to be negligible in scale and will be addressed in the Construction Transport Management Plan that will accompany the submission.

Cumulative Assessment 4.8.26 A cumulative assessment of significant committed development schemes will be undertaken where such schemes may be built concurrently with the Proposal. Proposals to offset cumulative impact of construction traffic including natural and legislative controls will be detailed and will make reference to elements contained with the Renewables UK Strategic Traffic Management Plan (STMP) and recent developments and submissions from the Mid Wales Conjoined Inquiry.

4.9 Hydrology, Hydrogeology and Geology

Introduction 4.9.1 Due to the scale and location of the proposed development there will be a requirement for the assessment of effects to hydrology, hydrogeology and geology within the site area and for a buffer area around the site boundary. This Section outlines the preliminary hydrology, hydrogeology and geology baseline and scopes the requirements for the Environmental Statement with regard to the surface and ground water resources. Peat is considered in Section 4.10.

Published Guidance and Approach 4.9.2 The following legislation and guidance will be consulted to provide the basis of this baseline assessment, and will be used as part of a subsequent impact assessment: o The Water Framework Directive (WFD 2000/60/EC;) o The Water Supply (Water Quality) Regulations 2010; o The Water Supply (Water Quality) (Amendment) Regulations 2011; o Private Water Supplies (Wales) Regulations 2010; o Relevant pollution Prevention Guidance Notes (PPG); and o Forestry Commission Forests and Water Guidelines 4.9.3 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The hydrological assessment will, among other things,

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reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

Assessment Methodology 4.9.4 A comprehensive desktop survey coupled with a site visit will review and verify the following information to assess the sensitivity of the baseline environment: o Geology, hydrogeology and soils of the application boundary and sub- catchments; o Details of designated and protected areas within the drainage pathways of the application boundary; o Watercourses within the application boundary (as detailed on Ordnance Survey 1:10,000 mapping) will be identified and located, in addition to existing and potential watercourse crossings, artificial and/or natural drainage pathways; o The quality and condition of the watercourse within the application boundary and sub-catchments will be obtained from NRW (details currently held by the Environment Agency) where available; o Flow characteristics of the catchments draining the application boundary, as any reduction in baseflows or a change in the magnitude and frequency of flood peaks in the rivers as a result of the proposed wind farm are critical issues with regard to flood risk, water supplies and aquatic ecology; and o The location and nature of public and private water supply abstractions within the application boundary and sub-catchments, recognised by local authorities and NRW. 4.9.5 The sensitivity of the sub-catchment hydrology will be assessed using the criteria defined in the table below: Receptor Criteria Sensitivity High The receptor has low capacity to absorb change without fundamentally altering its present character. o The receptor is of very high environmental value and/or National or International ecological status (i.e. SSSI, SAC, SEPA High waterbody status). o Environmental equilibrium is precarious and highly sensitive to change.

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o Designated salmonid fishery or for other freshwater ecological interests (e.g. freshwater pearl mussels). o Active floodplain. o Abstractions for public water supply; or abstractions for private water supply supplying more than 10 m3/day for human consumption or serves more than 50 persons. o Watercourse widely used for activities relating to water quality (e.g. fisheries, swimming, etc). Medium The receptor has moderate capacity to absorb change without significantly altering its present character. o The receptor has some environmental importance. Local or Regional ecological status (i.e. SEPA Good or Moderate waterbody status or target objective). o Environmental equilibrium is stable and copes well with natural fluctuations. o Designated cyprinid fishery, salmonids may be present and locally important for fisheries. o Contains some flood alleviation features. o Abstractions for private water supplies supplying less than 10 m3/day for human consumption or serves less than 50 persons (2). o Watercourse is not widely used for activities relating to water quality. Low The receptor is tolerant of change without detriment to its character and is of low environmental value. o Low ecological status (i.e. SEPA Poor or Bad waterbody status and not subject to higher target objectives). o Environmental equilibrium is stable and resilient to changes greater than natural fluctuations. o Fish sporadically present or restricted. o Does not contain any flood alleviation features. o No abstractions for private water supply. o Watercourse is not used for activities relating to water quality.

4.9.6 Once the sensitivity of the baseline environment has been assessed, a hydrological constraints map will be developed to ensure these sensitivities are

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taken into account in the layout design for the proposed wind farm infrastructure. The assessment of impacts on the surface water and groundwater baseline environment from the final design will then be conducted. The magnitude of changes to the baseline environment will be assessed based upon the level and duration of the change. If an identified receptor is sensitive to a change there will be an impact upon that receptor. The classification for the magnitude of change is summarised within the table below: Magnitude Change to the baseline environment Large o Long term loss of resource and/or quality; partial loss of or damage to key characteristics, features or elements. Moderate o Long term measurable change in attributes, quality or vulnerability; minor loss of, or alteration to, one or more key characteristics, features or elements; or o Short term loss of resource and/or quality; partial loss of or damage to key characteristics, features or elements. Small o Long term very minor loss or detrimental alteration to one or more characteristics, features or elements; or o Short term measurable change in attributes, quality or vulnerability; minor loss of, or alteration to, one (maybe more) key characteristics, features or elements. Negligible o Short term very minor loss or detrimental alteration to one or more characteristics, features or elements. No Change o No loss or alteration of characteristics, features or elements.

4.9.7 The impact assessment will follow a defined assessment criterion in which the final significance of an effect is a combination of the magnitude of a change and the sensitivity of the receptor to that change, as summarised in the table below: Magnitude of Change Site Sensitivity Large Moderate Small Negligible No Change

High Major Moderate Minor Negligible None

Medium Moderate Minor Negligible None None

Low Minor Negligible None None None

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4.9.8 Effects of a severity classified as Moderate or Major are deemed significant. Effects that are of a Minor, Negligible change or No Change severity are judged to be not significant. 4.9.9 The potential significant and residual effects will be identified, differentiating between short term construction and long term operational impacts. For each potential significant effect, mitigation measures will be derived to avoid, alleviate, minimise or remedy any adverse effects and enhance any positive benefits.

Baseline Surface Hydrology, Site Drainage and Flooding 4.9.10 The proposed development area lies within the watershed of the Afon Gam (to the north) and the Afon Rhiw (to the south) which lie within the River Severn catchment. The proposed development site drains to the Afon Gam via a number of tributaries to include Nant Wythan, Nant Menial and Nant Gelli- Gethin. 4.9.11 The Environment Agency’s Indicative 1 in 100 year River and Coastal Flood Map indicates some areas of Nant Wythan and Afon Gam are at risk of flooding, however this is confined to close proximity of the river channel. Geology, Hydrogeology and Soils 4.9.12 The proposed development area is comprised of sedimentary mudstone, sandstone and siltstone predominantly of the Penstrowed Grits formation with areas of Nantglyn Flags formation and Nant-ysgollon and Dolgau Mudstone formation. This is overlain in placed by Devensian Till and peat or is otherwise exposed at or near the surface. The extent and depth of peat across the site will be surveyed during the impact assessment, as detailed in Section 4.10. Land Use and Designated Sites 4.9.13 The proposed development site presents a complex topography of undulating hills and steep escarpments. Ordnance Survey mapping indicates the highest elevation is 425m of Mynydd Waun Fawr towards the east of the development area. The site contains some very steep slopes dominated by the north western slope of Mynydd Lluest y Graig. 4.9.14 The land use of the development area is dominated by open rough grassland with forested areas located to the western edge of the site. Surface runoff

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within the forestry areas is likely to have been modified runoff through uptake and forestry drainage. 4.9.15 The proposed development area contains two SSSI designated sites. These are Gweunydd Dolwen, located along the banks of the Afon Gam designated for unimproved acid grassland, and Bryn Coch located to the north of the site designated for Lowland Fen and acid grassland. Water Quality and Water Use 4.9.16 Nant Gam is currently of good ecological status and high chemical status as identified by the EA River Basin management Plans (RBMP). The Nant Rhiw waterbody is currently classified as having good ecological status and high chemical and biological status. 4.9.17 No abstraction licences were identified in the vicinity of the western extent of the site within the EA data request made in October 2007. An additional request was made in 2013 for the eastern extent of the site which returned the same result. An updated data request will be presented as part of the EIA consultation process. A number of discharges were identified within 2km of the proposed site, the majority of which comprise of private or agricultural effluent waste discharge. The main water use within the development area is for private water supplies of which a number have been identified within the site through previous consultation with residents. Powys County Council will be consulted again to ensure there are no additional properties potentially using a private water supply in the vicinity of the site. As the consultation with residents was conducted in 2006, residents will be consulted via letter to confirm the details of their supply are still correct. Ground Water Dependant Terrestrial Ecosystems 4.9.18 A number of potentially groundwater dependent terrestrial ecosystems (GWDTE) have been identified through an NVC survey undertaken on the western extent of the site in 2008. Existing surveys will be reviewed and the presence of GWDTE’s will be assessed.

Impact Prediction and Mitigation 4.9.19 The proposed wind farm may induce a series of potential adverse impacts upon the baseline hydrology, hydrogeology and geological environment within the vicinity of the proposed works. Impacts may arise during the construction, operation and decommissioning phases.

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4.9.20 The potential direct significant impacts of the proposed wind farm on the baseline environment relate to water quality, water resources and flood risk of the surface and groundwater in the draining sub-catchments. These impacts may then have indirect impacts upon the water use and aquatic ecology. The primary short term construction impacts include the potential for reductions in water quality through sedimentation, accidental release of pollutants and changes to in-stream hydrochemistry. The potential water quality impacts through enhanced erosion of disturbed peat will also be considered. The site will be assessed for flood risk in line with TAN15, although it is considered that a full Flood Risk Assessment will not be required. Construction of the wind farm has the potential to impact upon the supply of water to identified GWDTE’s through reducing the zone of contribution. 4.9.21 As the Gweunydd Dolwen and Bryn Coch SSSI sites are located within the drainage pathway of the site, there is potential for the sites to be impacted upon by the proposed development through reduced water quality. Felling of areas of commercial forestry may also impact upon the hydrology and hydrochemistry of the catchments, and the plantation drainage network may create short residence time pollution pathways. 4.9.22 The potential impacts arising from the operation of the site would primarily be through the accidental release of pollutants. The long term potential impacts of the infrastructure include an increase in impermeable areas which may impact upon site runoff, and if inappropriately designed, infrastructure may lead to sediment generation from concentrated runoff points. 4.9.23 Such impacts would be avoided as far as possible through the design process, and where this is not possible appropriate mitigation measures would be implemented to ensure potential impacts are minimised. A hierarchy of mitigation strategies will be devised following best practice guidelines including the Pollution Prevention Guidelines, the Water Framework Directive, and relevant NRW policies. Mitigation measures include appropriate drainage design, the use of runoff and sediment control measures where necessary and through the implementation of good working practice. The use of specific mitigation measures will be specified for every potentially significant effect identified in the ES.

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Residual Effects 4.9.24 The use of appropriate mitigation measures will reduce the potential impacts on this site from the proposed development. It is anticipated that all potentially significant effects will be mitigated via these measures and will not result in a significant residual impact.

Cumulative Assessment 4.9.25 The cumulative effects of developments within the local area will be assessed on a catchment basis. The size of the draining catchments and the proximity to current or proposed developments will be assessed to determine the likely cumulative impacts on the local environment.

4.10 Peat

Introduction 4.10.1 Given the known presence of peat deposits there is the potential for significant effects upon the peat during construction, operation and decommissioning of the scheme. The hydrological and carbon balance assessment of peat within the proposed development area will be considered within the Hydrology, Hydrogeology and Geology chapter of the ES. The impact of the development on peatland ecology will be assessed in the Ecology Chapter of the ES.

Published Guidance and Approach 4.10.2 The Waste Framework Directive (WFD) 2008/98/EC sets out the requirement to apply a waste hierarchy, this hierarchy in terms of this project should be considered as follows: a) Prevent peat excavation; b) Reduce volumes of peat excavated; and c) Reuse excavated peat in a manner to which it is suited. 4.10.3 A considerable body of guidance material has been produced for wind farm construction in the peat uplands of the UK, particularly in Scotland. Relevant guidance documents that will be considered during the ES are drawn from sources throughout the UK, which effectively constitute UK-wide best practice, as follows: o CCW, 2010. Guidance Note: Assessing the impact of wind farm developments on peatlands in Wales;

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o Scottish Renewables, SNH, SEPA, Forestry Commission Scotland (FCS) 2010. Good Practice During Wind Farm Construction; o Natural England, 2010. Investigating the impacts of windfarms on peatlands; o Scottish Renewables and SEPA 2012. Guidance on the Assessment of Peat Volumes, Reuse of Excavated Peat and the Minimisation of Waste; o SEPA 2012. Land Use Planning System SEPA Guidance Note 4 Planning guidance on wind farm developments; o Calculating Carbon Savings from Wind Farms on Scottish Peatlands – A new Approach (Nayak et al ., 2008; Nayak et al ., 2010 and Smith et al ., 2011); o SNH, SEPA, Scottish Government and The James Hutton Institute 2011. Guidance Developments on Peatland: Site Surveys; o Joint Nature Conservation Committee 2011. JNCC Report No. 445 Towards an assessment of the state of UK Peatlands; and o Scottish Executive 2006. Peat Hazard Landslide Risk Assessments Best Practice Guide for Proposed Electricity Generation Developments. 4.10.4 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The peat assessment will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

Assessment Methodology 4.10.5 The peat assessment will form part of the hydrology, hydrogeology and geology chapter, outlined in Section 4.9.

Baseline 4.10.6 A 100m grid peat depth survey has been conducted across the western half of the site and peat (>0.5 m depth) has been identified in areas across the site. The survey found depths of 0.25m to 2.9m (2.9m being the maximum extension of the survey probe) across the survey area with the greatest depths located in blanket bog habitats. The survey identified 5 areas of deep peat (>0.5m) with the most significant deposits in Cors yr Eboloin, a forested area in the west of the development area. This survey data will be supplemented with a 100m grid depth survey to ensure coverage within all areas being considered for development.

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4.10.7 Following design freeze, a detailed peat survey will be conducted at the infrastructure locations, consisting of a 10m corridor at 50m intervals along the proposed track and a 50m grid around the centre of each proposed turbine base. Peat core samples would also be taken at up to 10 spatially distributed locations to provide a reasonable indication of both horizontal and vertical variability. Each 0.5m sample within the core would be photographed, the degree of decomposition of peat determined using the von Post scale, and the levels of coarse and fine fibres and water content determined using the Hobbs scale. Bulk density would be estimated using the von Post scale. 4.10.8 The peat and hydrological information will be reviewed with reference to the peatland habitats noted during the collation of the ecological baseline. This will identify any areas of peatland habitat which would be sensitive to direct or indirect changes as a result of the proposals. The findings will be cross- referenced with the ecology chapter of the Environmental Statement.

Impact Prediction and Mitigation 4.10.9 Where peat is present, disturbance of deposits may result in instability, drying and oxidation of the peat, together with sedimentation and acidification of draining watercourses. 4.10.10 Disturbance of peat may result in carbon losses, therefore the payback period (number of years it will take the carbon savings to amount to the carbon costs) for the proposed wind farm development will be assessed using the latest version of the Scottish Government Carbon Calculator (currently version 2.8.0, 2014). The tool will be used early in the development process to advise the design process to reduce the carbon payback period and maximise carbon benefits. 4.10.11 Potential impacts also include both direct and indirect effects on the ecology of the peatland through landtake and changes in hydro-ecology . 4.10.12 A Draft Peat Management Plan will be developed to mitigate the potential impacts upon peat and peatland habitats (in particular blanket bog). The key aim of this plan is to first minimise peat excavation and disturbance, then to review options for reuse. The minimisation of peat excavation will be considered from the outset of the design using the existing depth data, which will be supplemented and refined using further survey data. The draft peat management plan will detail the likely volumes of peat that will be generated

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(including quantification of catotelmic and acrotelmic peat) and the principles of how the peat will be reused or disposed of. The plan will include the following details: o A description of the peat conditions on site; o Excavation and reuse volume estimates and reuse requirements; o Classification of excavated material; o Option for use of peat for restoration purposes (e.g. peatland restoration, ditch blocking etc); o The requirement for borrow pit restoration or other specific restoration areas on site; o Specification of the requirements for the handling of excavated materials; and o Construction programme and intended methods of handling and holding of excavated materials.

Residual Effects 4.10.13 The infrastructure layout will be designed to minimise the disturbance of peat and the use of appropriate peat management measures will reduce the potential impacts on this site from the proposed development. It is anticipated that all potential impacts will be mitigated and will not result in a significant residual effect.

Cumulative Assessment 4.10.14 The cumulative assessment of the hydrological impact to peat has been outlined in Section 4.9.25.

4.11 Electromagnetic Interference (EMI), Aviation and Shadow Flicker

Introduction 4.11.1 Wind turbines have the potential to interfere with military and civil aviation operations, primarily through effects on radar systems but also in respect of their location within military low flying areas. 4.11.2 The experience of existing wind farms is that television reception and other communications services, including nearby communications masts, can be affected by the rotating blades of wind turbines. As such an assessment of potential effects to telecommunications will be conducted.

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4.11.3 Shadow Flicker is described as the effect caused when an operating turbine is located between the sun and a receptor, whereby the shadow of the rotating blades falls over a dwelling causing the internal light intensity to fluctuate. Guidance recommended in NPS EN-3 explains that shadow flicker is unlikely to occur at greater than 10 rotor diameters from a wind turbine.

Published Guidance and Approach 4.11.4 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The EMI, aviation and shadow flicker assessment will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA. 4.11.5 In relation to both aviation and EMI the primary approach is one of consultation with the statutory and commercial bodies responsible for the operation of military and civilian radar and of the links used to relay the various types of television, radio and communication links.

Assessment Methodology, Impact Prediction and Mitigation 4.11.6 Consultations with telecommunications operators will be undertaken or reviewed and renewed where they have already been conducted. Any telecoms links crossing the site area will be factored into the EIA design process. 4.11.7 In a similar fashion, consultation with aviation stakeholders will identify any potential for interference with aviation interests. It is not considered likely that there will be any interference with civilian aviation interests due to the absence of civilian airports and radar in this area, and any interaction with military aviation interests is likely to focus on low flying activities. 4.11.8 In respect of military low flying appropriate mitigation will be proposed if required, including infra red lighting of turbines. 4.11.9 Within the shadow flicker assessment, the following will be undertaken: o Existing receptors (residential properties) within ten rotor diameters and within 130° either side of north of any turbine will be identified; o A shadow flicker analysis will be conducted for these properties using a proprietary and industry standard software; and o Where this analysis indicates that a given residential property will potentially be affected by shadow flicker the property will be visited and

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assessed for the presence of windows’ with a view toward the turbine and for buildings or vegetation which may provide screening. 4.11.10 Following this, the potential for shadow flicker to affect any property will be quantified in respect of the number of hours of shadow that the receptor will experience, including, when and how many days during each year, for how many hours it occurs in each day, and at what time of day. 4.11.11 Mitigation for shadow flicker will follow industry best practice and involve a scheme to curtail turbine operation during periods when shadow flicker may be experienced.

Residual Effects 4.11.12 No residual effects are expected to occur for any of these three topic areas given their well understood nature and the industry wide experience of successfully mitigating any such effects, either within the EIA and design stage of wind farm development or by appropriate controls secured by condition/requirement.

Cumulative Assessment 4.11.13 Where potential for cumulative effects are determined to exist, these will be assessed, although these are considered highly unlikely to occur.

4.12 Forestry

Introduction 4.12.1 The proposed Mynydd Lluest y Graig Wind Farm site contains approximately 603 hectares of forest which is in multiple, private ownership. 4.12.2 The forest areas can be characterised as upland forestry dominated by non- native tree species, the most common of which is Sitka spruce ( Picea sitchensis ). Smaller areas of broadleaved woodland exist within the development boundary as either plantation, Semi-natural or Ancient semi natural type woodland. 4.12.3 Large areas of the forests were established in the 1960’s and some of these areas have been harvested and restocked in recent times. Afforestation of bare agricultural land continued into the 1990’s and the last new planting took place in 2004. 4.12.4 The woodlands are found at elevations of between 210 and 420 metres above sea level on a range of soils from deep peat to Gleys.

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4.12.5 Most of the forest area is actively managed on either a clear felling or a continuous cover system. Smaller areas of broadleaved and coniferous forest have limited or no documented previous management whilst forest management plans are available for the majority of the coniferous areas. 4.12.6 Tree felling will be required within the development site to provide unobstructed locations for wind farm infrastructure such as the turbines and ancillary buildings. New and existing roads and cable routes will also require associated tree felling.

Published Guidance and Approach 4.12.7 The United Kingdom Forest Standard (Forestry Commission 2011) is the primary relevant standard along with its seven supporting guides: o Forests and Water; o Forests and People; o Forests and the Historic Environment; o Forests and Soil; o Forests and Climate Change; o Forests and Biodiversity; and o Forests and Landscape. 4.12.8 Woodlands for Wales strategy (WAG, 2009) and its eight supporting policy position papers which will be referred to are: o Heritage, Landscape and the Cultural Value of Welsh Woodlands and Trees; o Community Involvement with Welsh Woodlands and Trees; o Health and Well-being benefits from Welsh Woodlands and Trees; o Education, Learning and skills benefits from Welsh Woodlands and Trees; o Welsh Woodlands-their extent, nature and character; o Water and Soils, Policy position in support of Woodlands for Wales strategy; o Economic development and enterprise benefits from Welsh Woodlands and Trees; and o Biodiversity, Policy position in support of Woodlands for Wales strategy. 4.12.9 NRW has taken on the functions of Forestry Commission Wales under the Natural Resources Body for Wales (Functions) Order 2013 (WG 2013). NRW refers enquirers to many documents published by Forestry Commission UK or Forestry Commission Wales including Forestry Commission Wales Policy Position on Development Affecting woodlands (Forestry Commission 2010) and:

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o Technical Note: Protecting the Environment during Mechanised Harvesting Operations (Forestry Commission 2005); o Report: Brash Management on Habitat Restoration Sites (Forestry Commission 2003); o Report: A Strategic Assessment of the Afforested Peat Resource in Wales (Forestry Commission 2012); o Practice Note: Managing Brash on Conifer Clearfell sites (Forestry Commission 2006); o Forestry Practice Guide: Whole Tree Harvesting- A Guide to Good Practice (Forestry Commission 1997); and o Technical Paper: Designing Forest Edges to Improve Wind Stability (Forestry Commission 1996). 4.12.10 British Standard 5837:2012 (British Standards Institution 2012) Trees in relation to design, demolition and construction will be utilised as required. 4.12.11 The certification status of the forestry is not known at present but it will be incorporated into the baseline. 4.12.12 Whilst felling is not considered to be development requiring consent, if appropriate requirements may be included within the DCO that secure adherence to ensure that any felling is undertaken in accordance with agreed standards and procedures. 4.12.13 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The forestry assessment will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

Assessment Methodology 4.12.14 The study area will extend beyond the proposed DCO boundary, in particular at the western end of the site area where the largest block of woodland within the proposed DCO boundary is contiguous with woodland outside the boundary and, to a lesser degree, where this occurs with woodland on the central northern boundary. It is considered that these adjoining woodlands should be included particularly in respect of assessment of woodland management issues such as minimisation of windthrow in the forestry study area.

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4.12.15 Assessment will use the baseline GIS information (itself based on existing management plans) which will provide information on the location of infrastructure in relation to the forest and other features and: o An examination and discussion of the baseline existing conditions; o An assessment of the impacts of any tree felling required in the development area; o An assessment of the development against best practice guides; and o An assessment of the development using practical forest management experience. 4.12.16 In determining the significance of an effect, the magnitude of change and the sensitivity of the receptor are combined. For the Mynydd Lluest y Graig Wind Farm development the definitions of magnitude will be based on the areas of woodland impacted in relation to the existing conditions. In assessing the sensitivity of the forests and their management, it is considered that their status at International, European, UK or National level will be a key factor. The Impact assessment criteria are shown in the table below. Magnitude of Definition/Criteria Example Impact (positive or negative) Major An impact on one or more Loss of part of an Ancient International, European, UK or Semi-Natural woodland National receptors or a major land use change. Moderate An impact on one or more Loss of part of a semi-natural receptors of Regional value or a woodland. partial change or partial loss or gain. Minor An impact on one or more Loss of several minor trees receptors of county or Unitary from a native woodland. authority value or a minor land use change. Negligible An impact on one or more Loss of plantation woodland receptors of local value or a slight land use change Neutral Results in no measurable impact No change from baseline or change data.

Baseline 4.12.17 A forestry baseline in the form of a forest inventory database holding crop information and linked to GIS software is in preparation which will allow an overview of the entire wooded area and analysis of proposed development layouts and their impact on the crops present. The baseline will be informed by

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the individual management plans in existence for each forest property. Where no information is present it will be gathered through site investigation and forest mensuration. Site investigation will also be used to quality assure, through sampling, data provided from existing sources. 4.12.18 Information gaps may arise from a lack of felling plans and management plans for some smaller areas of woodlands. Where these are not available assumptions will be made about felling dates base on normal forest rotations and best practice guides.

Impact Prediction and Mitigation 4.12.19 The most significant potential source of impact will be from the preparation of the site prior to the construction of turbines and infrastructure. This will be in the form of tree felling/clearance to create the space required for the development. Tree felling and clearance will be needed for bases and foundations, the upgrading and construction of new access tracks/roads, excavation of quarries, cable routes and the construction of control buildings, meteorological masts, compounds and laydown areas. 4.12.20 Further impact in the operational phase may arise from maintenance works to tree cover around infrastructure and repowering works. Examples may include removing or cutting trees to maintain tree heights. During decommissioning it may be necessary to remove trees, which have regrown since construction, in order to access the infrastructure. 4.12.21 Potential key impacts include: o The risk of windthrow in adjacent crops; o Impacts on approved felling plan; o Impacts on forest certification; o Forest fragmentation arising from new infrastructure in the forest; o Impact on Welsh Government's Woodlands for Wales Strategy; o The potential loss of designated woodlands; and o Impacts on compliance with UK Forest Standard guidelines. 4.12.22 While more substantial felling in turbine areas is expected during construction, the majority of the forestry study area will return to the same land use post construction. Input into the design of the location of infrastructure will provide the primary means of mitigation. The redesign of felling coupes to include new infrastructure and windfirm edges will mitigate against the risk of windthrow

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and forest fragmentation. Woodland that has been designated as Ancient Semi- natural woodland (ASNW) (Ancient Woodland Inventory 2011) lies within the site boundary along with further areas of semi-natural woodland. Design of infrastructure will seek to avoid these areas. Where infrastructure is located near ASNW or other native woodland, British Standard 5837 (British Standards Institute 2012) will be used to mitigate the impact and ensure appropriate tree work is carried out.

Residual Effects 4.12.23 The residual effects will be assessed with the aid of the GIS baseline but it is considered that they are unlikely to be significant. The felling programme may provide opportunities for forest managers to amend species and management plans at the end of the construction period in order to fully integrate the wind farm and the forest. It is anticipated that new wind farm access tracks will also allow improved access to forestry vehicles including timber lorries.

Cumulative Assessment 4.12.24 The forestry impacted by the proposed development is spatially distinct from other afforested land and therefore the risk of cumulative impacts is considered to be low. It is possible that neighbouring projects could be under development at similar times and there could be a cumulative impact from forestry vehicle movements on local roads. 4.12.25 The ES will quantitatively assess designated native woodlands which appear on the Ancient woodland Inventory for impact from other projects within 20km.

4.13 Socio-economics, Recreation and Tourism

Introduction 4.13.1 The scale of the potential development is such that is has the potential to affect, both positively and adversely, the local economy, recreational assets and visitor experience. 4.13.2 The purpose of a Socio-economic Impact Assessment (SIA) is to consider effects both positive and negative as a result of the proposed Development on: o the local economy; o tourism; and o recreation and land use.

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4.13.3 The SIA will assess the construction and operational phases in terms of: o the project and cumulative effects; o the significance of these effects; and o potential mitigation measures. 4.13.4 The SIA will take into account the findings of other chapters such as the LVIA and Cultural Heritage assessment.

Published Guidance and Approach 4.13.5 The Welsh Government acknowledges the social, economic and environmental dimensions of sustainable development and in doing so embeds socio- economic considerations within the national policy framework. The government is committed to sustainable development by developing policy on matters such as climate change, transport, renewable energy, energy efficiency, waste management, biodiversity and public health. 4.13.6 The EIA Regulations state that an EIA shall identify, describe and assess in an appropriate manner, the direct and indirect effects of a project on human beings, and the interaction between human beings and other environmental aspects of the project. The SIA will seek to fulfil this requirement. 4.13.7 This assessment should consider all relevant socio-economic impacts, which may include: o the creation of jobs and training opportunities; o the provision of additional local services and improvements to local infrastructure, including the provision of educational and visitor facilities; o effects on tourism; o the impact of a changing influx of workers during the different construction, operation and decommissioning phases of the energy infrastructure. This could change the local population dynamics and could alter the demand for services and facilities in the settlements nearest to the construction work (including community facilities and physical infrastructure such as energy, water, transport and waste). There could also be effects on social cohesion depending on how populations and service provision change as a result of the development; and o cumulative effects – if development consent were to be granted to for a number of projects within a region and these were developed in a similar timeframe, there could be some short-term negative effects, for example a

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potential shortage of construction workers to meet the needs of other industries and major projects within the region. 4.13.8 The SIA should describe the existing socio-economic conditions in the areas surrounding the proposed development and should also refer to how the development’s socio-economic impacts correlate with local planning policies. 4.13.9 Socio-economic impacts may be linked to other impacts, for example the visual impact of a development may also have an impact on tourism and local businesses. 4.13.10 The socio-economic impact assessment will be mindful of the Powys County Mid Wales Conjoined Public Inquiry’s decision not to call evidence on the socio- economic impacts of the Mid Wales developments as they do not intend to pursue an argument that they should be refused on that basis 2. However, on a case by case basis assessment of the socio-economic impacts can help identify opportunities to optimise positive benefits and minimise negative effects. 4.13.11 The assessment will follow current best practice guidance as described above and set out in the following documents: o Green Jobs Strategy for Wales- Capturing the Potential (2009); and o Renewable UK Cymru (2013) Economic Opportunities for Wales from Future Onshore Wind Development. 4.13.12 Section 2 of this Scoping Report sets out the planning policy framework that is considered of relevance to undertaking the EIA for the proposed Mynydd Lluest y Graig wind farm. The SIA will, among other things, reference those topic specific policy or advice notes of relevance to this technical discipline of the EIA.

Assessment Methodology 4.13.13 The assessment will involve desk study, consultation, data processing and analysis as well as interpretation using professional judgement. The proposed development will be analysed within the socio-economic characteristics of the Study Area to identify the potential positive and negative effects on socio- economics, land use and tourism. 4.13.14 The ES Chapter will include: consideration of the social and economic policy context at the local, regional and national level; a review of local socio- economic baseline conditions at the site and in the surrounding area; expected

2 Updated Outline Statement Addendum 1

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future conditions in the absence of the proposed scheme; a description of likely the scale, scope, permanence and significance of identified impacts; and initial mitigation measures, where appropriate. 4.13.15 The impact assessment method will seek to balance a top down assessment of economic impact and bottom-up approaches which require a more detailed assessment of projected impacts at the local level. The methodology will align with guidance for UK and Wales as appropriate. It will detail data and literature sources, stakeholders and consultation and/or survey methods. Quantitative assessment will be based on evidence from previous studies, assumptions based on input-output models where available, and baseline socio-economic data. The assessment methodology will include an appraisal of impacts on other industries and land uses (via externalities and spillovers) such as the impact on tourism and recreation, agriculture and forestry, etc. These will be developed using benchmark examples and bespoke research evidence (such as through literature reviews, consultations and surveys). 4.13.16 The assessment of overall significance of effect will be based on combining the degree of vulnerability of the receptor to change with the magnitude of the predicted effects. The threshold of significance will vary across different socio- economic receptors and will be dependent on sensitivity and magnitude of effect. There are no standard significance criteria at present and professional judgement will be applied. The criteria for assessment of significance are set out in the table below. Significance Description of Effect

Major Where the extent of the effects on economic activities, local businesses, tourism and recreation or the local population is large in scale or magnitude, and a large number of people or activities would be affected (either positively or negatively).

Moderate Where the extent of the effects on economic activities, local businesses, tourism and recreation or the local population is small in scale or magnitude, and a large number of people or activities would be affected (either positively or negatively).

Or

Where the extent of the effects on economic activities, local businesses, tourism and recreation or the local population is large in scale or magnitude, but only a small number of people or activities would be

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affected (either positively or negatively).

Minor Where the extent of the effects on economic activities, local businesses, tourism and recreation or the local population is small in scale or magnitude and only a small number of people or activities would be affected (either positively or negatively).

Negligible Where the extent of the effects on economic activities, local businesses, tourism and recreation or the local population is barely noticeable in scale or magnitude and would only affect a small number of people or activities (either positively or negatively).

4.13.17 The key SIA impacts anticipated are as follows: o Opportunities for temporary (construction phase) and permanent (operational phase) local employment; o Indirect benefits via construction phase and permanent phase procurement expenditure benefiting local businesses and potentially stimulating additional local employment; o Induced (multiplier) effects from the effects of the two noted points above; o Potential negative impacts in terms of tourism and recreational activity and among businesses located in the area that meet the needs of tourists, day visitors and others seeking recreational opportunities; and o Impacts of the development on local education provision; skills and workforce development impacts, relating to upskilling opportunities provided by the scheme.

Baseline 4.13.18 The Study Area for the SIA would be Powys County Council (PCC) region, although it may also be appropriate to include a wider ‘travel to work’ area. 4.13.19 Powys is an inland authority in the heart of Wales comprising about a quarter of the area of the nation. The county borders eleven local authorities in Wales, and Shropshire and Herefordshire in England to the east. The principal towns in the authority include Abergavenny, Brecon, Builth Wells, Llandovery, Llandrindod Wells, Machynlleth, Newtown and Welshpool. 4.13.20 Census 2011 indicates that there are 133,071 people living in Powys (comprising 49.4% males and 50.6% females), compared to 3,063,758 residents in Wales as a whole. The percentage of residents aged 65+ accounts for 22.9% of the local population, which is higher than the percentage for Wales at 18.5%. Mean

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income in Powys was £30,690 in 2012, is a shade lower than that of Wales at £32,391. The percentage of working age people who are claiming Job Seeker’s Allowance in Powys is 2.3 %, compared to 4% in Wales (Department of Works and Pensions, 2012). 4.13.21 56% of Powys residents were born in Wales and 21% of people aged three or more can speak Welsh. Across Wales, 75% of all Welsh residents were born in Wales and 21% of people aged three or more can speak Welsh. A higher proportion of pupils in their final year of compulsory education achieved five or more GCSEs at grades A*-C (63.9); compared to the figure for Wales (57.7%) (Welsh Government 2011). 4.13.22 The Welsh Index of Multiple Deprivation 2011 ranks specific small areas in Wales in terms of deprivation: none of Powys’s areas fall in the 10% most deprived areas in Wales and the majority of its areas are less deprived than the Wales average. 4.13.23 Powys has many visitor attractions in the region in addition to stunning countryside and some particularly popular areas such as the Brecon Beacons National Park and the Elan Valley Estate. There are over 1,600 accommodation providers in the region, mainly consisting of small serviced and non-serviced accommodation. The STEAM Report- (Scarborough Tourism Economic Activity Monitor, Global Tourism Solutions (UK) Ltd, 2008) for 2008 indicates that Powys had 4.7 million visitors staying a total of 11.1 million days generating a total revenue across all expenditure sectors of £647.2 million. There were 1.42 million trips and 5.7 million bed nights in the same year. There are 6,793 serviced bed spaces in the county and 43,855 un-serviced bed spaces, including camping and caravanning. 4.13.24 Powys’ Visitor Profile - Wales Visitor Survey 2009 reveals the following statistics: o 33% of visitors to Powys in the survey were visiting as a Day Visitor; o 43% of Powys visitors were aged 55+, 41% were aged 35-54 and 15% were aged 16-34; o In terms of socio-economic grade, Powys visitors were more likely to be from the ABC1 grouping (professional and non-manual occupations) than average; 73% were ABC1 and 27% were C2DE (skilled and unskilled manual occupations, and non-working groups);

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o Looking at the type of trip being taken by Staying Visitors in Powys, 47% were on a short break, 31% on their main holiday of the year and just over a fifth (21%) on an additional holiday; o The main reason for choosing to visit Wales given by visitors to Powys was the scenery, landscape and countryside – mentioned by 52% of visitors. Other main reasons for visiting included the sightseeing and attractions (35%), peace and quiet (32%), historic sites (26%) and the history/heritage of the area (25%).

Tourism and Recreational Resources Baseline Survey 4.13.25 A tourism and recreational resources baseline survey will be conducted with tourist attractions and accommodation providers within the defined Study Area which have a view of the proposed Development. The key tourism assets and major accommodation providers will be mapped against the ZTV to help assess the possible visual effect at these locations and any changes to the visitor experience in the Study Area. 4.13.26 In respect of recreation and access, consultations will take place to assess the effects to users of the public rights of way, cycle routes and bridleways. This will include consultations with the local authority and relevant statutory and primary interest consultees.

Impact Prediction and Mitigation 4.13.27 Employment and GVA impact will principally be assessed through analysis of the planned investment and project details and supply chain – a large part of the employment and supply chain impact will stem from the construction phase, i.e. what is being constructed, how, by whom and where, as this may have direct effects on employment in the Study Area. While decisions about procurement are unlikely to have been finalised, the assessment will estimate the distribution of economic benefit to the local and national economy. Increases in investment will also have multiplier or knock-on effects in the rest of the economy through increases in wages and through the supply chain. The assessment of these factors would be based on published data, secondary evidence and professional judgement. 4.13.28 In the context of the socio-economic, the scale (i.e. number of jobs, Gross Value Added (GVA) of potential activity and duration of impacts (i.e. the number of

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years over which jobs and GVA persist/last) are the primary factors which determine the magnitude of effect. 4.13.29 The vulnerability of the receptor (the economies of the Study Area) describes the level of sensitivity to changes in GVA and employment now and over the lifetime of the project. 4.13.30 Mitigation measures will be considered to optimise beneficial effects and mitigate significant effects, for example, the timing of direct effects during construction, the maximising of the local supply chain through choice of design.

Residual Effects 4.13.31 The residual effects will include the positive, neutral and negative effects on employment, GVA, tourism and land use in the Study Area.

Cumulative Assessment 4.13.32 The SIA will consider the baseline characteristics of the local area of the Mynydd Lluest y Graig Wind Farm, and given nearby proposals, and the cumulative and synergistic effects arising from other developments in the Study Area. In relation to cumulative effect this will depend on the extent to which the supply chain has the capacity to meet demand from a number of projects. An assessment will be made as to whether it is likely that the cumulative effect indicates a loss of benefit due to competing projects or an enhancement of opportunity which helps to develop expertise and capacity in the supply chain. In terms of recreation the SIA will consider the findings of other disciplines (especially LVIA, Access, Transport and Traffic and Cultural Heritage) to assess the effects at the different phases of the proposed Development. 4.13.33 In terms of tourism consideration would be made of the cumulative effect of the proposed Development in the Study Area and whether there are sufficient substitute activities for tourists.

4.14 Suggested Planning Issues to be Screened or Scoped Out 4.14.1 The Applicant proposes that the assessment of the potential for the Proposal to affect local air quality is scoped out of the EIA and ES. During operation wind turbines produce little or no atmospheric pollution and standard (and effective) construction methods for dust suppression during construction and decommissioning will be sufficient to negate potential air quality effects potentially produced through wind farm related transport movements. Further,

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suitable maintenance of vehicles involved in the construction and decommissioning of the proposed wind farm would be required in line with current vehicle legislation to ensure their engine emissions are within acceptable thresholds. 4.14.2 In addition, issues involving wider atmospheric pollution such as the carbon balance of the proposed wind farm, will be addressed in other sections of the ES (as described in 4.10.10) where a calculation accounting for the carbon producing effects of building the proposed wind farm (including the energy balance of the manufacture and erection of the wind turbines themselves) and the effects of the disturbance of peat soils during construction (which may lead to the ‘unlocking’ of stored carbon) will be undertaken. 4.14.3 The Applicant also proposes that impacts upon registered historic landscapes be scoped out of the EIA and ES and does not propose to undertake an ASIDOHL. The nearest registered historic landscape is the Caersws Basin, the northern limit of which lies approximately 9km to the south of the Development Consent Order boundary. A key feature of the Caersws Basin is the degree to which it is enclosed by hills, which create a natural arena from which ‘ visual prospects…are confined in almost every direction ’. Given this and the distance of the proposed Development from the Caersws Basin, there is no potential for the proposed development to have a significant effect upon this registered historic landscape. There is similarly no potential for significant effects upon other registered historic landscapes in the wider area, which are a minimum of 11km from the proposed Development. 4.14.4 The Applicant seeks to screen out the need for any European Economic Association (EEA) Transboundary assessment and, while noting the guidance presented in Advice Note 12 regarding the provision of a screening matrix to aid the Secretary of State in determining this requirement, would suggest that a combination of the nature of the development i.e. an onshore wind farm proposal, and the distance from the nearest neighbouring EEA state (it is more than 180km to the east coast of the Republic of Ireland) precludes the likelihood of potential environmental impact beyond UK borders. 4.14.5 Further to the points above regarding the nature of the proposal and its proximity to EEA states, it is considered that the greatest likely geographical extent of any environmental impact will be that associated with landscape and

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visual effects which will not extend beyond UK borders (the Proposal is unlikely to be discernible to the human eye beyond 40km from the site boundary and is hence unlikely to create visual impact at this distance). Additionally, no migratory bird species in any number likely to present risk of a significant impact have been observed (either within the context of the current surveys or the earlier survey data presented in Appendix 5) and so no potential transboundary impact is expected to occur in this respect. 4.14.6 Finally, and as discussed in 4.4.16, the need for a Habitat Regulations Assessment will be screened once the relevant baseline conditions of the Proposal have been collected, analysed and reviewed.

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5 Draft Outline of the Environmental Statement and Other Documents

5.1 Environmental Statement 5.1.1 It is proposed at this stage that an Environmental Statement (ES) will be prepared that would comprise a Non-Technical Summary, Written Statement, and a Figures document. Detailed specialist reports, as required, will be included as separate Technical Appendices forming part of the ES. 5.1.2 The Written Statement will comprise chapters detailing: o Introduction; o Environmental impact assessment methodology; o Site selection and project evolution; o Project description; o Planning policy context; o Landscape and visual assessment; o Noise assessment; o Ecology; o Ornithology; o Hydrology, hydrogeology and geology; o Forestry assessment; o Archaeology and cultural heritage; o EMI, aviation, PRoWs and shadow flicker; o Access, transport and traffic; o Socio-economic assessment; and o Residual effects. These chapters will be supported by relevant drawings and photographs within the Figures document

5.1.3 A confidential annex may be provided which would contain any sensitive, confidential information, e.g. ornithological information. Initial circulation will be restricted to NRW and RSPB, with circulation to other parties subject to agreement by both organisations.

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5.2 Other documents 5.2.1 A separate Planning Statement will be prepared in support of the application for consent. The Planning Statement will not be part of the ES. It will discuss the relevant energy, environment and planning policies of relevance and assess the identified impacts against those. The Planning Statement will also set out the wider policy context for renewable energy development at the European and national levels. 5.2.2 In addition it is considered that the following supporting DCO application documents will be provided: o Consultation Report; o Environmental Protection Information; o Draft Development Consent Order; o Explanatory Memorandum; o Order Limits and Land Plans; o Works Plans; and o Grid Statement.

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Figure 1: Location of Proposed Mynydd Lluest y Graig Wind Farm

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Scale (at A3): 1:250,000 Date: March 2014

Prepared by:

Client:

Mynydd Lluest y Graig

Figure 1: Site Location

Drawn by: CJ Checked by: CTVersion: V1

Every effort has been made to ensure the accuracy of the information Contains Ordnance Survey data © Crown copyright 05 10 20 provided on this figure. Dulas Ltd cannot be held responsible for any omissions or errors in the data supplied by third parties and hereby expressly and database right 2014. Kilometers disclaims any responsibility for any losses, disappointment, negligence or damage caused by reliance on the information contained on this figure. Mynydd Lluest y Graig Wind Farm Scoping Report

Figure 2: Proposed Development Area for the Mynydd Lluest y Graig Wind Farm

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Scale (at A3): 1:50,000 Date: March 2014

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Mynydd Lluest y Graig

Figure 2: Proposed Development Consent Order Boundary

Drawn by: CJ Checked by: CTVersion: V1

Every effort has been made to ensure the accuracy of the information © Crown copyright and database rights 2014 00.75 1.5 3 provided on this figure. Dulas Ltd cannot be held responsible for any Ordnance Survey 0100030994 omissions or errors in the data supplied by third parties and hereby expressly Kilometers disclaims any responsibility for any losses, disappointment, negligence or damage caused by reliance on the information contained on this figure. Mynydd Lluest y Graig Wind Farm Scoping Report

Figure 3: Proposed Development Area in relation to Designated Sites and Planning Boundaries

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Proposed Development Consent Order Boundary ¯ 5km & 10km Buffer of Site Boundary County Boundaries Snowdonia National Park Special Area of Conservation Special Protection Area Site of Special Scientific Interest National Nature Reserve Important Bird Area

10km 5km

Scale (at A3): 1:150,000 Date: March 2014

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Mynydd Lluest y Graig

Figure 3: European & National Site Designations within 10km and Planning Boundaries

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Every effort has been made to ensure the accuracy of the information © Crown copyright and database rights 2014 02.5 5 10 provided on this figure. Dulas Ltd cannot be held responsible for any Ordnance Survey 0100030994 omissions or errors in the data supplied by third parties and hereby expressly Kilometers disclaims any responsibility for any losses, disappointment, negligence or damage caused by reliance on the information contained on this figure. Mynydd Lluest y Graig Wind Farm Scoping Report

Figure 4: TAN8 Strategic Search Areas B, C and D and Wind Farms within 35km of the Proposed Development Consent Order Boundary

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Proposed Development Consent Order Boundary Braich Ddu TAN 8 Strategic Search Areas ¯ 35km Buffer of Site Boundary Mynydd Mynyllod

Cumulative Data Garreg Lywd Hill, Appeal/Public Inquiry Wind Farm Name and Status Hirddywell, Application Submitted Braich Ddu Farm, Operational Llaithddu, Conjoined Inquiry Bryn Titli Extension, Design/Scoping Llanbadarn Fynydd, Conjoined Inquiry Bryn Titli, Operational Llanbrynmair, Conjoined Inquiry Bryngydfa, Application Submitted Llandinam Repowering, Conjoined Inquiry Carnedd Wen, Conjoined Inquiry Llandinam, Operational Carno I, Operational Mynydd Clogau, Operational Carno II, Operational Mynydd Gorddu, Operational Carno III, Application Submitted Mynydd Mynyllod, Design/Scoping Cefn Croes, Operational Mynydd y Gwynt, Design/Scoping Cemmaes 2, Operational Nant y Moch, Design/Scoping Cemmaes 3, Appeal/Public Inquiry Neuadd Goch Bank, Application Submitted Dyfnant Forest, Design/Scoping Rheidol, Operational Dyfnant Forest Esgair Cwmowen, Application Submitted Tirgwynt, Consented

Carnedd Wen Cemmaes 3 SSA B

Cemmaes 2

Llanbrynmair Tirgwynt Esgair Cwmowen Mynydd Clogau Carno II SSA D Carno I Nant y Moch Carno III Scale (at A3): 1:300,000 Date: March 2014

Mynydd Gorddu Prepared by: Mynydd y Gwynt Llandinam SSA C Llandinam Repower Neuadd Goch Bank Rheidol Llanbadard Fynydd Cefn Croes Client: Bryngydfa Hirddywel Garreg Llwyd Hill Bryn Titli Extension Llaithdu Mynydd Lluest y Graig Figure 4: Tan 8 SSAs B,C,D and Wind Farm Bryn Titli Developments within 35km and their status

Drawn by: CJ Checked by: CTVersion: V1

Every effort has been made to ensure the accuracy of the information Contains Ordnance Survey data © Crown copyright 05 10 provided on this figure. Dulas Ltd cannot be held responsible for any omissions or errors in the data supplied by third parties and hereby expressly and database right 2014. Kilometers disclaims any responsibility for any losses, disappointment, negligence or damage caused by reliance on the information contained on this figure. Mynydd Lluest y Graig Wind Farm Scoping Report

Appendices 1-5: Ecology Appendices A1-A5

A.1 Legislation and Guidance The Ecology and Ornithology EIA will take account of current legislation and guidance, where applicable, including:

• Wildlife and Countryside Act 1981. • Conservation of Habitats and Species Regulations 2010. • EU Birds Directive 2009/147/EC. • EU Habitats Directive 1992/43/EEC. • Protection of Badgers Act 1992. • Hedgerows Regulations 1997. • UK and Powys Biodiversity Action Plans. • Wales Biodiversity Partnership (2012) Natural Environment & Rural Committees Act 2006: Section 42 list of species of principle importance for conservation of biological diversity in Wales. • Chartered Institute of Ecological and Environmental Management (CIEEM) (2006) Guidelines for Ecological Impact Assessment. • Joint Nature Conservation Committee (JNCC 1990) Handbook for Phase I Habitat Survey: A technique for environmental audit. • Rodwell, J. S. (1991 – 1997) National Vegetation Classification. British Plant Communities. Volume 1 – 5. • Bat Conservation Trust (2012). Bat Surveys: Good Practice Guidelines (2nd edition). • Bat Conservation Trust (2004) Bat Mitigation Guidelines. • Natural England (2012) Technical Information Note TIN051 – Bats and onshore wind turbines – Interim Guidance. • English Nature (2001) Great Crested Newt Mitigation Guidelines. • Langton et al . (2001) Great Crested Newt Conservation Handbook. • Froglife (1999) Reptile survey: an introduction to planning, conducting and interpreting surveys for snake and lizard conservation: Advice Sheet 10. • Oldham et al . (2000). Evaluating the suitability of habitat for the Great Crested Newt (Triturus cristatus ). Herpetological Journal 10 (4), 143-155. • Scottish Natural Heritage (2013) Recommended bird survey methods to inform impact assessment of onshore wind farms. • SNH (2010) Use of Avoidance Rates in the SNH Wind Farm Collision Risk Model. • SNH (2010) Windfarms and Birds: Calculating a theoretical collision risk assuming no avoiding action. • SNH (2013) Recommended bird survey methods to inform impact assessment of onshore wind farms; • SNH (2005) Environmental Assessment Handbook: Guidance on the Environmental Impact Assessment Process (SNH 2005); • SNH (2000) Windfarms and Birds: Calculating a theoretical collision risk assuming no avoiding action. • SNH (2006) Assessing Significance of Impacts from Onshore Windfarms on Birds outwith Designated Areas (SNH 2006). • SNH (2012) Assessing the cumulative impacts of onshore wind energy developments. • Gillbert et al . (1998) Bird Monitoring Methods. • Hardey et al . (2013) Raptors: a field guide to survey and monitoring, 3rd Edition .

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A.2 Review of Historic Surveys

Mynydd Lluest y Graig Wind Farm comprises two historical wind farm proposals for which a wealth of floral and faunal survey data exists which has been reviewed to inform the EcIA, as summarised in the Tables below. The key documents reviewed include:

• Mynydd Waun Fawr Wind Farm ES, 2007 (surveys 2005 - 2008) and Supplementary Environmental information (2009) as requested by consultees following submission to address issues raised and report additional surveys; and • Rhyd Ddu Wind Farm Baseline Data, 2013 (surveys 2008 – 2012) – this internal report sets out the baseline sections of the Environmental Statement that was being created prior to the project being put into abeyance in 2009 but also includes the results of breeding curlew surveys that continued until 2012.

The information derived from the historic data review has been used to inform the scope of further survey work and potential impacts including the 2013/2014 winter ornithology surveys agreed with statutory consultees that are currently taking place.

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Review of historical survey data relating to the Mynydd Waun Fawr Wind Farm proposals

Topic Area Periods of Data Collection Survey and assessment methodologies used Key Findings Extended Phase 1 2005 & 2006 & Updated Best practice (JNCC). Botanically important acid grassland and March 2008 (SEI) blanket bog habitats. Peat estimated to occupy 96ha.

Hedgerow Regulations 2005 & 2006 According to regulations criteria. None Badger 2006 Standard. 9 setts Otter & Watervole 2006 & 2008 (SEI) Search area increased from 100m to 250m Evidence of occasional otter use in the form of upstream and downstream of site as part of spraints along watercourses and around upland SEI on request. waterbodies. Great Crested Newts 2006 & 2007 Habitat Suitability Index (HSI) (Oldham et al N/A 1990) assessment only. Justification for not carrying out further surveys agreed under consultation owing to low suitability of upland waterbodies. Bat Roost Assessments 2008 Two buildings subject to inspections and one No roosts identified and limited potential. emergence survey (BCT 2007). Bat Activity 2008 3 transects walked on three occasions in Low foraging/commuting activity recorded by summer and autumn, 8 static detectors which low risk species (pipistrelle species accounted collected 29 nights worth of data (BCT 2007). for 89% Anabat contacts) along the few suitable vegetative features. No bat species of high risk to turbine collisions were recorded. Reptiles 2005 & 2006 Habitat suitability assessed only. Incidental lizard sightings.

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VP Surveys May 2005 - March 2006 2 - 3 VPs (3rd Vp discontinued following Peregrine recorded on one occasion, barn owl decision not to site turbines in this area). breeding location recorded off site, red kite Survey effort of 36hr per VP per season. recorded twice in winter and twice in summer, Undertaken in accordance with SNH guidance hen harrier recorded 5 times in winter, several (2005). small and one large (200+) golden plover flocks recorded flying over in winter. Moorland Breeding Birds 2005 2 visits including the site and adjacent habitats Five pairs of breeding curlew and four pairs of (Brown & Shepherd 1993). snipe recorded around the fringes of the site. Woodland Point-count Spring 2005 5 point count locations surveyed on two Nothing of note. occasions (Bibby 1992). Short-eared Owl May/June 2005 2 visits (Gilbert et al 1998) within site. Nothing recorded. Waterbody Point Counts May 2005 - March 2006 4 spring counts and 7 winter counts at the five Flock of 20 & 36 Teal at Llyn Newydd and flock in Summer and Winter upland water bodies present on or in close of 45-50 brent geese at Llyn Hir in winter. proximity to the site (Lyn Hir, Lyn Newydd, Lyn Breeding pair of great crested grebe, teal and y Grinwydden, Lyn Lort and Lyn y Bugail). black-headed gull and 11 pairs of Canada goose. Hen Harrier Roosting October 2006 - March 9 winter visits (Gilbert et al 2002). Intermittent roost used by single male just off 2007 site (appeared to alight in a similar area twice at dusk)

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Review of historical survey data relating to the Rhyd Ddu Wind Farm proposals.

Topic Area Periods of Data Collection Survey and assessment methodologies used Findings Principally 2008 but access rd Extended Phase 1 Best practice (JNCC) Notable acid grassland and bog habitat. and track 2009 - 2011 NVC 2008 Best practice (Rodwell 1991 & 1992) 11 locations of notable botanical value 2009 and connecting track Peat depth and extent survey within site and Peat Analysis 5 areas of deep peat occupying 123ha 2011 connecting track (no best practice guidance). Presence or absence survey along 12 transects Red Squirrel October 2008 Nothing found covering 3 woodland blocks (Gurnell et al 2001). 10 watercourses and 4 waterbodies surveyed Otter & Watervole October 2009 Evidence of otter only (Strachan and Moorhouse 2006). Habitat Suitability Assessment (Oldham et al. 1990) and surveying of 5 waterbodies with Great Crested Newts 2008 & 2009 reference to best practice guidance (English None Nature 2001). No access was available to two further waterbodies. 23 structures (e.g. buildings, trees, quarries) Bat Roost October 2009 within 250m of the site with potential (varying No roosts Assessments degrees). 3 transects walked/driven on 7 occasion’s Low level activity predominantly by low risk spread over two survey seasons. 29 static species (92% recording related to pipistrelle August - October 2008 & May Bat Activity locations for a total of 135 nights including species). High risk species noctule (2% - October 2009 some at met mast height (BCT 2007, NE 2008, recordings, predominantly off site) and Leisler PCC 2009) (only 2 contacts) were also recorded. Reptiles None None Lizard incidentally recorded

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4 VPs - survey efforts of 36hr per VP per season Hen harrier, red kite, goshawk, peregrine, VP surveys 2007 - 2009 undertaken in accordance with SNH guidance hobby, curlew and golden plover most notable (2005). species recorded. 3 visits each season to suitable habitat within a No breeding waders on site but some curlew, Moorland Breeding 2008 & 2009 500m buffer zone (modified Brown & Shepherd snipe and sandpiper breeding in the wider Birds 1993). area. Woodland Point- 15 locations subject to 10 visits (Bibby et al Nothing of note (no breeding crossbill 2008 & 2009 counts 2000) recorded - only over winter records). 17 walkover surveys (twice monthly) of habitat Winter Walkover 2007-2008 Nothing of note. up to a 1km buffer zone. 4 visits to suitable habitat within a 2km buffer Raptor Walkover 2009 No breeding raptors identified. zone. 7 visits (Boyce et al 2005) within a 1km buffer Goshawk 2008 No breeding activity. zone of the site. 4 visits each year (Gilbert et al 1998) to clear fell Nightjar 2008 & 2009 and young coniferous plantation woodland on None recorded site. 2 visits to one suitable area on site and one Black Grouse 2009 other suitable area identified within 1km of the None recorded site. 3 visits to suitable habitat within a 500km Snipe 2008 Breeding outside of site. buffer zone. 2 visits (Hardey et al 2006) to a vantage point Barn Owl 2008 near a disuded farm building outside of the site Nesting pair outside of the site. to record breeding activity. 3 visits each season to suitable habitat within a Supplementary No breeding curlew within site but two within 2010 -2012 500m buffer zone (modified Brown & Shepherd Breeding Curlew an 800m buffer. 1993).

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A.3 Impact Assessment Methodology

Following desk studies and field surveys, and in light of consultations, the issues of concern and Valued Ecological Receptors (VERs) (including species, communities, habitats and ecological processes) within the site and adjacent areas will be identified. Definitions will be derived for the importance of each VER and the magnitude of direct and indirect impacts, with reference to current CIEEM guidance (2006).

Once a potential significant impact is identified as likely to affect the integrity/favourable conservation status of a potential VER, the value of the receptor is then used to help determine the geographical scale at which the impact is significant. The significance of the potential impacts upon VERs will be assessed both before and after consideration of additional mitigation measures. The latter represents the assessment of the residual impacts of the project.

Geographical Context

The CIEEM Guidelines recommend that the value or potential value of an ecological resource or feature be determined within a defined geographical context and recommends that the following frame of reference be used:

• International; • UK; • National; • Regional; • County; • Local; and • Within zone of influence only (typically at site level only).

Valuing Designated Sites

Within the UK, certain valued habitats have been assigned a level of nature conservation value through designation; and the CIEEM Guidelines referred to above recommend that the reasons for this designation need to be taken into account in the assessment. Such designations include:

• Internationally important Sites such as SACs, SPAs and Ramsar Sites; • Nationally important Sites such as SSSIs and National Nature Reserves (NNRs); and • Regional/Locally important Sites, which are referred to as Local Wildlife Sites (LWSs) in Powys.

Where a feature has value at more than one designation level, its overriding value is that of the highest level.

Valuing Biodiversity

The CIEEM Guidelines state that there are various characteristics that can be used to identify ecological resources or features likely to be important in terms of biodiversity; furthermore, that consultation, especially with local specialists, can be crucial for identifying less obvious important resources and features. The Local Biodiversity Action Plan (LBAP) for Powys are some of the

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Valuing Habitats

The CIEEM Guidelines recommend that the value of areas of habitat and plant communities should be measured against published selection criteria where available. Where areas of a habitat or plant communities do not meet the necessary criteria for designation at a specific level, the CIEEM Guidelines recommend that the ecologist may consider the local context if appropriate. Valuation will also take account of the geographical context of the habitat in addition to using professional judgment in determining the value.

Valuing Species

Species should be assessed according to their biodiversity value rather than according to their legal status; although some species will fit into both categories. In assigning value to a species, it is necessary to consider its distribution and status, including a consideration of trends based on available historical records. The evaluation of populations should make use of any relevant published evaluation criteria and professional judgment will be used in determining the valuation.

Summary of the approach to valuing ecological receptors at different geographic scales

Level of Value Examples

International Internationally designated sites (e.g. SAC, cSAC, SPA, pSPA, Ramsar site).

or site meeting criteria for international designations.

Species present in internationally important numbers (>1% of biogeographic populations) or habitats or species that form part of the cited interest within an internationally protected site.

National Nationally designated sites (e.g. SSSI or NNR) or sites meeting the criteria for national designation.

Species present in nationally important numbers (>1% UK population).

Large areas of priority habitat listed on Annex I of the EC Habitats Directive and smaller areas of such habitat that are essential to maintain the viability of that ecological resource.

Regional Species present in regionally important numbers (>1% of the Natural Heritage Zone population).

Local Wildlife Sites including Montgomeryshire Wildlife Trust Reserves & Local Nature Reserves (depending on their condition)

Presence of National and Local Biodiversity Action Plan (BAP)

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Level of Value Examples

species (depending on their population status).

Local Habitats or species that form part of the cited interest of a local level designated site (e.g. Local Wildlife Sites) (depending on their condition) and BAP species (depending on population status).

A feature (e.g. habitat or population) which is of nature conservation value in a local context only, with insufficient value to merit a formal nature conservation designation.

Negligible A widespread or common habitat and species. Loss of such a feature would not be seen as detrimental to the ecology of the area and is normally scoped out of the assessment process.

Summary of the approach to valuing ornithological receptors at different geographic scales

Level of Value Examples International Species for which an internationally protected site (e.g. SPA, Ramsar) has been designated. Species present in internationally important numbers (>1% of biogeographic/flyway populations). Species listed on Annex I of the EC Birds Directive if present in qualifying numbers/proportions of national /international population. National Species that contribute to the integrity of an SPA or SSSI but which are not cited as species for which the site is designated (SPAs) or notified (SSSIs). Ecologically sensitive species such as rare birds (<300 breeding pairs in the UK). Species present in nationally important numbers (>1% UK population). Species listed on Annex 1 of the EC Birds Directive or breeding species listed on Schedule 1 of the Wildlife and Countryside Act. Regularly occurring relevant migratory species, which are either rare or vulnerable, or warrant special consideration on account of the proximity of migration routes, breeding, wintering and staging areas in relation to the Development. Regional Species for which a locally designated site (e.g. LWS) has been designated. Species present in regionally important numbers (>1% regional population). Significant populations of species on the red-list for Birds of Conservation Concern or subject to national and local BAPs.

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Level of Value Examples Local Other species of conservation interest, e.g. red- or amber-listed species of Birds of Conservation Concern or subject to BAPs not covered above. Negligible All other species not included in the above categories, such as small populations of green-listed species. Such species are normally scoped out of the assessment process.

Characterising Potential Impacts

The CIEEM Guidelines state that the assessment of impacts should be undertaken in relation to the baseline conditions within the zone of influence that are expected to occur if the development were not to take place. Having identified the activities likely to cause significant impacts, it is then necessary to describe the potential resultant changes and to assess the impact on valued ecological resources.

The CIEEM Guidelines recommend that the process of identifying impacts should make explicit reference to aspects of ecological structure and function on which the feature depends. Impacts must be assessed in the context of the baseline conditions within the zone of influence during the lifetime of the project.

The CIEEM Guidelines further state, that it is important to consider the likelihood that a change/activity will occur as predicted, and also the degree of confidence in the assessment of the impact on ecological structure and function. The limitations to certainty should be described and the consequences for confidence in predictions must be stated clearly.

When describing changes/activities and impacts on ecosystem structure and function, reference should be made to the following factors:

• Positive or negative; • Magnitude; • Extent; • Duration; • Reversibility; and • Timing and frequency.

In order to characterise the likely change and impact, it is necessary to take into account all the above factors.

It is also important to consider the likelihood that a change/activity will occur as predicted and the degree of confidence in the assessment of the impact on ecological structure and function. The limitations to certainty should be described and the consequences for confidence in predictions must be stated clearly. The following four-point scale has been adopted to describe the degree of confidence in the assessment of the impact on ecological structure and function:

• Certain/near-certain – probability estimated at 95% chance or higher;

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• Probable - probability estimated above 50% but below 95%; • Unlikely - probability estimated above 5% but below 50%; or • Extremely unlikely – probability estimated at less than 5%.

Assigning Significance

Having followed the process of attributing a value to a receptor and characterising potential effects, the significance of an effect is then determined. Legislation and policy often require significant negative or positive impacts to be distinguished from others, although there is little guidance on how this distinction should be made. The CIEEM Guidelines define an ecologically significant impact as an “impact (negative or positive) on the integrity of a defined Site or ecosystem and/or the conservation status of habitats or species within a given geographical area”.

In accordance with the CIEEM Guidelines, the assessment approach will not utilise traditional matrices that compare the value of a receptor and magnitude of impact, in combination with professional judgement, to ascertain the level of significance of an impact as minor, moderate or major. Instead it seeks to simply evaluate whether an impact is significant or not according to factors such as the size/extent and conservation status of a species population or habitat in the context of its natural geographical range. Addressing each effect qualitatively in its own right is considered to be a more robust approach.

If an impact is not found to be significant at the level at which the resource or feature has been valued, it may still be significant at a more local level. An impact that is of significance at, or below, a local level, or is deemed not to be significant, will be scoped out of the impact assessment unless there are legal implications associated with the impact which will otherwise be stated.

Although certain species and habitats may not constitute VERs based upon their nature conservation value, they may still warrant consideration during the design of the development (and any mitigation identified) on the basis of their legal protection, their implications for policies and plans, or other issues, such as animal welfare.

Significance Criteria

Once a potential significant impact is identified as likely to affect the integrity/favourable conservation status of a potential VER, the value of the receptor is then used to help determine the geographical scale at which the impact is significant. The significance of the potential impacts upon VERs has been assessed both before and after consideration of additional mitigation measures. The latter represents the assessment of the residual impacts of the project.

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A.4 Consultation on Winter Bird Surveys

NRW and RSPB were contacted in October and November 2013 to agree the scope of winter bird surveys proposed to inform the proposals including the types of survey and effort level employed. This included a telephone conference call with Carol Fielding of NRW held on 16 October 2013 and preceding and subsequent email correspondences with both Carol Fielding and Simon Hugheston- Roberts of the RSPB as detailed below.

Dr Carol Fielding - Montgomeryshire Team Leader, Natural Resources Wales

Email 25/10/13

Dear Conrad/Rob,

Thank you for your email below of 23 October 2013 setting out a suggested scope for winter avian surveys for the proposed Mynydd Waun Fawr - Rhyd Ddu windfarm in Montgomeryshire. Thank you also for the additional information which you have supplied on historical surveys undertaken at the site and for arranging an initial discussion on the surveys in a telecon on 16/10/13.

My current understanding is the proposed windfarm would be for approximately 35 turbines in an area to the south-east of Nant yr Eira within SSA B. Other historical data are available for other proposed windfarms in the area including Carnedd Wen, Llanbrynmair and Tre Gwynt. Knowledge of this information has helped informed my advice below. I have also worked on a number of windfarms adjacent to the proposal over a period of 5 years.

Natural Resources Wales advises that the SNH guidance 'Recommended bird survey methods to inform impact assessment of onshore windfarms ' (August 2013) is used to inform baseline surveys for onshore windfarms. In the first instance we therefore advise that you follow the recommendations in this guidance subject to agreeing any derogations with ourselves. Where my advice below does not specifically refer to an issue then you should assume that the guidance in this document is relevant. Where there is a lack of detail regarding your survey methodology I have assumed that you are adhering to this guidance. If this is not the case then you should discuss this with us at the earliest opportunity.

Our scope below covers the turbine envelope. As discussed in our telecon of 16/10/13 you will also need to consider the need for avian surveys with regard to ancillary infrastructure including power lines and off-site road works. NRW would expect the potential significant effects of this infrastructure on ornithology to be considered within the ES for the windfarm.

VP surveys

Thank you for the map illustrating the predicted visibility from the six proposed vantage points and your additional email of 25 October 2013 providing additional information on the VPs.

We cannot confirm visibility from these VPs without undertaking our own reconnaissance surveys and you should ensure that the visibility on the map matches that on the ground. We are broadly happy with the number of viewpoints and their suggested location. Our main concern is that these VPs provide sufficient visibility to encompass any need to change turbine locations in the future and

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One aspect of the VPs which you should consider is that VP2 is located within an area known to support breeding curlew. You should therefore consider whether this would be a suitable breeding survey VP as its use could cause disturbance early in the breeding season. The VP surveys cover March which is when breeding curlew may be back on the site. Is there an alternative location for VP2?

Water body point counts

We discussed at our meeting of 16/10/13 as to whether further additional desk study could be undertaken to collate records of the use of the lakes by birds. I understand that given the relatively short timescales that this has been difficult. I would recommend that you further pursue this asap so that as much information as possible can be collated on the use of the lakes. As you have stated in your email there may be a second year of winter survey so this may be important to help inform future work. The desk study should inlcude a Powys BIS search and a request of records from the Montgomeryhsire County Bird recorder.

In your email of 23/10/13 you have suggested that the VP and hen harrier roost surveys could be used as a surrogate for water body point counts. My concerns with this are that the VPs have been selected for visibility above a height of 25m so only flights to and from the lake would be recorded using this methodology. Settled birds on the lakes within the VPs survey times would not be recorded. The topography of the site also means that the lakes are not clearly visible from other parts of the site during hen harrier roost surveys and movements between VPs.

The winter water body point counts undertaken to inform the Mynydd Waun Fawr ES recorded waterfowl on the lakes including a flock of dark bellied brent geese. We are also aware that a flock of whooper swans use upland lakes in the near vicinity although it is unclear if they use Llyn Hir.

I also note that the proposed turbine lay-out includes turbines in the neat vicinity of the waterbodies. The historical data for Mynydd Waun Fawr was collectd in the winter of 2005-6 and by the time that the ES for the new windfarm was submitted would be approximately 8 years old.

Taking all the above factors into account NRW's advice is that you undertake water body point counts. We will need to discuss the frequency of these counts. For the MWF ES they were collected monthly. I suggest that this year point counts are taken every two weeks. Based on the results of the desk survey this may need to be revised.

Winter transect surveys

I agree with the comments provided by RSPB on this matter. Again the age of the previous baseline data means that we consider update surveys are required.

Please note that information is required on the use of the forestry areas by breeding crossbills and mitigation may be required for this Schedule 1 species during any forestry felling to precede infrastructure felling. I note that the SNH guidance recommends that a survey is done post consent however we would need to discuss that you are happy to accept a potential planning requirement that breeding crossbill surveys are required pre-felling.

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I note that there appear to be records of short-eared owls from the MWF plateau and your surveys need to take this into account.

You need to take into account that displaying raptors may be present on the site in early spring and the late winter surveys will be the surveys in which goshawk and hen harrier nests may be most apparent. This is particularly important as the Rhyd Ddu forestry has previously been known to support goshawk. To date we have not discussed the breeding bird surveys but you need to be aware that the wintering bird surveys may provide information on breeding locations.

Your original email of 14 October 2013 raised the issue of whether two years of wintering bird surveys were required in light of previous data for the site. At this stage I would assume that two years are required but this can be reviewed after year 1 in the light of the data collected.

I hope these comments are helpful and please come back to me if you wish to discuss any of the above or require clarification on any matter. kind regards

Carol

Simon Hugheston-Roberts – RSPB

Email 25/10/13

Dear Conrad/Rob

Thanks to you both for providing the initial proposed bird survey effort and additional information on Zones of Visual Influence.

I would like to provide comments on the following parts of the winter bird surveys:

VP Surveys

The number, position and overall coverage appear to be satisfactory.

Water body point counts

It is most important that these areas are adequately covered as they can potentially attract large numbers of transient birds. It may be possible to detect waterbirds present on the lakes during vantage point surveys. However, it would be far better to undertake specific counts to ascertain of the usage of each water-body and present the data accordingly. Please also ensure that you obtain any outstanding waterbird data from the county recorder.

Winter transect surveys

These walkover surveys are necessary and should be informed by the results of the VP survey work. This additional survey effort allows detailed recording and plotting of foraging flocks of passerines and/or daytime roosts of species such golden plover, often detected during VPs.

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If you require further information in relation to this matter, please do not hesitate to contact me. I would be grateful if you could keep me informed as to future developments in relation to this project.

Kind regards

Simon

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A.5 Target Bird Species Based on the ongoing field surveys, the extant survey data (from both the former site proposals, see Appendix A.2 , and adjacent wind farm proposals) and records received during the course of the desk study a preliminary list of target species has been drawn up as detailed in the table below.

Bird Species Desk study records and/or historical survey Ongoing Survey Records findings

Schedule 1 (i) Annex 1 (ii) BoCC (iii) Wales orUK LBAP (iv) / Section 42 (v)

Hen Harrier x x R Low level activity recorded on site Single adult male observed over eastern and central parts of (Circus cyaneus ) predominantly in winter. No breeding activity site during Oct, Nov and Dec 2013 (6 occasions in total). No was recorded however a possible intermittent apparent roost within site area but may have roosted winter roosting site was identified adjacent to occasionally near Llyn Lort to south of site. the eastern site boundary.

Red Kite x x A L Low level foraging recorded over the site with Recorded once within site (VP5 Nov 2013). Up to 2 birds (Milvus milvus ) higher levels towards the sites western extent. recorded from VP1 and 6 but well outside 500m buffer. No breeding activity observed.

Peregrine x x G Recorded on four occasions on site during One recorded outside 500m buffer from VP6 (Dec 2013). (Falco peregrinus ) survey work. No breeding activity observed.

Merlin x x A Single recording made on site. Male and female recorded from VP4 (Dec 2013) plus singles (Falco columbarius ) from VP4 (Nov 2013) and VP5 and 6 (Dec 2013).

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Goshawk x x G Recorded on site in association with the Single males and females recorded over site during all (Accipiter gentilis ) coniferous habitat within the sites western months apart from Nov. Most activity associated with extent but no breeding activity observed conifer woodland viewed from VP6 (1 male flight over despite targeted surveys. woodland of 200 secs) but also seen flying low over site from VP1 and 2.

Kestrel R Only recorded foraging on site. Single birds regularly recorded, mainly hunting over central (Falco tinnuculus ) parts of site.

Osprey x x A A single bird record at Lyn Hir adjacent to the None (Pandion haliaetus ) sites eastern boundary in 1995. Considered to be a bird passing through.

Hobby x A Two recordings made on site. None (Falco subbuteo )

Short-eared owl x R Records exist from the nearby Tirgwynt wind Single bird recorded hunting on the MWF plateau during the (Asio flammeus ) farm ES. None recorded during historical January 2014 winter transect survey. targeted surveys.

Barn Owl x A Two known nest locations in close proximity to None (Tyto alba ) the site.

Golden plover x R Occasional flocks recorded flying over the site. A flock of c300 recorded over centre and eastern parts of (Pluvialis apricaria ) site during Oct 2013. Seen to alight in grazed grass fields close to metmast in middle of site. A flock of 60 also recorded over centre of site during Nov 2013 survey and birds heard over site during foggy/low cloud conditions in Jan 2014.

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Snipe A Up to eight pairs of breeding snipe recorded Single birds flushed from wet grassland by surveyors or HH (Gallinago gallinago ) within or adjacent to the western extent of the during most visits. site.

Woodcock ( Scolopax A Recorded on site. Singles flushes during Dec 2013 and January 2014 winter rusticola ) transects near VP3 and new VP4.

Curlew R UK & Up to eleven breeding pairs within 800m of the None (Numenius arquata ) L site including two on site.

Lapwing R UK & Recorded twice off site during surveys. None (Vanellus vanellus ) L

Redshank A Recent records from within Montgomeryshire None (Tringa tetanus ) grid square SJ00.

Black Grouse ( Tetrao x R UK A single record from 1995. None recorded None tetrix ) during targeted surveys.

Nightjar ( Caprimulgus x R UK No records returned during the desk study or None europaeus) during targeted surveys.

Crossbill x G Historical and current winter records made in Small flocks (<20) seen in/over conifer woodlands at west (Loxia curvirostra ) association with the coniferous woodland on end of site during all VP surveys. Also occasional flights over site. eastern/central parts of site recorded (peak of 9 during Nov 2013 survey).

Starling R UK Recorded foraging and commuting over the Notable numbers (up to 15000) recorded commuting over (Sturnus vulgaris ) site. the eastern/central parts of site during dawn and dusk surveys. Appears to be a major roost a distance to the north- west of VP3.

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Greenland White- x R UK Historical records from 1998 at Llyn Hir None fronted Goose ( Anser adjacent to the sites eastern boundary. albifrons subsp. flavirostris )

Brent Goose ( Branta A A single flock of 45-50 birds recorded at Llyn None bernicla ) Hir.

Wigeon ( Anas A Recent records from within Montgomeryshire 13 on Llyn Newydd during Oct 2013 survey plus single on penelope ) grid square SJ00. Llyn Hir during Dec 2013 survey.

Teal A One breeding pair and overwintering flock of Peak of one bird recorded (Llyn Newydd Nov 2013). (Annas crecca ) 20 and 36 birds at Llyn Newydd.

Whooper Swan x x G Recent records from within Montgomeryshire A pair recorded at Llyn in November and December 2013 (Cygnus Cygnus ) grid square SJ00. during VP surveys.

Great black-backed gull R Recent records from within Montgomeryshire (Larus marinus ) grid square SJ00.

Lesser Black-backed A Recent records from within Montgomeryshire Peak of 89 arrived to roost on Llyn Hir during Oct 2013 Gull grid square SJ00. survey. Ones and twos also recorded flying past VPs 3 and 6 (Larus fuscus ) during Nov 2013 and Jan 2014 surveys.

Black-headed gull R A pair recorded breeding at Llyn Hir adjacent to (Chroicocephalus the sites eastern boundary. ridibundus )

I) Species is listed on Schedule 1 to the Wildlife and Countryside Act 1981 (as amended) ii) Species is listed on Annex 1 of the Council Directive 79/409/EEC on the conservation of wild birds

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iii) Welsh Birds of Conservation Concern. Population status of birds in Wales 2 (2009) RSPB (G - Green, A - Amber, R – Red) iv) Certain species of conservation concern are subject to their own Biodiveristy Action Plan within the UK or locally (L) within Powys. V) Wales Biodiversity Partnership (2012)Natural Environemnt & Rural Commities Act 2006: Section 42 list of species of principle importance for conservation of biological diversity in Wales. This conforms with the UK BAP list unless stated.

In addition, a small number of conservation concern passerine species have been recorded breeding on or within the site (e.g. skylark) however best practice guide states that such species are generally not impacted by turbines and will therefore be excluded from the EcIA except where significant habitat loss/disturbance impacts could potentially arise.

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