National Resources Wales COLD BLOW, WERNOG POWYS REVIEW

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National Resources Wales

COLD BLOW, WERNOG POWYS

REVIEW OF A SINGLE WIND TURBINE PLANNING APPLICATION

January 2014

National Resources Wales

COLD BLOW, WERNOG, POWYS

SINGLE WIND TURBINE PLANNING APPLICATION

Evaluation of Landscape and Visual Impact Assessment (LVIA)

January 2014

TACP

10 PARK GROVE

CARDIFF CF10 3BN

Project Number: 60669

Report Revision No: 1

Revision No. Date of Checked by Date Approved by Date Revision

0 16.12.13 FC 16.12.13 JW 16.12.13

1 28.01.14 FC 28.01.14 JW 29.01.14

Contents

1.0 Introduction ...... 1 1.1 The Brief 1 1.2 Proposed Development 1 1.3 Scope of this Evaluation 2

2.0 Evaluation Methodology ...... 3 2.1 Review of Documents 3 2.2 Site Visit 3 2.3 Best Practice Guidance 4

3.0 Evaluation of the Landscape and Visual Impact Assessment ...... 4 3.1 Introduction 4 3.2 Methodology (2. and Appendix 2) 5 3.2.1 Relevant Guidance ...... 5 3.2.2 Assessment Methodology (Appendix 2) ...... 5 3.3 Baseline Condition (3) 7 3.3.1 General ...... 7 3.3.2 Sources of Data (3.1) ...... 7 3.3.3 The Site and Study Area (3.2-3.12) ...... 7 3.3.4 Statutory and Non-statutory Landscape Designations (3.13 to 3.23) ...... 8 3.4 Description of the Proposals (4) 8 3.5 National Planning Policy (5) 9 3.5.1 General ...... 9 3.6 Effect on Landscape Character (6) 9 3.6.1 General ...... 9 3.6.2 Landscape Character Assessment (6.1 to 6.55) ...... 9 3.6.3 Conclusions on Landscape Character Assessment (6.55 to 6.61) ...... 11 3.6.4 Assessment of the Existing Landscape Character (6.62 to 6.79) ...... 11 3.6.5 Effect on Landscape Character (6.80 to 6.85) ...... 12 3.6.6 Summary (6.86 to 6.89) ...... 13 3.7 Effect on Visual Amenity (7) 13 3.7.1 Consultation (7.2) ...... 13 3.7.2 Zone of Theoretical Visibility (ZTV) (7.3 to 7.4)...... 13 3.7.3 Baseline Visual Receptors (7.6 to 7.37)...... 13 3.7.4 Viewpoints (7.38 to 7.127) ...... 14 3.8 Effect upon Landscape Features (8) 15

3.9 Cumulative Landscape & Visual Effects (9) 16 3.10 Conclusions (10) 17

4.0 Conclusions ...... 17 4.1 Methodology 17 4.2 Baseline Condition 17 4.3 Description of Proposals 18 4.4 Landscape Effects 18 4.5 Visual Effects 19 4.6 Cumulative Landscape & Visual Effects 19

1.0 Introduction

1.1 The Brief

National Resources Wales (NRW) has been formally consulted by the local planning authority, Powys County Council, on a planning application (Ref. P2013/1055) for a single wind turbine at Cold Blow, Clyro Powys.

NRW has a statutory duty for the conservation and enhancement of natural beauty in Wales, and is a statutory consultee and advisor to Government and local planning authorities on development likely to affect Wales’s natural environment. The organisation has a duty to comment on the implications of developments such as wind turbines both in terms of possible impacts on nature conservation interests and on the landscape, historic landscape, access and general amenity value of the countryside.

The Applicant has prepared a Landscape and Visual Impact Assessment (LVIA) which incorporates a Cumulative Landscape and Visual Impact Assessment (CLVIA) which included in the supporting documents submitted by the applicant and NRW need to assess and evaluate these documents in order to determine whether the assessment has been carried out in accordance with best practice guidance and whether the conclusions are reasonable and valid. This will assist them in determining the level of response required. The planning application is described as a non-Environmental Impact Assessment as the Welsh Government has deemed the project to be non-EIA.

TACP have been commissioned to carry out the evaluation on behalf of NRW and the review has been undertaken by Fiona Cloke BSc MPhil CMLI, Associate to TACP, together with Jo Wall, Partner of TACP. Both are Chartered Landscape Architects with considerable experience of working within Wales and of preparing and reviewing landscape and visual impact assessments.

1.2 Proposed Development

The wind turbine site is located in an area of rolling hills to the northwest of the Wye Valley and is approximately 60m to the north of the farm buildings at Wernog Farm and 650m east of Wern Fawr Farm, all near Clyro in Powys. the gird reference for the site is 319250, 246349. The site is in a field called Cold Blow, elevated at approximately 375m OD and near to the summit of Clyro Hill. The land cover is predominantly improved grassland with irregular shaped and medium sized fields enclosed by hedgerows and/or post and wire fences. The fields immediately around the turbine, and including Cold blow itself, are slightly larger than those in the surrounding area. There are many small areas of woodland, both irregular shaped blocks and linear woodland aligned to streams and valley sides. There are also linear and rectangular blocks of conifers in places.

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The proposal is to erect a single wind turbine with three blades and a maximum height from base to blade tip of 84 metres. The finish of the turbine would be in a low-reflectivity off- white colour.

The turbine would be located on a steel reinforced concrete hexagonal base 12.3m across and 2.5m deep, and adjacent to a hard standing/crane pad of approximately 35m x 20m. The access track, maximum 5m wide, would lead from an existing field gate taking a curved alignment up slope to the turbine location. The width of this track would be reduced to 2m when the turbines are in operation. A temporary construction compound, 40 x 40m, would be located part way up this track. A substation/control room would be situated close to the entrance gate and this would have a 10 x 5m footprint and a height of 4.5m. There would be underground cabling from the turbine to the control building and further cabling to connect to the local network. The route of this cabling has not yet been finalised.

The construction period is estimated to be about four months. The turbine would be operational for up to 25 years and before the end of this period a decision would be made as to whether to decommission the turbine or to replace/refit which would be the subject of a further planning application.

Cold Blow is located 3Km northwest of Clyro, 2.2Km east of Painscastle and 1.4 Km southwest of Rhosgoch. The town of Hay-on-Wye is located beyond Clyro on the opposite side of the Wye Valley approximately 5Km from the site.

The Brecon Beacons National Park (BBNP) is located to the south of Cold Blow and is approximately 4.6Km from the application site at its nearest point in Hay-on Wye. The special qualities of the National Park, as defined in the BBNP Management Plan, 2010-2015, include:

The Park’s sweeping grandeur and outstanding natural beauty observed across a variety of harmoniously connected landscapes, including marvellous gorges and waterfalls, classic karst geology with caves and sink holes, contrasting glacial landforms such as cliffs and broad valleys carved from old red sandstone and prominent hilltops with extensive views in all directions.

1.3 Scope of this Evaluation

This document includes an explanation of the methodology used in evaluating the Cold Blow LVIA in Section 2. The LVIA is then assessed in Section 3 with sub-sections relating to those provided in the LVIA itself. The numbers in italics relate to the numbered sections in the Cold Blow LVIA. Conclusions are itemised in the final Section 4.

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2.0 Evaluation Methodology

2.1 Review of Documents

Initial discussions with the client took place to clarify the precise scope of the evaluation. A series of documents which formed part of Planning Application P2013/1055 were accessed via Powys County Council's website including

 Planning and Environmental Report

 Landscape & Visual Impact Assessment

 Photomontage Viewpoints 1 to 6

 Photoviews 7 to 14

 Plans including:

Proposed Layout

Typical Turbine Foundation

Typical Access Track

Typical Control Building

Landowner Boundary

Landscape Designations

Zone of Theoretical Visibility

Cumulative Zone of Theoretical Visibility with Pentre Tump Wind Farm

These documents have been reviewed in order to establish an understanding of the proposed development. The following evaluation relates to the LVIA and accompanying plans and visualisations.

2.2 Site Visit

The site and the surrounding area were visited on 9 December 2013. A visual assessment of the local landscape characters and qualities was carried out. Areas of open access land, public rights of way close to the site as well as sections of the long distance recreation routes in the area were assessed for likely visual effects. Several of the viewpoints used in the LVIA were accessed in order to compare the visualisations provided to the existing view in the field. The visualisations were based on photographs taken in September 2013 and it was useful to check the views at a time of year when existing vegetation would be likely to provide less screening.

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2.3 Best Practice Guidance

The main documents utilised in carrying out the evaluation of best practice were:

 ‘Guidelines for Landscape & Visual Impact Assessment’ (GLVIA), 3rd Edition, Landscape Institute and Institute of Environmental Management & Assessment, 2013. GLVIA3 Statement of Clarification 1/13, Landscape Institute, 10.06.13 (postdates this LVIA but provides useful clarification on the use of ‘significance’)

 ‘Landscape Character Assessment: Guidance for England and Scotland’, Scottish Natural Heritage (SNH) and The Countryside Agency, 2002.

 ‘Photography and photomontage in landscape and visual impact assessment’ Advice Note 01/11, Landscape Institute, March 2011

 ‘LANDMAP Guidance Note 3: Using LANDMAP for Landscape & Visual Impact Assessment of Onshore Wind Turbines’, Natural Resources Wales, May 2013

 ‘Visual Representation of Wind Farms: Good Practice Guidance’ Scottish Natural Heritage, 2006

3.0 Evaluation of the Landscape and Visual Impact Assessment

3.1 Introduction

The LVIA for Cold Blow Wind Turbine has been prepared by the Pegasus Group and is numbered as follows: 1. Introduction 2. Methodology (detailed methodology provided in Appendix 2) 3. Baseline Condition 4. Description of the Proposals 5. National Planning Policy 6. Effect on Landscape Character 7. Effect on Visual Amenity 8. Effect upon Landscape Features 9. Cumulative Landscape & Visual Effects 10. Conclusions

These section headings cover the scope of an LVIA as required by the GLVIA, except for mitigation, and comments are provided on each before a more general evaluation is provided. The numbers in italics cross reference to those used in the LVIA.

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The section headings listed in the LVIA introduction differ from the above list which is taken from the Contents. This is slightly misleading but not important for the evaluation.

The extent of the study area was agreed with landscape officers in Powys County Council i.e. a 15Km radius.

Mitigation and residual effects are dealt with only in the introduction. The LVIA recognises that best practice requires that potential effects be assessed, mitigation proposals identified and residual effects then reassessed (1.7). As wind turbines are tall structures that require an open location it is not possible to screen them with vegetation.....no difference between assessed potential effects and residual effects. However there are also no mitigation proposals for the control building, access tracks and grid connections in terms of layout or landscape and the effect all of these could potentially be reduced with mitigation.

Construction and decommissioning stages are dealt with briefly in the introduction. It is considered that the construction works would be short term and there would be no additional effects on the views. There may well be additional effects on the landscape within the site including the construction compound, access track and grid connections and these should be acknowledged. Also that there would be no residual effects once the wind turbine has been decommissioned - subject to method statement being agreed with Powys CC. This statement is dependent upon both the agreed method and it being enforced in 25 years or more. It would be advisable to agree site restoration proposals at planning stage.

3.2 Methodology (2. and Appendix 2)

3.2.1 Relevant Guidance

A list of guidance documents is given including all those listed in 2.3 above except the LANDMAP Guidance Note 3. However this guidance note is referred to several times in the LVIA.

3.2.2 Assessment Methodology (Appendix 2) The assessment methodology is explained at some length with explanation of effects on:  landscape elements - these are restricted to the area within the site boundary as they are direct effects on the fabric of the site.  landscape receptors - 2 groups - landscape character and designated areas.

 views

There are definitions for levels of:

 magnitude of change for landscape elements - high, medium, low and negligible.

 sensitivity of landscape receptors - high, medium and low. The use of positive and negative landscape characters in this definition is questionable.

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 magnitude of change for landscape character receptors - high, medium, low and negligible.  sensitivity for visual receptors - high, medium and low.

 magnitude of change on visual receptors - high, medium, low and negligible.

The 3rd Edition of GLVIA encourages practitioners to move away from the use of the terms sensitivity to describe receptors, and magnitude of change to describe effects. Instead the nature of the receptors and effects should be assessed. The nature of the receptor should consider its value and susceptibility to change while the nature of the effect considers its size/scale, duration and reversibility. While the authors of this LVIA may not have used the currently advised terminology they do consider value and susceptibility to change for receptors and size/scale for effects. And finally a matrix for both landscape and visual effects which cross references the magnitude of change with the sensitivity of the receptor. The various levels given in this table do not appear to be defined in the methodology but are used throughout the LVIA. They are assumed to be levels of significance/importance:

Magnitude of Change

High Medium Low Negligible

Landscape High Major Major/Moderate Moderate/Minor Minor/Moderate and Visual Sensitivity Medium Major/Moderate Moderate Minor/Moderate Minor Low Major/Moderate Minor/Moderate Minor Negligible/None

Importance is used in the text to describe effects (including cumulative effects) on landscape elements, receptors and views - the following is that for landscape elements but the principle of effect being important if the wind turbine defines the element/character/view is used throughout:

An important effect will occur where the combination of the variables results in the wind turbine having a material effect on the receptor, so that its landscape character is defined by the presence of the wind turbine. An effect that is not important will occur where the effect of the wind turbine is not definitive, and the landscape character of the receptor continues to be defined principally by its baseline characteristics. In this instance the wind turbine may have an influence on the receptor and may alter the landscape character, but this influence will not be definitive. The link between the values of effects as shown in the above table and importance/significance is not entirely clear. There are headings in the LVIA entitled Significance of Visual Effect (e.g. 7.45) but these simply attribute categories from the above table to the effects.

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Throughout the LVIA report it is acknowledged that any scheme involving wind turbines will be visible to some degree. Although there will be some visual change at local level it would not necessarily be a harmful one, merely different to that which exists now (7.140). The GLVIA states that thought must be given to whether the likely significant landscape and visual effects are judged to be positive (beneficial) or negative (adverse) in their consequences for the landscape or for views and visual amenity. This LVIA does not assign positive or negative values to likely significant effects - but an explanation is provided in the assessment methodology. This states that there are no definitive criteria by which the effects of wind farms can be measured as being categorically positive or negative. Graphic techniques for the production of Zone of Theoretical Visibility (ZTV) diagrams and photomontage are detailed and follow best practice guidance.

3.3 Baseline Condition (3)

3.3.1 General

The baseline landscape and visual conditions should be reviewed as the initial step in an LVIA. This involves recording and analyzing the existing landscape features, characteristics, the way the landscape is experienced, and the value or importance of the landscape and visual resources.

While the use of existing landscape character assessments, LANDMAP aspect areas and landscape designations are of great assistance at screening and scoping stages, more comprehensive and detailed baseline studies are required once the preferred site has been selected.

3.3.2 Sources of Data (3.1)

The baseline study is described as being presented in five sections - in fact two of the five are to be found in this section - description of the site and study area (with a brief mention of landscape character), and landscape designations. Planning and legislative context is in 5., landscape character is in 6., visual receptors and views is in 7. Although confusing the required baseline information is in the LVIA and both landscape and visual baselines are described. LANDMAP data should be used in defining the baseline landscape - this is used in Section 6.

3.3.3 The Site and Study Area (3.2-3.12)

The Cold Blow LVIA is based upon a 15Km study area – a radius centred on the turbine site. This remains the same for cumulative effects. (Figures A.0246_01-C & A.0246 _12-A). Although the LANDMAP Guidance Note 3 (2013) recommends a 35Km radius for the initial search area this is for turbines of 100m height and refers to wind farms rather than individual turbines. The suggested study areas for individual aspect areas range from a 5Km to 15Km although the guidance states that areas around Snowdonia or near other hills or mountains greater extents may be required and recognises that significant landscape impacts can be experienced around 20km in places. SNH (2006) guidance states 25Km radius for ZTV for 71-

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85m turbines, guidance drawn up for wind farms although smaller developments likely to have smaller study areas. Given the size and location of the turbine it is considered that 15km study area is appropriate for the assessment.

The study area for Cold Blow is considered to be in line with current guidance and appropriate for the scale of the proposed development and the nature of the surrounding landscape. The study area is characterised as low density rural landscape with many hamlets and individual farmsteads. Larger towns are a feature in this part of Powys. This, together with the rest of the description in this section, is considered to be a reasonable introduction to the landscape character.

3.3.4 Statutory and Non-statutory Landscape Designations (3.13 to 3.23)

The Brecon Beacons National Park (BBNP) is acknowledged as the only statutory landscape designation in the study area. In paragraph 3.16 it is stated that the BBNP is approximately 5.5Km from the turbine site - in fact it is closer than this at approximately 4.6Km in Hay-on- Wye. There is no mention of the National Park's special qualities despite the fact that prominent hilltops with extensive views in all directions forms part of the description of the following quality: sweeping grandeur and outstanding natural beauty (BBNP Management Plan 2010-2015).

Ancient Monuments within 5Km of the site are listed, also Registered Parks and Gardens, Conservation Areas and Listed Buildings. The Middle Wye Valley Historic Landscape is mentioned but not the fact that it is on the CCW / Cadw / ICOMOS UK Register of Landscapes of Outstanding Historic Interest in Wales. None of the designated sites are mapped, except for the BBNP, which makes it difficult to assess their relationship to the site.

Landscape is not considered in its wider sense as there is no mention of the Areas of Nature Conservation Interest designated in Powys County Council's Unitary Development Plan (UDP) or of the protected nature conservation sites close to the site - including Rhosgoch Common which is a National Nature Reserve (NNR), a Site of Special Scientific Interest (SSSI) and a Special Area of Conservation (SAC).

National Trails (Offa's Dyke Footpath) or routes which are part of the National Cycle Network of which there are three within the study area are also not considered. However the Offa's Dyke Footpath is referred to in Effects on Visual Amenity (7).

3.4 Description of the Proposals (4) The description of the proposed development is lacking in detail - simply a generic list of wind turbine elements and their attributes with no references to the drawings of proposed layout or typical details. Chapter 2 in the Planning and Environmental Report provides most of

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the detail needed but this should be in the LVIA as well. Figure A.0246_10-A (separate to LVIA and not referenced in it) is of the proposed layout but this is also lacking in detail e.g. no contours, spot heights or existing vegetation shown. The Landowner Boundary and Proposed Layout plans show the turbine location in slightly different locations. While it is accepted that there is a request for a 50m micro-siting allowance (2.2 in the Planning and Environmental Report), on a sloping site 50 to 60m can be significant for visualisations as the turbine's base may be lower or higher than portrayed. Construction, operation and decommissioning phases of the development are not included.

3.5 National Planning Policy (5)

3.5.1 General

This section includes reference to local as well as national planning policy. Relevant policies from Planning Policy Wales, TAN8: Renewable Energy and TAN12: Design are listed as well as principal strategic and generic policies in Powys County Council's Unitary Development Plan (adopted March 2010). E3: Wind Power is set out in full. E4: Removal of Redundant Wind Turbines is not set out in full but would have been useful with regards to the decommissioning stage. More detail on a number of the environmental policies including ENV2: Safeguarding the Landscape and ENV3: Safeguarding Biodiversity & Natural Habitats would have provided a more balanced picture.

No information from the Herefordshire UDP is provided although it is stated that relevant policies from this plan were reviewed as part of this assessment (5.19).

3.6 Effect on Landscape Character (6)

3.6.1 General

This section examines the potential effects on landscape character and utilises LANDMAP data in so doing. The report author then assesses the effects upon existing local landscape character within 2Km of the site and between 3 and 5 Km of the site area. There are separate conclusions relating to each of these assessments (6.55 to 6.61) and (6.60 to 6.85) followed by a summary of the overall effects (6.86 to 6.89).

3.6.2 Landscape Character Assessment (6.1 to 6.55)

All five layers of LANDMAP data were included in the assessment but only those judged to potentially experience some effect are described. It should be noted that LANDMAP does not in itself provide a landscape character assessment. Instead it provides information about five different aspects of the landscape - these may then be used in establishing landscape character areas if required.

There are some misleading references to LANDMAP Guidance Note 3:

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 that it is aimed at large scale industrial size developments and the level of detail is perhaps not appropriate for the proposed development. This is not the case.

 that it identifies that information contained in the description of aspect areas is the only source to judge sensitivity. This is disagreed with.

Key stages which should be informed by LANDMAP include:

 gathering baseline information relevant to the potential effects of the proposal on the landscape and visual resource

 predicting and describing the potential effects of the proposal and defining ways of mitigating adverse effects, when this is possible

 LANDMAP information can be used further to inform the assessment of significance of impacts  as well as helping to explain the final proposed site layout over any possible alternatives considered in the process.

LANDMAP report sheets for aspect areas of above low evaluation which fall within the 15Km study area are included in Appendix 4 - for four of the aspect layers but not for Landscape Habitats.

Habitats: the consultant was unable to access the report sheets for LANDMAP landscape habitat aspect areas at the time of writing the LVIA. Apart from the classification of improved grassland there is no further information about the nature conservation interest in the area despite there being a number of valuable sites within the immediate study area including Rhosgoch Common. While it is accepted that the proposed development may have no direct effects on these areas, they are important in understanding the nature of and value attached to parts of the local landscape.

In addition to the report sheets a description of the aspect areas is included in the text. It is not always clear into which aspect area the proposed development falls, or how its qualities relate to the site. A Zone of Theoretic Visibility plan overlain on separate plans for each of the 5 aspect areas with relevant evaluation levels would have assisted an understanding of the area and would be in accordance with LANDMAP Guidance Note 3. There are no drawings to illustrate the landscape character of the wider setting.

The Visual and Sensory aspect area into which the site has been located is inaccurate. It is described as Rolling Hills, South East but in checking the LANDMAP website it is considered that the site falls wholly within Improved Upland, Eastern Outliers. This aspect area describes the site's immediate landscape setting well and has an overall evaluation of low - due to the intrinsically higher landscape value having been degraded by insensitive intensive farming ..... resulting in disturbed messy rather barren landscape. The aspect area is not included in the LVIA except to be used in 6.60 as a context for the northern edge of the site - its low evaluation is set next to the moderate value for Rolling Hills, South East.

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If the correct Visual and sensory aspect area had been used it would in fact have altered the LANDMAP evaluation from moderate to low for this aspect of the site area.

The Middle Wye Valley Historic Landscape is not highlighted except as a Cultural Landscape aspect area and there is no assessment of the effects on its character despite the fact that the ZTV indicates that the turbine may be seen from the majority of the aspect area.

3.6.3 Conclusions on Landscape Character Assessment (6.55 to 6.61)

LANDMAP information is used in the LVIA to assist in understanding the value of the existing landscape but it is very general - using the overall evaluation for each aspect area as a gauge of its sensitivity and does not follow the LANDMAP Guidance Note 3. This may be too crude as the sensitivity of the receptor should also take account of the susceptibility to change of a particular type. No attempt appears to have been made to assess which qualities of the aspect areas would be sensitive to the particular changes proposed. In addition, the assessment of local landscape character, as outlined below does not refer to LANDMAP and this assessment is used to define the predicted impacts.

It is stated in 6.58 that the outstanding Cultural and Historic aspect areas have been used to reflect the choice of viewpoints. The Visual and Sensory aspect areas have also been used as a guide, with more long viewpoints from the south and east of the site due to the National Park designation. This reflects the locations of the statutory landscape designations and the importance of the Middle Wye Valley Historic Landscape although this latter is not specifically referenced in this section. There are also important areas of open access land to the north and west of the site – refer to Section 4.

3.6.4 Assessment of the Existing Landscape Character (6.62 to 6.79) The assessment of the landscape character uses the following criteria - individually to 2Km distance and as a group for 3 to 5Km:

 landscape scale  landform and enclosure

 landscape pattern and complexity  settlement pattern and human influence

 skylines  inter-visibility

 tranquillity Under each heading there is a statement on the effect of the proposed development upon the particular criteria. It is not clear how the proposed methodology has been utilised to come to the conclusions on these effects:

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The landscape scale is judged to be small to medium but with a larger scale landscape created by the hilltops and hillsides. The wind turbine is judged to be of medium scale which would suit the landscape scale in which it would be situated. This statement lacks evidence and is not considered to be accurate. The turbine is 84m high. The height difference between the Wye Valley (near to Hay-on-Wye) and the site is approximately 300m while between Painscastle and the site it is approximate 120m. The height of the turbine may be medium in relation to some other turbines but is considered large in relation to the scale of this landscape. In landform and enclosure there are descriptions of each ranging from strong sense of enclosure in river valleys to openness in exposed locations. Which of these is relevant for the proposed wind turbine is not made clear except to describe it as having little effect upon the existing moderate sense of enclosure. Again this is contested as the site is open and exposed as described in the LANDMAP Visual & Sensory aspect area. The landscape pattern and complexity is described as fairly complex and varied and the proposed wind turbine would therefore suit the chosen location. Again this is difficult to accept as evidence both from the site visit and the LANDMAP Visual & Sensory aspect area is of a simple level of diversity and an open landscape pattern. This is not to say that the proposed wind turbine would not fit a less complex landscape but without more evidence of the proposed methodology being utilised the conclusions in the LVIA are questioned. Settlement pattern and human influence: it is stated that the proposed development would not materially change the profile of human influence or settlement pattern associated with this landscape and that this already includes overhead lines including a large scale high voltage transmission line. The transmission line was not obvious during the evaluation site visit or when checking photographs taken during the visit. There are occasional overhead lines often aligned to roads and estimated to be 8 to 10m high. The scale of the existing built infrastructure is not comparable with the wind turbine at 84m and it is considered that the turbine would change the profile of human influence in the area as there are no other comparable structures clearly visible from the site. No assessment of the effect of the turbine on the skylines is provided. Inter-visibility is not defined but is assumed to mean the effect on the extent of views between elements. This is assessed as limited in effect. The area is judged to be relatively tranquil with the turbine having a negligible effect upon this as the landscape is already settled although peaceful. In landscape terms this is a reasonable judgement.

3.6.5 Effect on Landscape Character (6.80 to 6.85) The introduction of the wind turbine is judged not to detract from the existing strong character with no significant change to physical characteristics of the landscape. This is partly justified on the basis of there being several existing vertical infrastructure elements present in the landscape including transmitter masts. The masts noted during the evaluation site visit are near Clyro (3.3Km away) and at Mintfield Farm (11.5Km away). Both are set at approximately 220 to 230m OD so are lower in the landscape than the proposed turbine at 375m OD. Neither could be seen form the proposed turbine site and both are judged to be considerably lower than 84m in height. It is also stated in the LVIA that the proposed turbine

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is set well below the relatively high points of Clyro Hill to the north. This high point is 383m OD as compared to 375m at the base of the turbine. An 8m drop from high point to the turbine base is not considered to be constitute 'well below' when the overall height of the turbine is 84m. There is no description/evaluation of the effects on the character of the wider landscape. The landscape effects in the National Park and the Middle Wye Valley Historic Landscape are not defined.

3.6.6 Summary (6.86 to 6.89)

The summary appears to work through a process of downgrading the levels of sensitivity, magnitude of change and effects until it arrives at a minor overall effect upon landscape character for this proposal. It is not clear over what area the landscape character is being considered when reaching this conclusion. When a medium susceptibility to change is paired with a high value landscape the overall sensitivity to change is considered to be medium - again it is not clear as to why medium is selected rather than high. Paragraph 6.88 explains why the landscape character would undergo a low magnitude of change. Paragraph 6.89 then justifies changing the overall effect, based on pairing the medium landscape sensitivity with the low magnitude of change, from minor/moderate, as per the table provided in the proposed methodology, to minor.

It is suggested that the above neither follows best practice guidance nor is reasonable and accurate.

3.7 Effect on Visual Amenity (7)

3.7.1 Consultation (7.2) The viewpoints selected were agreed with Powys County Council and are not intended to cover every single possible view, but are intended to be representative of a range of receptor types. See comments at 3.7.4.

3.7.2 Zone of Theoretical Visibility (ZTV) (7.3 to 7.4) The production of the ZTV appears to follow best practice - generated using ArcGIS 10.1 and Landform Panorama 50m digital Terrain Modelling data.

3.7.3 Baseline Visual Receptors (7.6 to 7.37) It is stated in 7.8 that the most notable views are anticipated to be within 3Km. Beyond this the proposed turbine will become a smaller element in a wider view. The photoviews could be construed as being misleading in this respect as all are taken with an angle of view of 90 degrees which is approximately double that seen with the naked eye, although the angle of view does not contravene current best practice guidance. It would have been helpful to have grid references for the properties and other areas listed as receptors - or have them located on a plan. The following are included:

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 residential properties - three properties are listed as within 2km of the site and to its north but with views masked by intervening landform. This is not the case for Cefn-y- blaen where the farmhouse has views towards the site. This may have been less evident in October when vegetation may have also masked views. There are also views from a number of farms and rural properties on the southeast facing slopes to the north of Rhosgoch - several within 3Km of the site.

 public highways

 public rights of way - it is not accepted that there are very few rights of way within 3Km of the site - particularly in areas to the north and southwest of the site. The Begwns are to the southwest and have clear views of the site - not partial views as described. Nor is it accepted that that the turbine will be a notable but not defining element in views from paths within 3Km of the site. It is likely to be the only turbine or vertical element in an area of at least 5Km radius, with a height of 84m and being close to a hilltop. In addition to the National Trails mentioned there are several National Cycle Network routes in the study area. The closest is Route 12 which passes through Hay-on-Wye and Glasbury, Route 825 which forms part of the Radnor Ring passes within approximately 7Km to the north and Route8 is 10Km to the west.

 open access and common land  landscape designations

 other designations - it is considered that nature conservation sites should be considered in this category, particularly Rhosgoch Common, which are of European significance. They are highly valued landscapes which will be visited by the public.

3.7.4 Viewpoints (7.38 to 7.127)

The following were included for each viewpoint:

 nature of baseline view and sensitivity of visual receptor  nature and magnitude of visual effect

 significance of visual effect The production of the photomontages (1 to 7) appears to follow best practice. Photographs have been taken at 20 degree intervals between frames, with a digital SLR camera with a fixed 50mm lens, and then digitally joined using Adobe Photoshop software. The series of connected images is then projected in a number of facets that approximate to a cylindrical projection. For correct perspective viewing the images need to be curved through 90 degrees and viewed at a distance of 400mm. The view appears distorted when flat although the photomontage should ideally include a note to say that they can be viewed flat by looking straight at the image while moving your head across the page at a constant viewing distance of 400mm.

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The photoviews (8 to 14) also appear to have been constructed from more than one frame and have an angle of view of 90 degrees. This should be made clear on the image page as they could otherwise be misleading as the view is wider than would be taken in by the naked eye. These views also lack information regarding camera focal length and viewing distance. While it is acknowledged that the viewpoints used were agreed with Powys County Council it is considered that there are two further locations from which valuable information could have been gathered to assist with the LVIA: 1. The Begwns: an area of open access land some of which is owned by the National Trust and which offers spectacular panoramic views of the surrounding countryside. It is possible to see almost the entire Brecon Beacons National Park from the Roundabout. At its eastern end the area is within 2.1Km of the proposed site and there are clear views from the area to the site. 2. Rhosgoch: this hamlet is the closest settlement to the proposed site and again there are clear views of the field in which the turbine would be located. There is also a caravan park at Weasel Bridge to the north of Rhosgoch and only 2Km from the site. There seems to be an under-representation of viewpoints from the north and including Rhosgoch would help to even the balance.

Specific viewpoints In Viewpoint 1 the turbine is visible in the wire frame but not on the photomontage - or at least not at the resolution provided via the Planning Portal. The images are supposed to be viewed at 750mm wide but the Planning Portal resolution is not clear enough to do this. Therefore the following comments may be revised if clearer images were provided. Viewpoint 2: the magnitude of change is considered to be low rather than negligible. Photoview 10: the effect has been downgraded from moderate/minor to minor. It is a skyline view form 5.2Km away and should perhaps stay as moderate/minor.

In Photoview 14 the position of the Begwns appears to be wrongly labelled - the Begwns are just to the right of the turbine. The clump of conifers between the viewer and the turbine site is perhaps overly convenient.

3.8 Effect upon Landscape Features (8) This is a short section describing the direct effects upon:

 topography  trees and hedges

 herbaceous vegetation  water features (none) It is assumed that the term features equates to elements as used in the GLVIA i.e. the individual parts that make up the landscape. Features are particularly prominent or eye-

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catching elements in the landscape, such as tree clumps, church towers or wooded skylines OR a particular aspect of the project proposal (GLVIA glossary, p156). The section concludes that the wind turbine would have a negligible effect upon topography, trees and hedges, and herbaceous vegetation due to medium or low sensitivities and negligible magnitudes of change. These conclusions are considered to be reasonably accurate for the immediate site area, taking no account of its wider setting. The negligible magnitude of change for topography could be questioned but without more detail on the proposed development this is difficult to do. It might have been helpful to include this section earlier in the report, following the Description of Proposals (4), so that the direct effects more clearly helped to inform the indirect effects upon the landscape character.

3.9 Cumulative Landscape & Visual Effects (9)

The other wind turbine and wind farm developments considered in the CLVIA date from a search made in May 2013 and the cumulative assessment is based only on a subset of those built, consented and validated applications at that time. Filters have been applied to rule out other turbine developments below certain heights - 25m in the 5 to 10Km zone and 40m beyond 10Km. All turbines are considered within 5Km of the site.

The cumulative ZTV shows limited areas from which both Cold Blow and the only other turbine development considered, at Pentre Tump, may both be viewed. It is stated at 9.4 and 9.5 that there is no inter-visibility between Cold Blow and Pentre Tump. The areas from which they can both be seen include the northwest edges of the Black Mountains, small areas on the eastern edge of Mynydd Eppynt and small areas of high ground northeast and north, some around Kington.

Only the viewpoints assessed in the LVIA have been reassessed for cumulative visual effects and because Viewpoint 5, the only one falling within the cumulative ZTV, is well to the south of Cold Blow, and therefore Pentre Tump, the effects are considered to be very limited.

However there are other areas on the cumulative ZTV from which both developments may be seen and which are closer to the two sites. These also should be considered before being discounted.

The sensitivity of visual receptors is rated as high due to being elevated and remote locations and often settings for PROW and National Trails. Magnitude of change is rated as negligible due to the long distances to viewpoints - this will result in a minor/moderate visual effect.

The sensitivity of the landscape across the whole study area is classed as medium due to there being few landscape designations. This is a crude measure for such a wide area. The magnitude of change is rated as low which is understandable at the distances from site being considered. The cumulative effect upon landscape character is minor/moderate but this is downgraded to minor due to the character still being defined by the existing landscape. The need for this downgrading is not clear.

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The CLVIA does not appear to be very thorough or detailed particularly in relation to reassessing the visual effects and to categorising the sensitivity of the landscape. No reference to LANDMAP is made and this could have assisted with the sensitivity and possibly with visual effects. Having said this the same conclusions may have been reached but their justification would have been clearer.

3.10 Conclusions (10)

The LVIA concludes that the proposed wind turbine would not detract from the existing landscape character and there would be no significant change to the physical characteristics of the landscapes identified within the LANDMAP landscape character assessment.

This conclusion is not considered to be reasonable or accurate, based upon the assessments carried out and detailed in the LVIA.

In 10.8: publicly accessible locations from where views are afforded are difficult to find. There are a considerable number of open access areas, generally on high ground around the site as well as PROW and Offa's Dyke Footpath. The proposed site is visible from a considerable number of these routes/areas.

The overall conclusion is that the proposed turbine could be successfully accommodated and assimilated into the wider landscape without causing unacceptable harm to landscape character, visual amenity or the landscape features of the area.

There are a number of issues within the LVIA, relating to the application of the methodology and to the assessment of effects, which give cause for doubting this overall conclusion.

4.0 Conclusions

4.1 Methodology A comprehensive set of best practice guidance is listed in the LVIA and the proposed methodology relates clearly to the guidance. This includes considerable detail on levels of sensitivity of receptors and magnitude of change and how these levels lead to categorising landscape or visual effects. However, in the Cold Blow LVIA, the proposed methodology is not always followed through and it can be difficult to relate conclusions made to the method employed. In many instances e.g. 6.89, an effect is arrived at from combining sensitivity and magnitude of change levels, and then a justification is given for reducing the overall effect. This measure is always used to reduce the scope of the effect and is clearly subjective.

4.2 Baseline Condition The study area with a radius of 15Km is considered appropriate for the assessment.

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Descriptions of the baseline are found in several sections of the LVIA but landscape features, landscape character and visual receptors are all covered. As this evaluation has been carried out for NRW the fact that no baseline conditions are provided for the parts of the study area set within England has not been emphasised. However it is a considerable gap in the data provided.

All LANDMAP aspects except landscape habitats are referred to in the LVIA. Existing landscape designations are also referred to but not those relating to nature conservation sites.

The Visual & Sensory aspect area in which the proposed site is located has been wrongly defined. It should be Improved Upland, Eastern Outliers but the neighbouring Rolling Hills, South East has been used. This would change the overall evaluation of the aspect area from moderate to low which, using the method employed in the LVIA would reduce the sensitivity level for the landscape immediately around the site.

LANDMAP data is used to assist in understanding the value of the existing landscape, although only the overall evaluation for each aspect area rather than specific criteria. This does not conform to LANDMAP Guidance Note 3. However the assessment of local landscape character (6.62 to 6.79) does not relate to LANDMAP and it is this assessment which has been used in defining effects.

Throughout the LVIA, but in particular in relation to the baseline conditions, there is a lack of illustrative material. The Landscape Designations drawing shows only the BBNP boundary despite other designations being referred to in the text. LANDMAP record sheets for individual aspect areas are provided in and Appendix but it is not always clear which areas play host to the proposed site and they are not overlain by the ZTV plans. There are no drawings to illustrate the landscape features or the landscape character of the wider setting.

4.3 Description of Proposals

The description of the proposals lacks detail and makes it more difficult to evaluate the accuracy of the LVIA. The Proposed Layout drawing gives no information on topography, existing vegetation or mitigation measures. The Site Location drawing shows the turbine in a different location to the proposed layout which may be significant in terms of turbine height and visibility.

No mitigation measures are given - or consideration of alternative sites. This is explained adequately in the introduction for the turbine itself but the impact of ancillary items such as the control housing could be mitigated.

4.4 Landscape Effects There are three levels of assessment of landscape effects in the LVIA: 1. Across the whole study area (15Km radius) LANDMAP information is used in the LVIA to inform the assessment of significance of effects but this is in a very general way - using the overall evaluation for each aspect area as a gauge of its sensitivity.

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2. The assessment of various characteristics of the local landscape covers a 5Km radius. 3. An assessment of the direct effects of the proposed development on the site itself.

It would have been beneficial to link each of these assessments so that a clearer picture of the overall effects is obtained. The assessment of LANDMAP aspect areas has been utilised in defining viewpoints but does not appear to have informed the assessment. Illustrative material would have helped understanding of the relationship between LANDMAP and the more immediate setting. The assessment of effects on landscape scale, landform and enclosure, and landscape pattern and complexity are questioned in terms of conclusions drawn. The introduction of the wind turbine is judged not to detract from the existing strong character with no significant change to physical characteristics of the landscape. This is partly justified on the basis of there being several existing vertical infrastructure elements present in the landscape including transmitter masts. This is contested in terms of scale and the lower elevation and height of two existing masts in the 15Km study area. Landscape effects on the wider landscape including the BBNP and the Middle Wye Valley Historic Landscape are not defined.

4.5 Visual Effects

The production of the ZTV and photomontage appear to follow best practice. The photomontage need to be viewed when curved through 90 degrees and at a viewing distance of 400mm. The photoviews are also panoramic with a horizontal angle of view of 90 degrees but this is not stated on the images and they could be misleading in that the turbine is part of a wider view than would be obtained with the naked eye. There are two further locations from which valuable information could have been gathered to assist with the LVIA: 1. The Begwns: an area of open access land some of which is owned by the National Trust and which offers spectacular panoramic views of the surrounding countryside.

2. Rhosgoch: this hamlet is the closest settlement to the proposed site and there are clear views of the field in which the turbine would be located.

There is not a specific assessment of impact on the Brecon Beacons National Park or clear review of the impact of the Special Qualities of the National Park.

4.6 Cumulative Landscape & Visual Effects The CLVIA is already dated by the fact that only planning applications prior to May 2013 are considered as this was the date when searches were made for the assessment. This is not a criticism but a statement of fact. One other planned development is included in the CLVIA and

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this is at Pentre Tump. Other applications for smaller turbines were not included when over certain distances from the proposed site. Areas from which both developments may be seen are shown on a cumulative ZTV and many are over 10Km from either site but others are closer and no attempt appears to have been made to assess any views from these areas.

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