County Hall , CF104UW Tel: (029) 2087 2087 www.cardiff.gov.uk Our Ref: SC 18/00001 /MJR .Neuadd y Sir Your Ref: Caerdydd, ~~ CF10 4UW CARDIFF Ff6n: (029) 2087 2088 Date I Dyddiad: 16/05/2018 CAERDYDD www.caerdydd.gov.uk

Ms F Parmenter David Lock Associates 50 North Thirteenth Street Central Milton Keynes 1 8 MJ\Y ~~018 MK9 3BP

Dear Ms Parmenter

Application No: SC 18/00001/MJR Proposal: SCOPING OPINION Location: NORTH EAST CARDIFF (WEST OF )

The above proposal has been scoped with regard to the need for the preparation of an Environmental Statement to accompany the application, in accordance with the Town and Country Planning (Environmental Impact Assessment) () Regulations 2017 (the EIA Regulations).

1. Introduction

1. 1 This request for a scoping opinion relates to proposals for the development on part of land at North East Cardiff (Strategic Site F in the Local Development Plan) of up to 2,500 dwellings together with mixed use district and local centres/areas comprising retail and services, commercial and employment uses; community and leisure uses; land for a secondary school; a primary school; green infrastructure including formal (including playing fields) and informal open space, landscape, biodiversity and amenity space; play space (including Neaps/Leaps/MUGA); changing and sports facilities; sustainable drainage systems; highway, cycle and pedestrian routes; car parking; infrastructure (including utilities); engineering works including ground remodelling; demolition, site reclamation and removal of structures; the formation of new accesses.

1.2 This scoping opinion has been prepared by in response to the information contained within the Scoping Report prepared by David Lock Associates and submitted to the Council in January 2018. The opinion comprises a brief description of the site and the proposals, a summary of the consultation responses, and the scoping opinion.

The Local Planning Authority has taken the following into account before adopting its opinion in accordance with Regulation 14(6) of the EIA Regulations:

(i) any information provided by the applicant about the proposed development; (ii) the specific characteristics of the particular development; (iii) the specific characteristics of development of the type concerned; and (iv) the environmental features likely to be significantly affected by the development

· 2. Description of The Proposed Development and Site Context

The Proposed Development

2.1 The development proposal is described as follows:

The development on part of land at North East Cardiff (Strategic Site Fin the Local Development Plan) of up .to 2, 500 dwellings together with mixed use district and local centres/areas comprising retail and services, commercial and employment uses; community and leisure uses; land for a secondary school; a primary school; green infrastructure including formal (including playing fields) and informal open space, landscape, biodiversity and amenity space; play space (including Neaps/Leaps!MUGA); changing and sports facilities; sustainable drainage systems; highway, cycle and pedestrian routes; car parking; infrastructure (including utilities); engineering works including ground remodelling; demolition, site reclamation and removal of structures; the formation of new accesses.

2.2 The site extends to approximately 135 hectares which accounts for approximately 57% of the LOP Strategic Site F (North East Cardiff, West of Pontprennau). The site is split into two parceis which sit either side of the approved 'Churchlands' development (ref: 14/02891/MJR). Two other parcels of land to the northwest and southeast lie within the Strategic Site allocation yet are outside the control of the applicant.

Site Context

2.3 The site is located between to the west and Pontprennau/Cardiff Gate Business Park to the east. The M4 forms the northern boundary and the southern boundary is defined by and Lisvane Reservoirs and Ty Draw Road. 2.4 The site is currently in agricultural use and comprises greenfield land characterised by a network of fields, woodlands, streams and sporadic residential buildings. The land is undulating with a mixture of sloping mounds and valleys.

2.5 The reservoirs to the southwest are designated as Sites of Special Scientific Interest and the dam structure of Llanishen Reservoir is also Grade II Listed. There is one Grade II Listed Building within the site at Panteg, south of St. Mellons Road.

2.6 There are 6 no. Sites of Importance for Nature Conservation within the site at: Malthouse Wood, Nant-y-Draenog, Nant Glandulais, Ty Llwyd Meadows, Lisvane Reservoir Wood, and Coetgae-sych.

2. 7 Various Tree Preservation Orders are located within or adjacent to the site. Of particular importance are Malthouse Wood to the north east near Cardiff Gate Business Park and, Coetgae-sych and Coed-ty-Llwyd between Lisvane Road and the reservoirs.

3. Consultation Responses

Socio-Economic Impacts

3.1 The proposed scope is considered to be acceptable. It is noted that effects of the development on health are referenced. Risks to human health must be considered in EIA development as required by the EIA Regulations (Schedule 4 Part 5(d)).

Transport

3.2 I attach a copy of the Local Highways Authority's response to the scoping consultation exercise. They advise that the Transport Assessment (TA) will need to be comprehensive and the study area will need to adequately cover the traffic impacts of the development. Discussions are ongoing between the Highway Authority and the Transport Consultants concerning the precise scope of the Transport Assessment. An updated submission is anticipated in the near future which the Local Planning Authority will issue a separate opinion on following consultation.

3.3 The Highways Directorate has been consulted. No response has been received.

' Air Quality

3'.4 The Air Quality Officer has reviewed the EIA scoping opinion document which documents the outlined approach for compiling the supporting EIA documentation for the mixed use development (North East Cardiff, West of Pontprennau). Chapter 6 of the submitted documentation refers to the air quality assessment that will be undertaken as part of the EIA.

3.5 He is satisfied for the best part of the outlined approach. As detailed within sub section 6.9 (Scope and Assessment Methodology); an initial consultation with Cardiff Council's EHO department will be undertaken to agree a scope of works. It is a requirement that the described initial consultation is carried out to agree a scope of works prior to any assessment being completed. This initial consultation will also provide an opportunity for Cardiff Council to share with the consultants more recent datasets than the ones detailed in Table 6.1 of the submitted documentation.

Noise and Vibration

3.6 The Council's Noise Pollution Officer is satisfied with the proposals outlined in the Environmental Impact Assessment, Scoping Report, Chapter 7 - Noise and Vibration. The full noise and vibration assessment should be completed and submitted with the application.

Landscape and Visual Impact

3.7 It is noted that the assessment of landscape and visual impacts of the proposed development will use methodology having regard to the 'Guidelines for Landscape and Visual Assessment, Third Edition (2013): The Landscape Institute and Institute of Environmental Management and Assessment.' This approach is accepted.

3.8 The stages of assessment to include landscape value, character and susceptibility to change, and sensitivity leading to an assessment of the magnitude and significance of the effects are also accepted as a suitable approach.

3.9 In respect of the viewpoints it would be beneficial to include additional locations at the Wenallt, Lisvane and Junction 30 of the M4 as advised previously. Both winter and summer assessments should be carried out mindful of the extent of green infrastructure across the site. Ecology and Biodiversity

3.10 Natural Resources Wales (NRW.) and the Council Ecologist have been consulted for their views on the proposed scope of ecology and biodiversity assessments. In addition to the Scoping report and appended summary note of badger, dormouse and bat surveys, extended phase 1 habitat surveys and badger and wintering bird survey report, consultations were also carried out on additional new survey data received on 19 March 2018.

3.11 A meeting took place on 28 March 2018 attended by the applicant's team, Natural Resources Wales, and officers of Cardiff Council. It was agreed at this meeting that:

(i) the Extended Phase 1 Habitat survey for the whole site will be updated to establish any changes to habitat since the previous survey (dated 2014); (ii) updated bat activity surveys will be carried out to supplement the surveys undertaken in 2014 and 2016; , (iii) targeted emergence surveys for trees and buildings.

3.12 Following this meeting, updated comments from Natural Resources Wales have been received dated 25 April 2018. A copy of these comments are attached which confirm that they are now satisfied with the proposed scope of survey work to inform the ecological and biodiversity assessment.

3.13 Following receipt of NRW's updated comments the Council's Ecologist provided updated comments which are also attached to this opinion. He also supports the proposed scope of the assessment, concurring with NRW's views regarding additional surveys. He also acknowledges that the application will be subject to a Habitats Regulations Appraisal prior to its determination.

Historic Environment

3.14 CADW notes that the Cultural Heritage Section of the submitted scoping report identifies that the proposed development could have an impact upon the settings of Cefn Mably (GM11), Pare Cefn Onn (G20) and the Castle Field Camp east of Craig-Llwyn (GM066) and identifies appropriate methodologies to assess these impacts. They acknowledge that suitable methodologies are also proposed to assess other heritage assets. A copy of their response is attached. 3.15 Gwent Archaeological Trust (GGAT) notes from the supporting information particularly the EIA Scoping Report, that Section 10 considers the Historic Environment. The section concludes that an archaeological assessment will be necessary, and they look forward to this being submitted in order for them, as the archaeological advisors, to be in a position to make an informed recommendation.

3.16 It is noted that Pant-teg Cottage (Grade II Listed) has been identified as the only listed building within or surrounded by the development area and an assessment of the effects of the development upon its setting will be carried out. as part of the EIA.

3.17 The proposed scope of heritage assets to be assessed is considered to be acceptable.

Agriculture and Soil Resources

3.18 The Welsh Government, Department for Rural Affairs response relates only to the application of 'Best and Most Versatile' Land Classification policy and Agricultural Land Classification System Technical Advice (PPW 4.10.1 and TAN 6 81, 85 & 86). They note that the submitted scoping report acknowledges that permission has already been given for three sites: Churchlands (14/02891/MJR), St. Edeyrn's (13/00578/DCO) and land adjacent to Lisvane Road (15/00036/MJR).

3.19 They note that Section 11 of the Scoping Report summarises the methodology and baseline assessment which is as they expected.

3.20 The Council's Tree Officer advises that a Soil Resource Survey and Plan prepared in accordance with the 2009 DEFRA Construction Code of Practice for the Sustainable Use of Soils on Construction Sites is an appropriate method to characterise, quantify and specify the soil resource to ensure it does not suffer irreparable damage and is utilised to support landscaping functions (trees, grassland, shrubs) that can return to the soil what has been lost through its disturbance as part of construction.

Water Resources

3.21 Dwr Cymru Welsh Water does not have any comments to make in respect of the scoping opinion for the residential development. However, they welcome early engagement with the applicant to discuss the holistic drainage strategy for this site.

3.22 Natural Resources Wales (NRW) has provided the following comments on drainage matters: (i) The ES should take account the potential for imminent changes to the SUDs position by Welsh Government, whereby the need and use of SUDs in development is emphasised. There is the potential for this development to become an exemplar site for the use of SUDs in construction;

(ii) For future developments across Cardiff, the management of water should be considered across the sites. Wide green corridors act as wildlife corridors, but also can be important in filtering water minimising diffuse runoff. It can also attenuate or slow overland flows, intercepting waters before entering streams and rivers, slowing flows and delaying or stretching out peak flow flooding events. This provides ecosystem resilience, multiple benefits and minimises downstream impacts. It also will enhance the well-being and attractiveness of developments. These wide green corridors should be present throughout developments in addition to more traditional and engineered SUDS.

(iii) There are communities throughout Cardiff which have varying degrees of flood risk. Any developments with watercourses should incorporate natural flood management techniques to improve infiltration, attenuation and slowing flows, these measures will not only benefit biodiversity and water quality, but also can make downstream flood alleviation schemes more resilient, reduce maintenance on downstream culverts and infrastructure and local flooding issues can be less frequent and less severe. This would be go some way to delivering sustainable management of natural resources principles in the Environment Act, and maximising contributions to well-being goals and more sustainable management in the wider environment.

3.23 In respect of flood risk they advise:

(i) The proposed application site is partially within Zone C2 (western edge of central part of the site) as defined by the Development Advice Map (DAM) referred to under Technical Advice Note 15: Development and Flood Risk (TAN15) (July 2004). Their Flood Map information, which is updated on a quarterly basis, confirms the site to be within the 1% (1 in 100 year) and 0.1 % (1 in 1000 year) annual probability tidal flood outlines of the Nant Glandulais, which is a designated main river;

(ii) They also note that the area next to the southernmost western parcel is at risk of flooding from the adjacent reservoirs however, this area appears to be outside of the development red line boundary. (iii) They note the intention to submit a Flood Consequences Assessment (FCA) in Section 12.9 of the Scoping Report. They advise the FCA needs to be undertaken in line with the guidance set out in Technical Advice Note 15: Development and Flood Risk (TAN15) (July 2004).

3.24 The Council's Drainage Division has been consulted and no comments were received.

Ground Conditions

3.25 The Council's Contaminated Land Team, having considered the submitted scoping report, advises that the scope of the assessment in relation to ground conditions and potential contamination is appropriate.

Utilities

3.26 The proposed scope is considered to be acceptable.

Waste

3.27 The proposed scope is considered to be acceptable

4. Scoping Opinion

4.1 In preparing the Environmental Statement, I would draw your attention to the requirements for Environmental Statements set out in Regulation 17 and Schedule 4 to the EIA Regulations.

4.2 Regulation 5(e) of Schedule 4 to the EIA Regulations requires that the cumulative effects with other existing and/or approved projects must be taken into account in an EIA. In this regard, referring to paragraph 1.9, I would confirm that the second Churchlands application (ref: 14/02891/MJR) was granted planning permission on 28 December 2017.

4.3 Regulation 5(f) requires a description of the likely significant effects of the development on the environment resulting from the impact of the project on climate and the vulnerability of the project to climate change. Whilst it could be assumed that this issue is covered in various places by the topics identified, I could not see any specific reference to climate.

4.4 The Council considers that, subject to the comments above and those contained in the attached consultation responses, the issues identified in the submitted scoping report should be included in the Environmental Impact . Assessment to enable the Council to consider the likely environmental effects of the development and whether these are likely to be significant.

I 4.5 The Council will issue its opinion on the scope of the Transport Assessment once discussions with the Highways Authority have ·concluded and the final version is received.

4.6 Please note that this scoping opinion is provided without prejudice and does not preclude. Cardiff Council from requesting further information, in accordance with Regulation 24 of the Regulations, should the need arise.

Yours faithfully

James Clemence HEAD OF PLANNING

PLEASE REPLY TO: Development Management, Strategic Planning, Highways and Traffic & Transportation, County Hall, Cardiff, CF10 4UW (e-mail: [email protected]. uk) (internet: Www.cardiff.gov. uk/dc) North East Cardiff (West of Pontprennau) Environmental Impact Assessment Formal Scoping Opinion Response

This consultation statement has been prepared as a formal response to the Environmental Impact Assessment (EIA) Scoping Report submitted in relation to the North East Cardiff strategic development site.

The Scoping Report sets out the approach that the applicant proposes to use in a forthcoming EIA ,. submission. This response deals with Section 5.0 Transport. Cardiff City Council Highway Authority has considered the information provided with this section and the initial discussions which have been undertaken to date. For background purposes, the discussions to date have been in the focus of the Transport Assessment (TA). The Scopi.ng Report makes reference to the TA and advises that the TA wnl inform the EIA Transport Chapter and a separate scoping exercise will be carr.ied out with CCC for the this purpose. It is worth setting out the Highway Authority's position that the TA will be required to be comprehensive and it will be of paramount importance that the study area extent adequately covers the traffic impact of the proposed development. This will then need to be assessed in an agreed manner with the study area assessment tools being appropriate for the scale ofthe development proposed. It would be advantageous to consider preparing the TA in light of the draft SPG guidance. Completion of the proposed procedure would help to ensure that all requirements/ elements are not only covered, but covered to the highway authority's satisfa~tion.

The statement will provide a response to the scoping report, following the submitted order of headings and subject areas, where possible.

Overview

Within the Overview of the proposed EIA transport scope, it is confirmed discussions which inform the extent of the scope of works and parameters of assessment have commenced. CCC welcomes further discussions on these matters and reserves its decision /approval until an appropriate time.

A full review of the baseline conditions will be required to identify the existing local highway provision for all modes together with identification of any deficiencies. It is antkipated that baseline conditions will be assessed within the area highlighted in Appendix A - plan illustrating our required area of potential impact -

Consideration of the effects of both construction and operation of the development would be required to be undertaken which is reviewed against proposed mitigation measures would be an acceptable way forward.

Peak network hours can be discussed further and following analysis of traffic survey data.

Proposed Assessment Criteria

The proposed development is anticipated to be residential led with complementary facilities such as local centres and education. It would be expected that the assessments consider the peak hours of the highway network during the operational phase of the development.

Although construction traffic is likely to be within the levels forecast for the operational phase of the development it is however, considered that it would be appropriate to assess the impact of construction on the designated routes. The criteria defined for the receptor sensitivity should then include reference to changes in daily HGV flows. These may impact on pedestrian and cycle receptors.

The assessment matrix, provided within the scoping note, shows the interaction of sensitivity and magnitude of change, from which the significance of effect can be determined (i.e. negligible, minor, moderate, major). Prior to making the assessment, criteria need to be set out and approved by CCC for each receptor in terms of sensitivity and magnitude of change. The actual criterion defined is for application of professional judgement.

There is a concern are that in column one of the table presented in the scoping report, under S'.15, there could be any number of additional vehicles in terms of increase, but if it is part of a busy network. (and therefore under 30% of the existing flow) it would be discounted as negligible. Similarly (but not as critical) at the opposite end of the table an increase of less than 30 vehicles, which could be up to 90% of the existing flow, on a very quiet, or a sensitive, route would also be regarded as negligible.

The screening process to delimit the scale and extent of assessment should follow two rules; 1. include highways with increase in traffic/HGVs of more than 30%; and 2. include specifically sensitive areas where traffic flows have increased by 10% or more.

These rules form the starting point for the assessment of effects. Specifically sensitive areas under Rule 2 include accident black-spots, conservation areas, hospitals and links with high pedestrian flows. A number of relevant areas are indicated in Appendix A I B ?

The significance of the effects of the development should be considered in respect of the following receptors based on the IEA Guidelines:

• Severance; • Driver delay; • Pedestrian delay; • Pedestrian amenity; • Fear and intimidation; and • Accidents and safety.

The table in the Scoping Report takes some of the guidance and presents it for agreement. Although, CCC would need to understand and agree the breakdown presented, particularly in terms of sensitivity of receptors in the EIA chapter.

With regards to severance the Scoping Report sets out that a quantitative and qualitative assessment will be undertaken should the TA demonstrate notable increases in traffic flow. Again CCC would need to understand and agree what constitutes a notable increase.

Driver and Bus Delay is reported to be dealt with as a qualitative commentary with regard to the construction phase . For the operational phase, a detailed quantitative and qualitative assessment of driver/bus delay has been suggested if notable increases are identified in the TA. This is agreed · subject to the guidance in the paragraph above and the study area, which is discussed later in this response.

Pedestrian and Cyclist Delay is worth grouping together with other pedestrian related receptors and undertaking a quantitative assessment for the operational phase. Rail Delay is requested that this can be scoped out, we would agree with this.

Amenity, Fear and Intimidation could be grouped together with related receptors as i~ pedestrian and cyclist delay for a quantitative assessment. Although a qualitative assessment should also be considered .

Accide nts and Safety would be a qualitative assessment which is considered to be reasonable. The subjective approach should be supplemented by a quantitative revi ew, which would involve the use of Cobalt. Cobalt predicts cha nges in acddent rates based on changes in traffic flows, junction types, etc. The assessme nt should ident ify if t here are any existing issues in the baseline si tuation and, if, so ca rry forward to the assessm ent of effects.

Hazardous Loads is requested that this can be scoped out. On the basis that there will be a plan for construction traffic management and abnormal and hazardous loads will require detailed planning to minimise disruption and risk, this is agreed.

Study Area and Assessments

The study area for the network capacity assessment has been discussed with CCC. The request was made that the study area is of sufficient scale to assess the traffic impacts of this strategic site. CCC provided junction count locations and an area map of junctions or links which have a history of collisions and are therefore considered to be sensitive to changes in traffic flows. The study area presented in the Scoping Report does not reflect the discussions that have taken place and CCC will require an extended study area.

It is essential that the data which is gathered for the study area is collected in accordance with guidance on traffic surveys and neutral months outside of holidays. CCC will audit any surveys which are presented as evidence for baseline assessments. Some additional survey data can be made available by CCC to supplement that already collected and any additional locations which are identified during this scoping process.

It is noted that the assessment years have been proposed as 2019/20, 2024/25 and 2034/ 35 which represe nt the anticipated years of commencement, 5 years after and com pletion date, res pectively. Th ere is a significa nt ga p betwee n t he second and third assessme nt period . It is the applicant's res po nsibility to demonstrate that t he mitigation mea sures are ade quate and appropriate for the proposed development and evidence will be required t o show when interventions are req uired and on which part of the network. It is suggested that t he assessme nts also include an interim year of 2029/ 2030 and lhis more comprehe nsive approach can be used to demonstrate the effectiveness of the proposed mitigation package as a whole ove r the implementation strategy.

The inclusion of cumulative developme nt has been suggested and also deferred for further discussion within the TA Scop ing Report. The Highway Authority will consult with the Local Planning Authority and provide more in formation during those discussions.

I Cyfoeth Ein cyf/Our ref: CAS-60426-P5J4 Naturiol Eich cy,f/Your ref: SC/18/00001/MJR Cymru Rivers House Natural St Mellons Business Park Resources Fortran Road Wales Cardiff CF3 OEY

Ebost/Email: [email protected] Ffon/Phone: 03000 653 091

FAO: Tim Walter

Cardiff City Council Development Control County Hall Atlantic Wharf Cardiff CF10 4UW

25 April 2018

.Annwyl Syr/Madam I Dear Sir/Madam,

TOWN AND COUNTRY PLANNING ACTS 1990 (AS AMENDED)

REQUEST FOR A SCOPING OPINION - NORTH EAST CARDIFF (WEST OF PONTPRENNAU)

Thank you for referring us to the scoping opinion request for the above application site. We have previously provided a scoping response to this site dated 5 February 2018, where we advised that matters regarding Ecology and Biodiversity, Protected Sites, Watercourses and Flood Risk should be considered in any future Environmental Statement (ES).

Further to our previous letrer, a meeting took place on 28/03/18 between SoltysBrester and NRW to discuss our position in respect of protected sites and European Protected Species. We have since reviewed the submitted 'Updated Response to Scoping Report note' and advise the following likely significant effects are assessed by the applicant and consider they are scoped in to any future Environmental Statement.

Ecology and Biodiversity

Key Habitats We note that an Extended Phase I Habitat survey will be completed for the whole site. We note this will include an update of trees with greater potential to support bats using a ground based inspection.

TY Cambria • 29 Heol Casnewydd • Caerdydd • CF24 OTP Cambria House • 29 Newport Road • Cardiff • CF24 OTP Croesewir gohebiaeth yn y Gyrnraeg a'r Saesneg Correspondence welcomed in Welsh and English We advise this should be undertaken in accordance with the 'NCC Phase 1 survey guidelines (NCC (1990). Handbook for Phase 1 habitat survey. NCC, Peterborough)'and 'Bat Surveys; Good Practice Guidelines 3nd Edition' published by the Bat Conservation Trust 2016 and should be undertaken and completed during the summer to ensure the best chance of identifying the habitats I species present.

Ecology and Protected Species We are aware of the presence of Dormice, Otter and Bats on site.

We note that surveys establishing the presence of dormice in part of the site were carried out in 2014 and 2016 respectively but these were limited to the areas to the north of St Mellom~ Road. We understand that the Applicant has agreed to design the whole site to conserve dormice and that this will be embedded within the masterplan and as part of the comprehensive green infrastructure strategy. Providing this is the case, in this instance we agree that further surveys for dormouse are not required to support the hybrid application. Further to this, we advise that when undertaking habitat surveys, the suitability I favourability of the habitats to support dormice is recorded, in order to inform an assessment of the impacts of the scheme on dormouse populations.

We understand that no direct evidence of Otter was found on site however, the stream corridors have the potential to be used as movement corridors and resting places. We also note the presence of Otter around the Lisvane and Llanishen reservoir. We understand that habitat connectivity for Otter will be maintained along existing stream corridors and further investigations for evidence of their use will be included in the updated Extended Phase I Habitat Survey. ,

We note that further supplementary surveys of bat activity will be undertaken in April and May 2018 and included in the ES. These will focus on trees of moderate or high potential that would be affected by the masterplan layout. We advise that the surveys be kept under review for the duration of the project. We also advise that consideration of dark corridors are included in any green infrastructure strategy produced.

Further to the above we note that justification for not surveying Water Vole, White Clawed Crayfish and Great Crested Newts will be included in the ES. This is based on the limited suitability of the habitat for these species on the site. We agree with this approach. We advise that comprehensive conservation I mitigation strategies are included in the ES, including addressing long term management as appropriate.

Protected Sites

Sites .of Special Scientific Interest (SSS ls) The proposed development site lies adjacent to the Llanishen and Lisvane Reservoir Embankments SSSI and Lisvane Reservoir SSSI. Llanishen and Lisvane Reservoir Embankments SSSI is designated for its diverse grassland fungi including waxcap Hygrocybe species that grow on the grass banks of the reservoir. The waterbody Lisvane Reservoir SSSI is designated for overwintering birds. The citations for these protected sites are available via our designated site search here. We note that the updated Extended Phase

www, natu ralresou rceswales, gov. uk www.cyf oethnatu 1·iolcym ru .gov. uk Page 2 of 5 I Habitat Survey will have regard to fungi however, no dedicated surveys for waxcap will be undertaken. We agree with this approach.

Construction Impacts We note that construction noise from the development would be a direct impact. Noise and visual disturbance are both direct impacts due to the close proximity of the SSSI and therefore should be considered as part of the ES.

Protection of Watercourses We are aware that large amounts of silt are currently in the Glandulais intake. Increases in the amount of sediment from the Glandulais could have a negative impact on bird populations in the area. Changes in water quality can affect food sources and the potential increase in oils can affect feather~ . To protect the water quality of Lisvane Reservoir SSSI, the watercourses in the Glandulais catchment that feed into the mushroom valve to the north of Lisvane Reservoir need to be safeguarded from pollution. We advise that pollution prevention measures (during and post construction) are included in the ES. Further to this, we advise that the applicant have future discussion with DCWW regarding water quality and future planning maintenance works.

Retention and enhancement of habitat We note the reference to the retention of the network of SINCs, hedgerows, trees and woodland, stream corridors, ponds and more diverse areas of marshy grassland in the submitted Phase I Habitat report (dated November 2014).

We recommend the marshy grassland and woodland areas adjacent to Lisvane Reservoir are retained, as shown in drawing E1452101/003 in the Extended Phase 1 Habitat survey report, due to their inherent ecological interest and the buffer the habitat provides between any future proposed housing and SSSls. We note retention of this habitat is also shown on the Schematic Framework for Strategic Site F: North East Cardiff (West of Pontprennau) in Cardiff Deposit Local Development Plan 2006-2026 Masterplanning Framework document dated May 2014. We recommend mycological considerations are included in the updated Phase I habitat survey. The most suitable time to survey for grassland fungi is October and November, avoiding periods of heavy frost.

Further to this, our comments regarding Drainage and Flood Risk are repeated below for your convenience.

Drainage

The ES should take account the potential for imminent changes to the SUDs position by Welsh Government, whereby the need and use of SUDs in development is emphasised. There is the potential for this development to become an exemplar site_for the use of SUDs in construction.

For future developments across Cardiff, the management of water should be considered across the sites. Wide green corridors act as wildlife corridors, but also can be important in filtering water minimising diffuse runoff. It can also attenuate or slow overland flows,

www.naturalresourceswales.gov uk www.cyfoethnaturiolcymru.gov.uk Page 3 of 5 I •

intercepting waters before entering streams and rivers, slowing flows and delaying or stretching out peak flow flooding events. This provides ecosystem resilience, multiple benefits and minimises downstream impacts. It also will enhance the well-being and attractiveness of developments. These wide green corridors should be present throughout developments in addition to more traditional and engineered SUDS.

There are communities throughout Cardiff which have varying degrees of flood risk. Any developments with watercourses should incorporate natural flood management techniques to improve infiltration, attenuation and slowing flows, these measures will not only benefit biodiversity and water quality, but also can make downstream flood alleviation schemes more resilient, reduce maintenance on downstream culverts and infrastructure and local flooding issues can be less frequent and less severe. This would be go some way to delivering sustainable management of natural resources principles in the Environment Act, and maximising contributions to well-being goals and more sustainable .management in the wider environment.

We recommend the Applicant consults further with the Lead Local Flood Authority on this matter.

Flood Risk

The proposed application site is partially within Zone C2 (western edge of central part of the site) as defined by the Development Advice Map (DAM) referred to under Technical Advice Note 15: Development and Flood Risk (TAN15) (July 2004). Our Flood Map information, which is updated on a quarterly basis, confirms the site to be within the 1% ( 1 in 100 year) and 0.1 % (1 in 1000 year) annual probability tidal flood outlines of the Nant Glandulais, which is a designated main river.

We also note that the area next to the southernmost western parcel is at risk of flooding from the adjacent reservoirs however, this area appears to be outside of the development red line boundary.

We note the intention to submit a Flood Consequences Assessment (FCA) in Section 12.9 of the Scoping Report. We advise the FCA needs to be undertaken in line with the guidance set out in Technical Advice Note 15: Development and Flood Risk (TAN15) (July 2004).

Other Matters

Our comments above only relate specifically to matters that are included on our checklist Natural Resources Wales and Planning Consultations (March 2015) which is published on our website at this link (hllps://naluralresources.wales/media/5271 /150302-natural­ resources-wales-and-planning-consultations-final-eng.pclf). We have not considered potential effects on other matters and do not rule out the potential for the proposed development to affect other interests, including environmental interests of local importance. The applicant should be advised that, in addition to planning permission, it is their responsibility to ensure that they secure all other permits/consents relevant to their development.

www.naturalresourceswales.gov.ul< www .cyfoethnaturiolcymru.gov .ul< Page 4 of 5 If you have any further queries, please do not hesitate to contact us.

Yn gywir I Yours faithfully

Lindy Marshall

Ymgynghorydd Cynllunio Datblygu/ Development Planning Advisor Cyfoeth Naturiol Cymru I Natural Resources Wales ·

www.naturalresourceswalesgov.uk www.cyfoethnaturiolcymru.gov.uk Page 5 of 5 I Application No: SC/18/00001- amended comments Proposal: EIA Scoping Opinion Location: North East Cardiff (West of Pontprennau} Date of Reply: 26/04/18 DC Officer: Tim Walter

Tim,

These are my amended comments on the scope of the proposed EIA at this site, which are made without prejudice to any further comments that I may make in the light of any new information or of alterations to the plans as submitted.

In making these comments I have considered the following documents:-

• North East Cardiff (West of Pontprennau} EIA Scoping Report • Land at North East Cardiff Extended Phase 1 Habitat Survey (18th Nov. 2014) • Land at North East Cardiff Summary Note of Badger, Dormouse and Bat Surveys (30th Nov 201G) • Badger and Wintering Bird Survey Report (07 April 2016) • NRW Scoping Opinion Request consultation response (25 April 2018) • Soltys Brewster Updated Response to Scoping Report (10 April 2018}

General Comments

In general I support the proposed scope of the EIA, and where I have not made a specific comment below, it should be assumed that I have no adverse comments on the proposed EIS scope.

I welcome the proposal to update the Phase 1 Habitat Survey, but I agree with the view of NRW that a survey undertaken in summer, especially June or July, would allow a more comprehensive assessment of the habitats and species likely to be present.

Section 2.'14 of the EIA Scoping Report, I welcome the commitment of the ES to identify and assess any likely significant effects of the off-site infrastructure improvements required in association with the proposed development.

Section 9.2 of the EIA Scoping Report - I welcome the reference to the 2016 CIEEM EclA guidelines, and in particular to the inclusion of ecosystems among the ecological features that should be considered in EclA. However, in the documents mentioned above I see little evidence that there are plans to identify ecosystems present and to assess the impacts upon them.

In considering any planning application, Cardiff Council will have to have regard to its duty under section 6 of the Environment Wales Act 2016. That duty being to maintain and enhance biodiversity in the exercise of our functions, and in so doing promote the resilience of ecosystems, so far as is consistent with the proper exercise of those functions. In complying with this duty it will have to take account of the \ resilience of ecosystems, in particular the diversity between and within ecosystems; the connections between and within ecosystems; the scale of ecosystems; the condition of ecosystems and the adaptability of ecosystems.

Any ES for this site will have to provide sufficient information to allow Cardiff Council to discharge this duty in its administration of this application. Therefore I would expect as a minimum the ES to set out the broad ecosystems present and the impacts upon their diversity, extent, connectivity, condition and adaptability. The latest SONaRR documents provide a helpful example of how these assessments · should be made.

Section 9.32 of the EIA Scoping Report - Local Planning Policy - it should be noted that the Green Infrastructure SPG has recently been approved, and so the proposed ES should make reference to the guidance therein.

Designated Sites

lntern~tionally Designated Sites

I agree with the view put forward by NRW that any eventual planning application will have to be subject to a Habitats Regulations App·raisal (HRA), which will most likely focus upon the impact of increased recreation upon the Cardiff Beech Woods SAC. The information contained within the ES would be used to inform the HRA, but I would not say that any specific surveys or assessments are needed in respect of the HRA

Sites of Special Scientific Interest (SSSI)

I agree with the view put forward by NRW that the impact of construction and occupation of the proposed development upon the SSSls nearby should be assessed. I support NRW's comments in this respect ..

Site of Importance for Nature Conservation (SINC)

In accordance with Section 5.5.3 of Technical Advice Note 5, development should avoid harm to SINCs as far as possible. Where harm is unavoidable it should be minimised by mitigation measures and offset as far as possible by compensation measures designed to ensure there is no reduction in the overall n~ture conservation value of the area or feature. Therefore the impact upon SINCs should be assessed, and measures put forward to counteract any adverse impact.

European Protected Species (EPS)

Dormice I support the proposal to assume the presence or dormice throughout the site, and to incorporate measures of avoidance, mitigation and habitat compensation into the Green Infrastructure Strategy for the site. Retention of high quality habitat and robust habitat connectivity are critical for the maintenance of favourable conservation status of this species at this site.

Bats

I support the proposals to re-survey for bats.

Otters

Otters are known to use the environs of the Llanishen I Lisvaen Reservoirs, and have also been found dead on the M4 along the north of this site. Therefore it is reasonable to assume that they use watercourses such as the Nant Glandulais, Nant y Draenog and Nant Ty-draw, as well as ponds such as the large pond in Malthouse Wood. This being the case, the impact of both construction and occupation (dog­ walkers etc) of any development proposals should be assessed.

Great Crested Newts

I accept tha't we have no historical records of GCN in this area, but this in itself in not evidence that this species not present. However following the meeting on 28th March I accept that further detailed GCN surveys are not needed, and that the GI strategy will incorporate aquatic and terrestrial habitat suitable for this species should they colonise the area in future.

Reptiles

I accept that much of the habitat on this site comprises heavily improved agricultural land, which is generally not suitable for reptiles. However, there are limited areas of suitable habitat, for example in the bases of hedgerows and in some areas of land which have not been recently grazed or managed. Therefore I would say that more detailed reptile surveys are best left until any subsequent reserved matters applications.

Badgers

I accept the results of the badger surveys. Any ES should include measures to avoid disturbance to badger setts, as well as measures to allow badgers to continue to forage and disperse throughout the site.

Freshwater crayfish and Water Voles

If there are no plans to survey for these species, then full justification should be provided. Enhancements

Any eventual development at this site would have to include measures to enhance habitats for species such as bats and nesting birds etc, above and beyond those measures which are necessary to mitigate and compensate for any adverse impacts identified by the ES.

Technical Standards

Qualifications and Competencies

Suryeys should be carried out by a suitably qualified and experienced ecologist, with the appropriate licences if necessary, using appropriate method~logy and techniques. We recommend that reference is made to the relevant survey methods listed in the CIEEM Sources of Survey Methods document; as part of the CIEEM Technical Guidance Series.

Ecological surveyors should meet the level of competency for each of the species/groups that they are surveying, as set out in the CIEEM Competencies for Species Survey documents. Surveyors should be able to demonstrate that they have the necessary training, skills and experience, if required.

Data 'Shelf-life'

As a general principle, survey work which is more than 2 years old will be regarded with caution, as certain species may colonise or leave an area in the interim period. This is particularly the case with mobile species such as bats, and bat surveys greater than 2 years old will have to be repeated. It is also likely that planning conditions will be attached requiring pre-commencement surveys for certain species.

Biodiversity and Resilience of Ecosystems Duty

These comments contribute to this Authority's discharge of its duties under Section 6 of the Environment (Wales) Act 2016. This duty is that we must seek to maintain and enhance biodiversity in the exercise of our functions, and in so doing promote the resilience of ecosystems, so far as is consistent with the proper exercise of those functions. In complying with this duty we will have to take account of the resilience of ecosystems, in particular the diversity between and within ecosystems; the connections between and within ecosystems; the scale of ecosystems; the condition of ecosystems and the adaptability of ecosystems.

Yours,

Matt Harris Ecologist