DECC REFERENCE: LLANDINAM GRID CONNECTION

ELECTRICITY ACT 1989 (Sections 36, 37, 62(3) & Schedule 8)

TOWN AND COUNTRY PLANNING ACT 1990 (Section 90)

and

THE ELECTRICITY GENERATING STATIONS AND OVERHEAD LINES (INQUIRIES PROCEDURE (ENGLAND AND WALES) RULES 2007

APPLICATION BY SCOTTISH POWER ENERGY NETWORKS (SPEN), DATED 7th DECEMBER 2009, FOR CONSENT UNDER SECTION 37 OF THE ELECTRICITY ACT 1989 TO CONSTRUCT AND OPERATE A 132KV OVERHEAD ELECTRICITY TRANSMISSION LINE BETWEEN BRYN DADLAU SUBSTATION AND WELSHPOOL SUBSTATION, POWYS, MID WALES (“LLANDINAM GRID CONNECTION”)

DECC REFERENCE: LLANDINAM GRID CONNECTION BERR/2009/0005

SUMMARY PROOF OF EVIDENCE of Mr John Campion BA(Hons) BLD MSc CMLI MCIEEM

On behalf of

Natural Resources Wales

Anthony Jellard Associates

Pear Tree Cottage Grosmont Abergavenny Monmouthshire NP7 8LG

Tel. 01600 750475 Fax 01600 750545 e-mail: [email protected] POWYS CONJOINED WIND FARMS PLANNING INQUIRY LANDSCAPE SUMMARY PROOF OF EVIDENCE – NATURAL RESOURCES WALES - LLANDINAM GRID CONNECTION

INTRODUCTION

1.1 My name is John William Campion. I am a Chartered Landscape Architect, having been qualified in both the Landscape Architecture and Landscape Management Divisions of the Landscape Institute since September 1982 and January 1989, respectively. I am also a full Member of the Chartered Institute of Ecology and Environmental Management.

1.2 In my main Proof I set out my qualifications and experience and provide details of my commission which lies within the remit of Natural Resources Wales, including the involvement I have had in connection with this proposal. I set out Natural Resources Wales' purpose and functions and their support for government's energy policy and the need to minimise environmental harm.

1.3 The evidence which I have prepared and provide for this Planning Inquiry in this Proof of Evidence is true, and has been prepared and given in accordance with the guidance of my professional institution, and I confirm that the opinions expressed are my true and professional opinions.

THE PROPOSED DEVELOPMENT 2.1 In Section 2 of my Proof of Evidence I describe the proposed development.

POLICY CONTEXT 3.1 In Section 3 of my Proof of Evidence, deal with relevant policy matters. I confirm that my evidence does not address the matter of planning need or any alternative proposals for a grid connection route. I set out the National policies and guidance for England and Wales, and the adopted local planning policies, which are relevant to the landscape and visual amenity issues under consideration at this Inquiry, including the relevant provisions of NPS EN-1, NPS EN-5 -with specific reference to the Holford Rules in the design of electricity lines - PPW and TAN8. I comment on how the proposed 132kV Llandinam Grid Connection would relate to these various policies and guidance.

THE LANDSCAPE CONTEXT OF THE APPLICATION SITE 4.1 In Section 4 of my Proof of Evidence, I describe the landscape context of the Application Site.

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DEFINITIONS 5.1 In Section 5 of my Proof of Evidence, I begin by providing definitions of technical terms used in landscape character assessment, with particular reference to practice in Wales and the use of the LANDMAP hierarchical classification system for landscape assessment. I also refer to the term 'Historical Landscape Characterisation' where this has been used to provide additional detailed information about the local landscape character within the Vale of Montgomery Registered Landscape of Outstanding Historic Interest in Wales.

LANDSCAPE CHARACTER ASSESSMENT

5.2 I go on to describe landscape character, included within the scope of the ELC definition, which is an important concept to enable our understanding of landscapes. Technical approaches to identifying and assessing landscape character have evolved over recent decades and in Wales the collection of information on the underlying influences that make up landscape character has been structured through a national assessment programme known as LANDMAP. I also note that Registered Historic Landscapes are based on professional academic consensus, backed by specialist Historic Landscape Characterisation.

Commentary on the Landscape Character and Sensitivity Assessments by the Applicant

5.3 I then provide a commentary on the Landscape Character and Sensitivity Assessments undertaken by the Applicant. I conclude that the presence of the Vale of Montgomery Registered Landscape of Outstanding Historic Interest in Wales underlying part of the route is a very significant landscape receptor. I conclude that the landscape sensitivity analysis undertaken by the Applicant is at too coarse a level to be reliable in fully understanding the sensitivity of the landscape through which the route will pass across the Vale of Montgomery and in the lower Severn Valley between Powis Castle and Leighton. In my opinion, this has led to an understatement of the value placed upon parts of the landscape, which has then been used as part of the basis for reaching their conclusions as to the significance of the predicted landscape and visual effects. Their assessment of sensitivity is therefore unreliable. Unlike the Applicant's assessor, I consider that the Vale of Montgomery Registered Landscape of Outstanding Historic Interest in Wales should be classified for landscape and visual assessment purposes as being of high landscape sensitivity, since it is of acknowledged national importance. In

3 Landscape Summary Proof of Evidence (FINAL 20th Dec 2013) POWYS CONJOINED WIND FARMS PLANNING INQUIRY LANDSCAPE SUMMARY PROOF OF EVIDENCE – NATURAL RESOURCES WALES - LLANDINAM GRID CONNECTION addition, Offa's Dyke National Trail passes through the same area of landscape as the proposed line route, within 1 km to the east. This is one of only 3 National Trails in Wales. I also conclude that the characteristics of the landscape in Section H and of the adjacent Leighton Hall estate are such that they warrant an increase in landscape sensitivity to high rather than medium-high, as ascribed by the Applicant's assessor. Therefore this increase in sensitivity leads to an increase in the significance of the effects on this area.

Landscape Character Assessment based upon LANDMAP Data and Historic Landscape Characterisation

5.4 Continuing in Section 5 of my Proof of Evidence, I then examine the Landscape Character along the route for the proposed 132kV Llandinam Grid Connection and its landscape context referring to the most recent LANDMAP data for all five Aspects. I then draw the following conclusions in respect of Landscape Character Assessment.

Conclusions in respect of Landscape Character Assessment

5.5 The Applicant's landscape assessor has undertaken an assessment of landscape character which is at too coarse a level to identify and describe accurately the underlying landscape character along sections F, G and H of the route for the proposed 132kV Llandinam Grid Connection.

5.6 By undertaking a more detailed assessment for Sections F, G and H, I conclude that there are high overall evaluations of the Visual & Sensory Aspect Areas within Section F (the Camlad Valley) and at the northern end of the route at Section H, where there is high evaluation both where the line would run (Severn Valley Cilcewydd to Leighton) and in an area immediately adjacent to the east (Leighton Hall Estate Parkland).

LANDSCAPE CAPACITY 5.7 In the final part of Section 5 of my Proof of Evidence, I deal with the matter of assessing the capacity of the landscape to accept changes resulting from the construction and operation of the line without detriment to landscape character, using published national guidance.

5.8 I conclude that the Applicant's landscape assessor has not carried out a Landscape Capacity Study in strict accordance with current guidance. In my opinion, the landscape through which Sections F and G of the proposed 132kV Llandinam Grid

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Connection would run across the Camlad valley between Court Calmore and the A490 near Fron has a low capacity to accept change in the form of the proposed 132kV Llandinam Grid Connection. Section H is identified by the Applicant's assessor as that part of the route which runs northwards from Cilcewydd to terminate at the operational substation adjacent to the B4381 east of Welshpool. I also conclude that this landscape has a low capacity to accept change in the form of the proposed 132kV Llandinam Grid Connection.

LANDSCAPE AND VISUAL EFFECTS OF THE PROPOSED LLANDINAM GRID CONNECTION

6.1 In Section 6 of my Proof of Evidence, I draw conclusions as to the predicted landscape and visual effects of the proposed grid connection.

Effects on the Vale of Montgomery Registered Landscape of Outstanding Historic Interest In Wales

Landscape Effects on the Registered Landscape 6.2 From my analysis of the SEI, I conclude that the Applicant's assessor's subdivision of the route of the proposed 132kV Llandinam Grid Connection in relation to the Vale of Montgomery Registered Landscape of Outstanding Historic Interest does not appear to be based upon the identified and mapped boundaries of the underlying LANDMAP Visual & Sensory Aspect Areas (Level 3). Since the Applicant has not gone to the more detailed Level 4 Visual & Sensory LANDMAP Assessment to provide any supporting visual and sensory information, I can see no Visual & Sensory evidence basis as justification for the identified line route subdivisions in the October 2013 SEI.

6.3 There is also no correspondence between the identified Level 3 Historic Landscape Aspect Area boundaries and the Applicant's assessor's line route subdivisions. There is also no correlation between the HLCA boundaries identified by the Historic Landscape Characterisation work for the Vale of Montgomery Registered Landscape of Outstanding Historic Interest. I can therefore see no Historical Landscape evidence basis as justification for the identified line route subdivisions in the SEI.

6.4 I have carried out a Level 4 LANDMAP Visual & Sensory Assessment for the locality and referred in detail to the HLCA information underpinning the Vale of Montgomery Registered Landscape of Outstanding Historic Interest in Wales.

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6.5 I do not agree with the Applicant's landscape assessor's conclusion that Corridor Section F: Court Calmore near B4385 to the B4386 near Woodlands should be ascribed medium-high sensitivity. The landscape traversed by the proposed line across the Camlad valley is substantially open, with a gently sloping terrain and the aggregation of multiple double wood poles and their supporting frames will be an entirely new linear element in this landscape. Low winter sun effects on this infrastructure will increase their visibility and their presence in the landscape, resulting in a medium magnitude of change. The new line will give rise to cumulative landscape effects with the existing low-voltage lines which run through that section of the landscape between Offa's Dyke National Trail and the Shrewsbury-Machynlleth railway line and the incongruous operational substation adjacent to the B4386 road east of Woodlands Farm. These effects would conflict with Holford Rule 6, which states that: 'Rule 6: In country which is flat and sparsely planted, keep the high voltage lines as far as possible independent of smaller lines, converging routes, distribution poles and other masts, wires and cables, so as to avoid a concentration or ‘wirescape’.'

These effects would be apparent not only from Offa's Dyke Path National Trail but also from the B4388 road which crosses the Camlad valley and from the B4386 road which runs alo9ng the northern edge of the valley. My Viewpoint NRW1 south of Salt Bridge on the B4388 shows the local context. (Refer to the photograph at Figure 5 in Appendix 3 to my Proof of Evidence). There will be significant direct and adverse effects on both landscape elements and landscape character along the route of the proposed 132kV Llandinam Grid Connection between Court Calmore and Fron. There is no existing structure in this landscape which has any similarity to that of the proposed 12-16 metres high double wood poles with steel supporting frames. Reliance upon tree cover which includes a significant proportion of ash trees to contribute to screening or assimilation needs to be considered in the light of the onset of ash die-back disease. The effects of this pathogen would be to open up the landscape still further, with younger trees affected first. Views of the Camlad valley from the western edge of the hamlet of Hendomen and from the elevated viewpoint at Montgomery Castle illustrate the rather open nature of much of the valley landscape where the line would run.

Visual Effects on Offa's Dyke Path National Trail 6.6 I conclude that In addition to the adverse landscape effects described above, travellers along Offa's Dyke Path National Trail would experience significant adverse

6 Landscape Summary Proof of Evidence (FINAL 20th Dec 2013) POWYS CONJOINED WIND FARMS PLANNING INQUIRY LANDSCAPE SUMMARY PROOF OF EVIDENCE – NATURAL RESOURCES WALES - LLANDINAM GRID CONNECTION visual effects. The length of the National Trail experiencing such effects would be at least 2 kms. This is an important route along which travellers can experience the unspoilt nature of much of the Vale of Montgomery landscape without distractions caused by passing vehicular traffic. I do not agree with the full detail of the Applicant's assessors definitions of magnitude of visual effects as set out in the SEI, for the following reasons. Reference to Tables 6.10a and 6.10b of the SEI shows that the assessment of significance has been reduced in relation to the visual sensitivity and the magnitude of change assessed at several viewpoint locations (for example, at VP13a, VP50 and VP51). For each of these viewpoints, a high visual sensitivity and a high magnitude have been ascribed, and yet the resulting visual effect is judged to be moderate, whereas I would expect the outcome to be major, unless otherwise qualified. This gives me little confidence in the Applicant's judgements of the predicted effects from Offa's Dyke Path National Trail.

6.7 These adverse effects would be particularly experienced from that section of the National Trail crossing the open landscape of the Camlad valley between the B4386 running east-west along the northern edge of the valley between the B4388 and Upper Hem farmstead and to the south of Devil's Hole. The footbridge over the River Camlad at c. 83m AOD (OSGR SO 2310 9925) is an important change point in the experience of this local landscape - crossing the river which also forms the border with England - a place where it is natural to pause, take in the views and reflect on the scene. The 180-degree view to the east, remarkably, is devoid of any overhead lines and poles and other man- made vertical elements. By contrast, there is a local concentration of low-voltage overhead lines between the National Trail and the Shrewsbury-Aberystwyth railway line. Some of these run up to the unattractive operational substation adjacent to the B4386 road east of Woodlands Farm, whilst another runs north-westwards towards the Severn Valley, its wood pole supports being seen as closely stacked in the view. Increasing the density of the concentration of overhead lines in the locality, especially by introducing much larger poles and steel supporting frames, would again conflict with Holford Rule 6.

6.8 There will be repeated views of sections of the proposed 132kV line, especially as it traverses the higher ground as it rises up from the Camlad floodplain near Woodlands Farm, where it is likely to be seen breaking the skyline. The attractive views to the south towards Montgomery would also be adversely affected, where key historical features also form important landmarks - Montgomery castle, Montgomery church, the wooded hill of Ffridd Faldwyn and the Town Hill monument. The proposed line would also be visible as it crosses the lower valley slopes just to the west of Hendomen hamlet, which form part of

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6.9 These 12-16 metres high double wood poles, with their steel supporting frames between their tops, would be entirely new man-made features in these views. In winter, when the sun is at a low angle, such steel frames and insulators can be readily seen, especially when strong sunlight follows rain, which increases the reflectivity of these components and their impacts upon the amenity of users of the trail.

Visual Effects on the National Cycle Route 81, B4381 Lower Leighton 6.10 I also conclude that there would be cumulative landscape and visual effects in combination with the existing 132kV and low-voltage lines which would adversely affect part of the setting of Holy Trinity Church, Leighton, and the views of it to the south-east from the National Cycle Route 81, where it runs along the B4381 road east of Leighton Bridge over the River Severn.

6.11 Moderate adverse effects would occur upon a high sensitivity landscape which would result in a significant adverse landscape effect in this section of the proposed line route. Moderate adverse effects would occur on the visual amenity of the travellers along National Cycle Route 81, high sensitivity receptors, the main focal point of attractive views being the conspicuous spire of Holy Trinity Church. It should be noted that the existing 132kV line in this locality is supported on double wood poles with only a single steel supporting frame at the top, unlike the much heavier lattice frames proposed for the Llandinam Grid connection line poles, as illustrated at Figure 1.2 of the Non-Technical Summary of the SEI. In addition, the two terminal poles proposed for the end of the line opposite the Welshpool grid substation are heavier still, each having four supports and multiple insulators.

Landscape and Visual Effects on the Kerry Ridgeway Locality 6.12 The proposed 132kV Llandinam Grid Connection would cause significant adverse landscape and visual effects in Section B of the route as it crosses the high ground in the area of Black Gate. This is a remote location which is close to the western end of the promoted Kerry Ridgeway regional trail. There are very few overhead lines in this area and these are low voltage. Although the proposed 132kV line would be seen against land backdrops for much of its route, it would be partly sky-lined as it crosses the B4355 road running southwards from Dolfor towards the head of the Teme Valley. Some mature tree removal will be required, and a long section of the line would be seen at an angle from the

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CUMULATIVE EFFECTS 7.1 In Section 7 of my Proof of Evidence, I deal with the predicted cumulative effects of the proposed grid connection. I deal with matters within SSA C, relating to existing and proposed wind farm developments, and in relation to the existing 132kV lines within the Severn Valley between Welshpool and Leighton and the consented Lower Leighton Farm Extension.

7.3 Part of Section B of the proposed line route within SSA C would pass through the northern section of the proposed Neaudd Goch wind farm site. This would create a potential conflict with the operation of wind turbines in that vicinity which would need to be resolved by re-siting proposed turbines, diverting the proposed 132kV Llandinam Grid Connection or by placing part of it underground.

7.4 In the northernmost part of the route, Section H between Cilcewydd and the Welshpool grid substation, there would be a gradual convergence of the proposed line with the operational 132kV line running down the lower Severn valley from Abermule. This line crosses over the River Severn from its western side to the east of the river to the south-east of Gravel Lodge. Both lines would then run roughly parallel along the valley as far as the Welshpool substation. There would be cumulative landscape and visual effects arising from this part of the line route, both in combination with the existing 132kV line in the valley and the network of existing low voltage lines, many of which connect to the Welshpool substation. In my opinion, these effects would be significant and adverse. These effects would conflict with Holford Rule 6.

7.5 The significant landscape effects would occur as a result of introducing a further high-voltage line into this part of the Severn Valley which has a high landscape sensitivity. This section of the valley forms part of the wider setting of the Leighton Hall estate with clearly legible estate landscape features, both built elements and characteristic parkland trees, specimen exotic tree species and avenue trees.

7.6 The significant visual effects would occur in further disrupting the views across the valley to Holy Trinity Church from the B4381 and from the footpath along the eastern bank of the River Severn to the north of Gravel Lodge.

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CONCLUSIONS

8.1 In Section * of my proof of Evidence, I draw the following conclusions with regard to the landscape and visual effects of the proposed 132kV Llandinam grid connection.

8.2 The proposed 132kV Llandinam Grid Connection would cause significant adverse landscape and visual effects within Sections F and G, where it crosses the Vale of Montgomery Registered landscape of Outstanding Historic Interest in Wales. By failing to avoid this landscape of national importance, the proposed route here would conflict with Holford Rules 1 and 2: Rule 1: 'Avoid (if possible) the major areas of highest amenity value, even if total mileage is somewhat increased in consequence'; Rule 2: 'Avoid smaller areas of high amenity value or scientific interest by deviation, provided this can be done without using too many angle towers.'

If deviation is not a considered to be a reasonable mitigation measure, then the new line should be placed underground throughout the Vale of Montgomery Registered Landscape of Outstanding Historic Interest in Wales.

8.3 The proposed 132kV Llandinam Grid Connection would cause significant adverse landscape and visual effects within Section H in the sensitive area of the lower Severn Valley landscape between Powis Castle estate and the Leighton Hall estate. There would be individual and cumulative landscape and visual effects, the latter in combination with the existing high and low voltage line infrastructure and the Welshpool grid substation. These effects would conflict with Holford Rule 6 which states that: 'Rule 6: In country which is flat and sparsely planted, keep the high voltage lines as far as possible independent of smaller lines, converging routes, distribution poles and other masts, wires and cables, so as to avoid a concentration or ‘wirescape’.'

Although the Applicant suggests that the detailed design stage of the project would consider local undergrounding of low-voltage lines where they would cross the proposed 132kV Llandinam Grid Connection, the undergrounding of the new line is not considered to be 'embedded mitigation'. In my professional opinion, the undergrounding of the proposed 132kV Llandinam Grid Connection in that section between the road north east of Cilcewydd and the Welshpool grid substation should be the appropriate mitigation measure.

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8.4 The proposed 132kV Llandinam Grid Connection would cause significant adverse landscape and visual effects in Section B of the route as it crosses the high ground in the area of Black Gate. The high landscape sensitivity of this section of the route is acknowledged by the Applicant and the potential for undergrounding part of this Section has been mentioned as a potential mitigation measure. I would suggest that this mitigation measure is applied in this locality.

8.5 For the above reasons, I believe that the Inspector should give very considerable weight to the landscape and visual effects of the proposed 132kV Llandinam Grid Connection when formulating his recommendation as to whether the scheme should be granted consent, and consider whether such impacts could be avoided or minimised through placing sections of the route underground, as detailed above.

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