Wentlooge Farmers' Solar Scheme Limited July 2020

Planning, Design and Access Statement

Proposed Renewable Energy Hub On behalf of Farmers’ Solar Scheme Ltd

www.savills.co.uk

Project: Wentlooge Farmers’ Renewable Energy Hub

Client: Wentlooge Farmers' Solar Scheme Limited

Job Number: TRP 1768

File Origin: Internal

Document Checking:

Prepared by: Nick Beddoe & Peter Grubb Signed: :

Checked by: Peter Grubb Signed:

Verified by: Peter Grubb Signed:

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Contents

1.0 Executive Summary ...... 9

2.0 The Site and Designations ...... 13

2.1 The Site ...... 13

2.2 Ecological Designations ...... 14

2.3 Levels Historic Landscape ...... 16

2.4 Severn Estuary Designations ...... 17

2.5 Public Rights of Way ...... 19

2.6 Heritage and Archaeological Assets ...... 20

2.7 Flood Risk ...... 20

3.0 The Proposed Development ...... 22

3.1 The Development Composition ...... 22

3.2 Materials ...... 24

4.0 Key Benefits from the Scheme ...... 26

4.1 Environmental Benefits ...... 26

4.2 Social Benefits ...... 29

4.3 Economic Benefits ...... 31

5.0 Planning Policy Assessment ...... 32

5.1 Introduction ...... 32

5.2 National Policy ...... 32

5.3 Energy : A Low Carbon Transition (2012) ...... 33

5.4 Well-being of Future Generations Act ...... 34

5.5 Planning Policy Wales (Edition 10, 2018) ...... 35

5.6 Technical Advice Notes ...... 37

5.7 Emerging National Planning Policy ...... 38

5.8 Practice Guidance: Planning for Renewable and Low Carbon Energy - A Toolkit for Planners ... 40

5.9 Newport Local Development Plan 2011 - 2026 ...... 42

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5.10 Renewable and Low Carbon Energy Assessment: Torfaen Council and Newport

City Council ...... 48

5.11 Capacity ...... 49

5.12 Targets ...... 49

5.13 Identified Opportunities ...... 50

6.0 Assessment of proposals against planning policy ...... 52

6.1 Principle of Development ...... 52

6.2 Site Designations ...... 53

6.3 Project Ownership ...... 60

7.0 Assessment of Environmental Impacts ...... 61

7.1 Overview ...... 61

7.2 Traffic and Transport ...... 61

7.3 Cultural Heritage ...... 64

7.4 Landscape and Visual Effects ...... 66

7.5 Ecology ...... 68

7.6 Ornithology ...... 70

7.7 Flood Risk and Water Resources ...... 71

7.8 Glint and Glare ...... 73

7.9 Noise ...... 74

8.0 Additional Assessments ...... 76

8.1 Agricultural Land Quality ...... 76

8.2 Tree Survey ...... 76

9.0 Sustainability Credentials ...... 78

9.1 Introduction ...... 78

9.2 Economic Sustainability ...... 78

9.3 Social Sustainability ...... 80

9.4 Environmental Sustainability ...... 81

10.0 Conclusions ...... 84

10.1 Summary ...... 84

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1.0 Executive Summary

This Planning, Design and Access Statement has been prepared by Savills UK Ltd on behalf of the

Wentlooge Farmers’ Solar Scheme Ltd. to support a DNS application for the Erection of a Renewable

Energy Hub comprising ground mounted solar panels, battery storage units (160 units) with a combined

installed generating capacity of up to 125MW, underground cabling, grid connection hub, associated

infrastructure, landscaping and environmental enhancements, for a temporary period of 40 years.

The site is located at land on the Wentlooge Levels to the west of Hawse Lane, between the villages

of St Brides and .

The grid connection hub is located within a central area of the site and would be well-screened by

existing vegetation. It will sit alongside the battery storage area adjacent a large electricity pylon (132

KV pylon).

The proposals will be temporary for a period of 40 years after which the site could be returned to its

current condition, with a positive legacy of planting and landscape management retained for the benefit

of the area.

Sheep would be grazed between the panels while providing an additional income for the landowners

they also serve to maintain the grassland.

The proposed development includes supporting infrastructure comprising inverter cabins, transformers,

grid connection hub, stock proof fence, CCTV, underground cabling, temporary vehicle tracks, access

and landscaping.

A substantial area of land is proposed to be set aside and managed for breeding birds.

Solar PV panels silently convert sunlight to electrical energy. They generate direct current (DC) that is

converted by the inverter hardware to alternating current (AC) that can be used by the electricity grid.

PV systems are rated for capacity in watts (or kW or MW) with the designation 'peak' (e.g. kWp, MWp).

The peak capacity of individual panels is established by measuring their performance under

internationally recognised standard conditions that include temperature and wavelength of sunlight.

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The actual output of a system will be determined by latitude, local weather and site conditions.

The proposals would export up to 125MW of electricity. The export of electricity would be controlled by

the inverters. In accordance with guidance outlined by the Solar Trade Association1 this would offset

around 53,750 tonnes (21.2 kilotons) of CO2 per annum, and 2,150,000 tonnes over the life of the

scheme. This equates to enough electricity to serve the total power needs of around 37,500 average

UK households per annum.

The proposals have been subject to a full Environmental Impact Assessment (EIA), which has been

based on a suite of evidence based studies completed over a period of two years.

This EIA describes the significance of potential impacts caused by the development to the following

key aspects identified during scoping:

 Traffic and Transport

 Cultural Heritage

 Landscape and Visual Effects

 Ecology and Nature Conservation

 Ornithology

 Flood Risk and Water Resources

 Glint and Glare

 Noise; and

 Agricultural Land Quality

 Tree Survey

 Potential impacts upon Population and Human Health

The EIA confirms that where impacts arise these can be either mitigated, compensated for or are

outweighed by the benefits of the scheme.

1 Solar Trade Association 2016: Resource Centre - http://www.solar-trade.org.uk/solar-farms/

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Planning Policy Wales (Edition 10, December 2018), sets out the national tier of land use planning

policies for Wales and is supplemented by a series of Technical Advice Notes (TANs). The document

makes numerous references to promoting sustainable development and the need to tackle climate

change.

Of particular relevance is paragraph 5.7.8, which explains that “the benefits of renewable and low

carbon energy, as part of the overall commitment to tackle climate change and increase energy

security, is of paramount importance. The continued extraction of fossil fuels will hinder progress

towards achieving overall commitments to tackling climate change.”.

For the purposes of this application, the pertinent development plan is the Newport Local Development

Plan 2011 – 2026 which was formally adopted in January 2015.

The most relevant policy within the plan is Policy CE10 [Renewable Energy], which states that

renewable energy schemes will be “considered favourably, subject to there being no over-riding

environmental and amenity considerations.” It further states that “large scale proposals may be more

appropriately located outside of the defined settlement boundary if no appropriate brownfield sites exist”

and that the “cumulative impacts of renewable energy schemes will be an important consideration”.

Paragraph 4.51 of the supporting text to the policy explains that particular care should be taken when

assessing proposals for renewable energy projects in sensitive, designated areas, such as areas of

high landscape quality, and areas of nature conservation, or archaeological or historical importance. It

continues to state that:

“The Gwent Levels are recognised as an internationally important resource in terms of landscape and

heritage and nationally important for ecology. Proposals which affect the special qualities of the Gwent

Levels, or any other protected site, will be resisted unless it can be demonstrated that there will be no

significant adverse effects.”

The proposed scheme would make a substantial contribution towards meeting Wales’ renewable

energy targets and the transition to a low carbon economy. There would be no overriding environmental

or amenity consideration and the scheme would preserve, and in many ways enhance the special

qualities of the Gwent levels.

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2.0 The Site and Designations

2.1 The Site

The site is located on agricultural land on the Wentlooge levels in and lies within the local

plan area for . At a local level, the site lies within the Marshfield ward and the

Wentlooge Community Council Boundary.

The site occupies a distinctively flat area of land to the south of the railway line between Cardiff and

Newport. The site is shown below in Figure 1. and sits between the settlements of Marshfield,

Peterstone and St Brides. There are no buildings within the site boundary.

Figure 1 Site Location

There are a number of large pylons on the land that carry cables across the site towards a nearby

substation. These would facilitate a connection to the electricity grid and are shown below in Figure 2.

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Figure 2 View of site showing electrical pylons

2.2 Ecological Designations

The site is subject to a Site of Special Scientific Interest (SSSI) designation under the St Brides SSSI.

The boundary for this area is shown below in Figure 3.

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Figure 3 Map showing boundary of St Brides SSSI in relation to the site

The Countryside Council for Wales (CCW) have released guidance to explain the special features of

these SSSIs set out in documents titled ‘Your Special Site and its Future’. Within these documents the

St Brides SSSI is noted for the having three features of special interest as follows:

 Reen and ditch habitat

 Insects and other invertebrates

 Shrill Carder Bee

In addition to these features, this SSSI is noted to comprise other habitats that contribute to the special

wildlife interest in the area. These include green lanes, hedgerows and flower rich ditch banks which

are important for a wide range of species. The CCW guidance explains that the management of these

sites should aim to look after these habitats as well as the listed features of interest.

It is explained within each of the related guidance documents that CCW are working with the Council,

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developers, owners and other relevant bodies “to ensure that where development does take place the

special interests of the SSSI are conserved and enhanced”.

Paragraph 3.24 of the supporting text to Local Plan Policy GP5 (General Development Principles –

Nature Conservation) explains that SSSI sites “will require the fullest regard to the intrinsic value of the

site and their nature conservation value. Development with the potential to affect a recognised site will

be closely scrutinised for any direct or indirect effects. The developer must demonstrate the case for

development and why it could not be located on a site of less significance for nature conservation”.

2.3 Gwent Levels Historic Landscape

The site area also lies within the Gwent Levels Historic Landscape Area as shown on Figure 4 as

designated under the Register of Landscapes, Parks and Gardens of Outstanding Historic Interest in

Wales.

The area comprises discrete and extensive areas of alluvial wetlands and intertidal mudflats and

represent a 'hand-crafted' landscape having been recurrently inundated and reclaimed from the sea

since the Roman period. The areas have distinctive patterns of settlement, enclosure and drainage

systems belonging to successive periods of use.

This Area is further broken down into 21 ‘character areas’ which reflect the locally distinctive features

within the area as shown on Figure 4.

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Figure 4 Gwent Levels Historic Landscape Area

The application site stretches across the ‘Western St Brides’ and ‘Maerdy’ Character areas. These

areas are described within the Historic Landscape Character record and are briefly characterised as

follows:

1. Western St Brides: ‘simpler landscape, laid out within a framework of elements surviving from

the Roman landscape’

2. Maerdy: ‘Regular landscape" of medieval/post-medieval date in low-lying back-fen.’

2.4 Severn Estuary Designations

The application site lies to the north of the Severn Estuary which is widely recognised for its

environmental importance as reflected by its international designation as an SPA, SAC and a Ramsar

site. The site does not fall within the boundaries of these designations, but given their significance and

their proximity to the site, it has been important to consider the potential impact of the proposals in this

regard.

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Resulting from its designation as an SPA and an SAC, the area is also defined as a European Marine

Site (EMS) in accordance with the Conservation of Habitats and Species Regulations 2010. A

‘European Marine Site’ is not itself a statutory site designation but is essentially a management unit for

those parts of Natura 2000 sites in the UK which extend beyond the Site of Special Scientific Interest

(SSSI) /Area of Special Scientific Interest (ASSI) designations.

The Severn Estuary Special Protection Area (SPA) and Ramsar site designations refer to the same

habitat types and therefore share the same boundary as shown on Figure 5. The Severn Estuary

Special Area of Conservation (SAC) captures a wider assemblage of species and habitats and covers

the whole Severn Estuary area as shown on Figure 5.

Its designation as an SPA is facilitated through legislation set out within the European Commission’s

‘Birds Directive’ (2009/147/EC). The ‘qualifying interest features’ are detailed within the ‘Regulation 33

Advice’ published by CCW and Natural England in 2009. These are noted to comprise a range of bird

species within three ‘supporting habitats’; Intertidal mudflats and sandflats, Saltmarsh and hard

substrate habitats.

The SAC is designated on the basis that it supports occurrences of habitat types and species listed in

Annexes I and II respectively of the Habitats Directive. These include an overarching “estuaries” feature

within which subtidal sandbanks, intertidal mudflats and sandflats, Atlantic salt meadows and reefs and

three species of migratory fish are defined as both features in their own right and as sub-features of

the estuary feature.

The qualifying interest features of the Severn Estuary Ramsar Site overlap with those of the Severn

Estuary SPA and the SAC in order to facilitate the development of integrated objectives across the

designations. Ramsar sites are, as a matter of policy, subject to the same legal protection as European

designated nature conservation sites, but without recourse to the EU courts.

In terms of the development plan policies that relate to these designations it is necessary to refer to

Local Plan Policy GP5 (General Development Principles – Natural Environment), which is cited in

Paragraph 5.9.24 of the ES.

Paragraph 3.23 of the supporting text to this policy states that “Nature conservation sites designated,

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or proposed to be designated, under European or international legislation are subject to the highest

level of protection and therefore require rigorous examination”. It is further stated that “where proposals

have the potential to impact upon a European protected designation, the competent Authority will be

required to undertake a Habitat Regulations Assessment”.

Figure 5 Map showing location of Severn Estuary Special Protection Area and Special Area of Conservation

2.5 Public Rights of Way

There are no public rights of way (PROW) across the site.

Previous PROW across the site have been extinguished and Figure 6 shows the up to date routes of

al PROW within the vicinity of the site.

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Figure 6 Public rights of way near to the site

2.6 Heritage and Archaeological Assets

The only designation applicable to the Site is the Historic Landscape designation of the Gwent Levels

(discussed above).

There are no designated historic assets including Listed Buildings or Scheduled Monuments within or

immediately surrounding the Site. There are no Conservation Areas covering or adjacent to the Site.

2.7 Flood Risk

The Natural Resources Wales (NRW) flood data shows that the site lies predominantly within Flood

Zone 3. Planning Policy Wales limits development within high risk areas to essential transport and

utilities infrastructure, and sets out requirements of such development. Solar farms fall within the

classification of utilities infrastructure.

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Figure 7 NRW Flood Risk Map

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3.0 The Proposed Development

3.1 The Development Composition

It is proposed to submit a full planning application for a Development of National Significance (DNS) in

Wales.

The development will be a Renewable Energy Hub comprising ground mounted solar panels and

battery storage units (160 units) with a combine installed generating capacity of up to 125MW,

underground cabling, grid connection hub, associated infrastructure, landscaping and environmental

enhancements, for a temporary period of 40 years.

The development requires a site of around 155 hectares and is formed from a contiguous block of land

on the Wentlooge levels. Figure 8 shows the location and configuration of the site in relation to the

nearby settlements.

Figure 8 Proposed site layout

The proposal also includes a ground mounted solar farm with arrays set out in rows and mounted on a

Wentlooge Renewable Energy Hub 22

framework system which is either screwed or driven in to the ground.

The proposals will be temporary for a period of 40 years after which the site would be returned to its

current condition.

Sheep would be grazed between the panels. While providing an additional income for the landowners

they also serve to maintain the grassland.

The proposed development includes supporting infrastructure comprising inverter cabins, transformers,

grid connection hub, stock proof fence, CCTV, underground cabling, temporary vehicle tracks, access

and landscaping.

The site has been surveyed in detail to understand the location and species of animals, insects, trees

and plants that currently exist on the site. Existing hedges and trees are to be maintained and habitats

are to be conserved and enhanced through the implementation of biodiverse areas around the field

boundaries. This will serve to enhance the important reen habitats for which the SSSI is designated

and will supported the protected species identified in the completed Ecology surveys.

3.3.1 There would be a stock proof fence around the perimeter of the solar farm development. The fence is

agricultural in nature and can be provided under permitted development up to 2m. The fence would be

used for security purposes and to guard against potential damage by livestock and wildlife; however, it

will be screened by the existing trees and hedges, and by additional planting. The fence will also allow

for the passage of small mammals through and underneath.

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Figure 9 Stock proof fencing

3.2 Materials

The development will comprise the following materials:

Element or Materials Indicative Quantities component of development

Silicon Cells

Aluminium Frame

Solar Panels Plexiglas Approx. 250,00 Panels

12V Wire for electrical connection

Glass sheet

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Commensurate with quantity of installed solar panels. Exact Mounted Frame System Galvanized Steel quantity will depend on installation approach including the angle and spacing of the arrays.

As indicated by cable runs shown Copper or aluminium depending on on submitted plans and additional Cable Connections application and installation cabling required within each field approach parcel.

Approximately 13.3 km of fencing Wooden post and galvanized steel Stock Proof Fencing required around the perimeter of wire each ‘parcel’ of the site.

Track length of approximately 3.75km. Exact quantities of material to be determined by Permeable stone aggregate. Not Stone Access Track contractor and specified within the tarmac or Asphalt. detailed Construction and Environmental Management Plan (CEMP).

Basic components include: an iron Quantities will depend on core plus primary and secondary Transformer and installation approach of the windings (coils of insulated wire Inverter units contractor as specified in the continuously wrapped around the detailed CEMP. core).

Formed from corrugated steel A maximum of 200 units Battery Storage sheets. Mounted on steel legs over proposed. Exact dimensions to be Containers a permeable gravel surface. specified.

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4.0 Key Benefits from the Scheme

4.1 Environmental Benefits

Solar PV panels silently convert sunlight to electrical energy. They generate direct current (DC) that is

converted by the inverter hardware to alternating current (AC) that can be used by the electricity grid.

PV systems are rated for capacity in watts (or kW or MW) with the designation 'peak' (e.g. kWp, MWp).

The peak capacity of individual panels is established by measuring their performance under

internationally recognised standard conditions that include temperature and wavelength of sunlight.

The actual output of a system will be determined by latitude, local weather and site conditions.

The proposals would generate approximately 125 MW of electricity. In accordance with guidance

outlined by the Solar Trade Association2 this would offset around 53,750 tonnes (21.2 kilotons) of CO2

per annum, and 2,150,000 tonnes over the life of the scheme. This equates to enough electricity to

serve the total power needs of around 37,500 average UK households per annum.

To put this in perspective, the new community of (on the former steelworks site) is

planned to contain 4,000 new homes upon the completion of the redevelopment in 2026–28. Based

upon an notional density of 35 dwellings per hectare (which is considered typical for modern housing

developments), this would provide enough electricity for a development of 1,071 hectares. The whole

of the former site (shown below in Figure 10 below) covers an area of 415

hectares, demonstrating the sheer capacity of the proposed scheme to provide a substantial amount

of renewable energy.

2 Solar Trade Association 2016: Resource Centre - http://www.solar-trade.org.uk/solar-farms/

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Figure 10 Area covered by former Llanwern steelworks site

Besides the exportation of electricity to the grid, the proposed would draw a small amount of its power

for the following purposes:

 To power the CCTV security system

 To power the security gates at the grid yard

 To monitor the transformers and inverters for safety purposes

This grid connection is required due to the high cost of on-site power transformation. However, the

draw from the grid is insignificant in comparison with the overall generating capacity of the development

itself.

To provide some understanding of the contribution which the development would have towards meeting

national targets for CO2 reductions, the figures provided by the Greenhouse Gas Inventory for Wales3

provide a useful comparison of overall CO2 emissions.

Despite the comparatively large scale of the proposals, the figures reveal that the CO2 savings resulting

3 National Atmospheric Emissions Inventory (2016) Greenhouse Gas Inventories for England, Scotland, Wales and Northern Ireland: 1990 – 2014. Report to the Department of Energy and Climate Change, The Scottish Government, The Welsh Government and The Northern Ireland Department for Agriculture, Environment and Rural Affairs. Available at: https://uk-air.defra.gov.uk/assets/documents/reports/cat07/1606140853_DA_GHGI_1990-2014_Report_v1.pdf

Wentlooge Renewable Energy Hub 27

from the proposals would represent a reduction of 0.12% of the Wales’ overall greenhouse gas

emissions (calculated as kilotons of CO2 equivalent – ktCO2e) and 0.3% of the country’s energy supply.

Above all, the figures serve to highlight the scale of the challenge faced in meeting the internationally

agreed targets of reducing CO2 emissions by 40% by 2020 (from 1990 levels)4 and the need for

immediate action for decarbonisation of the country’s electricity supply.

The environmental benefits of the scheme far outweigh the impacts resulting from the carbon footprint

of the panels themselves. This is clearly demonstrated through numerous ‘life-cycle assessment’

studies including an academic study from 2008 in which researchers found that it takes 250kWh of

electricity to produce 1m2 of crystalline silicon PV panel5. Under typical UK conditions, 1m2 of PV panel

will produce around 100kWh electricity per year, so it will take around 2.5 years to "pay back" the energy

cost of the panel.

Given the progress and expansion of the solar PV sector in recent years, it is reasonable to assume

that improved efficiencies in production will have further decreased the carbon footprint and the

resulting energy cost of the panels.

It is difficult to obtain life-cycle statistics for the ancillary equipment and development besides the solar

panels and as such it is not possible to form a precise and comprehensive life-cycle assessment for

the overall development. However, it is considered that the abovementioned data relating to PV panels

provides an indication that the benefits of the proposed development would comfortably outweigh the

embodied CO2 emissions resulting from the manufacturing process.

The Centre for Alternative Technology (CAT) provide specific, independent advice on this issue and in

a review of the available evidence available on their website, it is clearly stated that “a PV system

mounted in the UK will, under normal conditions, over its lifetime produce many times more energy

than was required for its production”6.

4 Welsh Assembly Government (2010) Climate Change Strategy for Wales 5 Fthenakis, Kim and Alsema (2008) Environment Science and Technology: Emissions from Photovoltaic Life Cycles 6 Centre for Alternative Technology Article: What is the energy and carbon payback time for PV panels in the UK? Available online: http://info.cat.org.uk/questions/pv/what-energy-and-carbon-payback-time-pv-panels-uk/

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Energy Storage

The proposals include supporting infrastructure and an area to house energy storage devices. Energy

storage is an important “missing piece of the jigsaw” that will enable the maximum use of electricity

from intermittent renewable energy sources. In addition, energy storage provides grid and distribution

network operators with a flexible tool to ensure electricity grids are fit for purpose as generation and

supply continues to decarbonise.

While mature lead-acid batteries are ubiquitous for electricity storage a veritable host of new

technologies are battling it out to be the leaders in the huge business of providing storage for Electric

Vehicles. In California and centres of technology across the world energy storage provided by ‘aqueous

hybrid ion’ is being tested against ‘compressed air storage’ and the ‘Velkess flywheel storage’ (amongst

many) to determine which is best and in particular which will be adopted by the major car companies.

Already the promise is there of cost reductions of 90% or more on current prices within just a year or

two from now.

Massive investments are already being made in production and supply chain facilities. The Tesla

Gigafactory built at a cost of $5bn and opened in 2017 will double global production of Lithium ion

batteries and enable Tesla to build 1.5m cars a year. However there are reportedly eight facilities being

built in China that will come on stream in the next two years that will exceed the production capability

of the Gigafactory.

A side benefit of these ventures that are principally aimed at the automotive industry is that the

Renewables industry will be able to use this progress to overcome intermittency in a cost effective way

and be able to out-compete the fossil fuel generators and the nuclear industry on the service it can

deliver as well as on price.

In the absence of any government subsidy, it is vital that renewable energy projects can be deployed

at a viable scale to attract investment and allow their delivery. Any reduction in the current scale of the

proposal would severely restrict the viability of the scheme.

4.2 Social Benefits

There is potential for engagement with local schools, educational establishments, and community

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groups relating to both biodiversity enhancements and clean energy production & use. There is also

the opportunity to demonstrate the co-production of both energy and food in harmony.

UK Government has tracked public opinion on energy issues in a quarterly ‘public attitudes tracker’

since 2012. This survey is now in its 22nd iteration (‘wave’)7 and the survey findings reveal that support

for renewable energy has remained consistently high during the tracker at around 75-80%. The most

recent survey has shown 77% expressing support for the use of renewables, whilst opposition to

renewables was very low at 4%, with only 1% strongly opposed.

Specific questions relating to Solar were removed following wave 178. However at the time of that

survey (April 2016), support for solar was particularly high, with 95% of respondents expressing their

support for solar energy development.

When respondents were asked if they would be happy to have a large scale renewable energy

development in their area, 75% or respondents agreed that they would be happy.

This evidence demonstrates that there is strong public support for renewable energy and that solar

energy in particular is the most strongly supported.

The proposal will also help to reduce the UKs reliance on imported fossil fuels and help the UK gain

more control over its energy provision and therefore more control over future energy prices and more

energy security going forward. Contributing towards the stable, cost efficient local energy production

will reap benefits for all households in Wales in the short and longer term.

There also various local benefits to the accrued, most notably through the diversification of the land,

which will support the ongoing viability of the landowner’s farming businesses for years to come. This

key point is exemplified by the following quotes from the landowners involved in the scheme.

Landowner Quotes

Mark and Nicola Cutter:

7 Department for Energy for Business, Energy and Industrial Strategy (DBEIS) – Energy and Climate Change Public Attitude Tracker – Wave 22 (August 2017) 8 Department of Energy & Climate Change – DECC Public Attitudes Tracker – Wave 17 (April 2016)

Wentlooge Renewable Energy Hub 30

"I am proud to be part of a plan to help Wales generate its own clean energy. There are not many ways

for us to diversify our farm in this area, but this is a perfect solution. It will also help support the business

going forward whilst enabling us to carry on farming the land."

Andrew and Anne Prosser:

“I run a small livestock farm on the levels. This scheme is a fantastic opportunity for my family and I to

diversify the farm and add a new income stream to help support the family business going forward. As

well as additional income to the business, this scheme actually enables me to carry on farming the land

and be part of a scheme that provides home grown clean energy for Wales, which is a real win win”

Mrs Khehra:

“I am proud to be part of a plan to help Wales generate its own clean energy. There aren’t many ways

for us to diversify our farm in this area, but this is a perfect solution.”

4.3 Economic Benefits

Alongside significant environmental benefits there are important economic benefits, including:

 25 direct construction jobs in the local area

 101 new jobs across Wales over a 14 month period

 4 operational jobs over 40 years

 Economic output of £2,2 million GVA over 14 months

 £170,000 business rates generated per annum (£6.8m total) to Newport City Council

 Significant spin off benefits for the supply chain

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5.0 Planning Policy Assessment

5.1 Introduction

In relation to the proposed development, a range of planning policy documents and guidance must be

considered as key material planning considerations.

National guidance comprises Planning Policy Wales Edition 10 (PPW) (December 2018), as well as a

range of supplementary Technical Advice Notes (TANs) and Practice Guidance. At the local level, the

Newport Local Development Plan 2011 – 2026 and the associated Supplementary Planning Guidance

(SPG) constitute the statutory development plan against which the proposals must accord.

5.2 National Policy

The Environment (Wales) Act 2016 requires Welsh Ministers to reduce emissions in Wales by at least

80% by 2050.

At a UK level, DECC published the UK Renewable Energy Roadmap (2011), which set out a

comprehensive suite of targeted, practical actions to accelerate renewable energy in the UK. The

publication of this document was followed by a surge in the growth and success of the Solar PV

industry, which was acknowledged within the updated Energy Roadmap in 2013.

This success prompted DECC to form a Solar PV Strategy Group and prepare a specific Solar PV

Strategy Roadmap. The Roadmap has been published in two parts, the first in October 2013 and the

second in April 2014. Part One established the general principles and vision for the solar industry, whilst

Part Two set out the particular ambitions for deployment in relation to each market area, including large-

scale ground mounted schemes.

The Solar PV Strategy Group is comprised of 5 ‘Task forces’, which deal with the specific issues facing

the industry in relation to; Land Use, Engagement, Grid, Innovation and Finance. These issues reflect

the various constraints related to the deployment of Solar PV and Part 2 of the Roadmap reflects the

on-going work of these five Task Forces.

The Land Use Task Force is chaired by the NFU who have worked with the Solar Trade Association

(STA) to develop “10 Commitments” of good practice in solar farm development. These are recognised

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as a set of industry best practice guidelines to ensure the quality of solar farms built and managed in

the UK. These state that developers should seek to fulfil the following duties:

 Focus on non-agricultural land or land which is of lower agricultural quality.

 Be sensitive to nationally and locally protected landscapes and nature conservation areas,

and we welcome opportunities to enhance the ecological value of the land.

 Minimise visual impact where possible and maintain appropriate screening throughout the

lifetime of the project managed through a Land Management and/or Ecology plan.

 Engage with the community in advance of submitting a planning application, including seeking

the support of the local community and listening to their views and suggestions.

 Encourage land diversification by proposing continued agricultural use or incorporating

biodiversity measures within our projects.

 Do as much buying and employing locally as possible.

 Act considerately during construction, and demonstrate ‘solar stewardship’ of the land for the

lifetime of the project.

 Offer investment opportunities to communities in their local solar farms where there is local

appetite and where it is commercially viable.

 Commit to using the solar farm as an educational opportunity, where appropriate.

 At the end of the project life, return the land to its former use.

The supporting notes to these guidelines explains that ground-mounted solar schemes should:

“Ideally utilise previously developed land, brownfield, contaminated land, industrial land and preferably

agricultural land of classification 3a, 3b, 4, and 5 (in most instances avoiding use of the ‘Best and Most

Versatile’ cropland where possible). Land selected should aim to avoid affecting the visual amenity of

landscapes, maintaining their natural beauty, and should be predominantly flat, well screened by

hedges, tree lines, etc., and not unduly impact upon nearby domestic properties or roads.”

5.3 Energy Wales: A Low Carbon Transition (2012)

This document sets out the principles of delivering energy policies in Wales, with the expressed aim to

‘create a sustainable, low carbon economy for Wales’.

Wentlooge Renewable Energy Hub 33

In outlining the aims for delivering renewable energy, the document states that it wants to be;

“Making the best use of commercially proven renewable energy sources – such as onshore and

offshore wind, solar, bio-energy and hydro – we want to facilitate appropriate deployment to deliver

against our low carbon objectives, contribute to wider UK and EU aims and realise the significant

wealth-generating opportunities Wales has.

We want to ensure that following best practice engagement of our communities, the appropriate

technology is deployed at the appropriate sites in a way that delivers for business, benefits communities

and supports the long term prosperity of Wales. In so doing we expect to achieve an energy mix across

energy sectors and different scales – with greater contributions from micro and community scale

developments alongside developments at a larger scale.”

5.4 Well-being of Future Generations Act

The Wellbeing of Future Generations Act (Wales) Act 2015 sets out a ‘sustainable development

principle’ requiring planning decisions to comply with the 7 well-being goals set out in Table 1 on Page

4 of the Act. These are:

1) A prosperous Wales

2) A resilient Wales

3) A healthier Wales

4) A more equal Wales

5) A Wales of cohesive communities

6) A Wales of vibrant culture and thriving Welsh Language

7) A globally responsible Wales

The ‘Sustainable Development Principle’ as discussed in Paragraph 5 (1) of the Act sets out that public

bodies “must act in a manner which seeks ensure that the needs of the present are met without

compromising the ability of future generations to meet their own needs.”

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Paragraph 5(2) explains that “in order to act in that manner, a public body must take account of... “the

importance of balancing short term needs with the need to safeguard the ability to meet long term

needs, especially where things done to meet short term needs may have detrimental long term effect”.

5.5 Planning Policy Wales (Edition 10, 2018)

Planning Policy Wales (Edition 10, December 2018), sets out the national tier of land use planning

policies for Wales and is supplemented by a series of Technical Advice Notes (TANs). The document

makes numerous references to promoting sustainable development and the need to tackle climate

change.

The document references the seven goals of the well-being and future generations act and in particular,

notes that

“Above all, a Globally Responsible Wales is promoted by reducing our carbon footprint through

integrated public transportation infrastructure, encouraging globally responsible business and the

promotion of renewable energy over carbon-emitting sources and resource choices through which

multiple benefits can be realised.”

In order to achieve a Resilient Wales it is noted that Wales’ topography “lends itself to renewable energy

generation.”

Support for Renewable Energy

Paragraph 5.7.8 is of particular relevance to these proposals and explains that “the benefits of

renewable and low carbon energy, as part of the overall commitment to tackle climate change and

increase energy security, is of paramount importance. The continued extraction of fossil fuels will hinder

progress towards achieving overall commitments to tackling climate change.”

Paragraph 5.9.1 demonstrates PPW’s support for renewable energy, stating that: “Planning authorities

should facilitate all forms of renewable and low carbon energy development. In doing so, planning

authorities should seek to ensure their area’s full potential for renewable and low carbon energy

generation is maximised and renewable energy targets are achieved”.

PPW (Edition 10, 2018) is less prescriptive than previous iterations of the document and does not

Wentlooge Renewable Energy Hub 35

require a sequential site selection approach prioritising brownfield sites. Indeed, Paragraph 5.9.9 states

that “Outside identified areas (such as those identified through TAN8), planning applications for

renewable and low carbon energy developments should be determined based on the merits of the

individual proposal.”

Furthermore, Paragraph 5.9.19 states that “Prior to an application being submitted, developers for

renewable and low carbon energy developments should, wherever possible, consider how to avoid, or

otherwise minimise, adverse impacts through careful consideration of location, scale, design and other

measures.”

Paragraph 5.9.17 sets out the way in which LPA’s should approach proposals for renewable energy

proposals on constrained sites. Here it is explained that:

“Planning authorities should give significant weight to the Welsh Government’s targets to increase

renewable and low carbon energy generation, as part of our overall approach to tackling climate change

and increasing energy security. In circumstances where protected landscape, biodiversity and historical

designations and buildings are considered in the decision making process, only the direct irreversible

impacts on statutorily protected sites and buildings and their settings (where appropriate) should be

considered. In all cases, considerable weight should be attached to the need to produce more energy

from renewable and low carbon sources, in order for Wales to meet its carbon and renewable targets.”

Paragraph 5.6.11 relates to Rural Business Diversification and states that “Diversification can also

include renewable energy proposals such as anaerobic digestion facilities or solar and wind

installations, which will help to increase the viability of rural enterprises by reducing their operating

costs. These schemes should be supported where there is no detrimental impact on the environment

and local amenity”.

Paragraph 3.67 explains that “Green wedges are local designations which essentially have the same

purpose as Green Belts. They may be used to provide a buffer between the settlement edge and

statutory designations and safeguard important views into and out of the area.”

Paragraph 3.73 specifies types of development which may be appropriate within the green wedge,

stating that:

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“Certain other forms of development may be appropriate in the Green Belt or green wedge provided

they preserve its openness and do not conflict with the purposes of including land within it”. These

include [inter-alia]:

 renewable and low carbon energy generation;

Paragraph 5.7.11 states that “Planning authorities should plan positively for grid infrastructure.

Development plans should facilitate the grid infrastructure required to support the renewable and low

carbon energy potential for the area, particularly areas identified for such development. Planning

authorities should support appropriate grid developments, whether or not the developments to be

connected are located within their authority.”

Paragraph 5.7.15 of PPW states that “The local balance of the energy network will be a crucial

consideration in this regard, and planning authorities should consider the best places for local

renewable energy generation to help improve the resilience of the grid in the future.”

5.6 Technical Advice Notes

The Planning Policies set out within Planning Policy Wales (Edition 10, 2018) are supplemented by a

series of topic based Technical Advice Notes (TANs), which provide detailed planning advice on

specific matters.

TAN 5 Nature Conservation and Planning, sets out the key principles of planning for nature

conservation in relation to development proposals.

Under Paragraph 5.1.6 of this note it is explained that:

“Local planning authorities, along with other public bodies, have a duty to take reasonable steps,

consistent with the proper exercise of their functions, to further the conservation and enhancement of

the features by reason of which SSSIs are of special scientific interest” [own emphasis]

TAN 6 Planning for Sustainable Rural Communities, provides practical guidance on the role of the

planning system in supporting the delivery of sustainable rural communities.

The introduction to the note explains that “Simultaneously, the planning system must respond to the

Wentlooge Renewable Energy Hub 37

challenges posed by climate change, for example by accommodating the need for renewable energy

generation.”

Paragraph 3.7.2 states that many economic activities can be sustainably located on farms and that the

production of non-food crops and renewable energy, are likely to be appropriate uses.

TAN 8 Renewable Energy, provides guidance on land use planning in relation to onshore renewable

energy technologies and how renewable energy should be accounted for as part of development plans,

development management and monitoring processes.

Under Paragraph 1.4 the advice note reiterates the Welsh Government’s target to generate seven

Terawatt hours (TWh) of electricity by 2020. Statistics published by DECC9 reveal that in 2015 Wales

generated just 5.1 TWh, leaving a significant shortfall to be made up in order to achieve the

Government’s target.

TAN 8 does not make specific reference to the deployment of ground-mounted solar PV and instead

focuses on roof-top installations. In this respect the advice note is somewhat out of date and does not

provide a useful source of planning policy guidance in relation to these proposals.

5.7 Emerging National Planning Policy

The Government has recently concluded a public consultation on a draft version of the emerging NDF

and this includes a number of draft policies on how renewable energy schemes should be considered.

The key points from the strategy and its draft policies are summarised below:

With regards to Renewable Energy, the NDF states that:

“Wales is abundant in opportunities to generate renewable energy and the Welsh Government is

committed to maximising this potential. Generating renewable energy is a key part of our commitment

to decarbonisation and tackling the causes of climate change. We have set the following ambitious

targets for the generation of renewable energy:

• For 70 per cent of electricity consumption to be generated from renewable energy by

9 DECC (2016) Energy Trends March 2016

Wentlooge Renewable Energy Hub 38

2030.

• For one gigawatt of renewable energy capacity to be locally owned by 2030.

• For new renewable energy projects to have at least an element of local ownership by

2020.”

The NDF does not provide any further information as to what would constitute local ownership.

Draft Policy 10 – expresses support for large scale on-shore wind and solar renewable energy

developments that are located inside ‘Priority Areas for Solar and Wind Energy’. These areas have

been identified based upon a review of landscape and visual sensitivity. However even within such

areas the draft policy requires that proposals demonstrate their suitability in terms of landscape

impacts, ecology and other environmental impacts.

Policy 11 – In areas outside of the 15 ‘Priority Areas for Solar and Wind Energy’ the principle of

development is not established, nor is the acceptance that the landscape is capable of accommodating

a certain level of change. The consequence of this is that it could be more difficult to achieve planning

permission for renewable energy developments outside of these areas.

Figure 11 shows an extract of the Priority Areas from the draft NDF and shows that the proposed site

does not lie within either the priority area for wind or for solar development.

Wentlooge Renewable Energy Hub 39

Figure 11 Priority Areas proposed under draft NDF

5.8 Practice Guidance: Planning for Renewable and Low Carbon Energy - A Toolkit for Planners

The Welsh Government has commissioned the preparation of a Planning guidance document

(‘Toolkit’), in order to support local authorities in planning for the development required to meet stringent

energy and emissions targets. The document sets out “how a local authority can prepare a robust

evidence base to underpin a number of LDP spatial policies that can support and facilitate the

deployment of renewable and low carbon energy systems”.

The outcome of this toolkit is an evidence base, comprising an assessment of the potential for

renewable and low carbon energy generation, at different scales, and at different levels of detail.

The Guidance explains that “Local Authorities have several key roles to play that can facilitate the use

and generation of renewable and low carbon energy”. The Development Management process is

identified as fulfilling one of these roles via the following means:

“Taking decisions on planning applications submitted to the local planning authority for development;

as well as preparing Local Impact Assessments for schemes which are determined by the Planning

Wentlooge Renewable Energy Hub 40

Inspectorate”

Despite outlining this role, the toolkit is primarily focused on planning policy and not Development

Management. In this respect, it is explained that the document is not intended for use in assessing

development proposals, but should instead be used to guide LPAs on how to prepare an evidence base

to support renewable and low carbon energy policies and site allocations in their LDPs.

To this end, the Toolkit provides a methodology for LPAs to follow in order to identify and allocate areas

for potential PV Farm projects. It is intended that this methodology will enable a high level assessment

of the potential solar resource from ground-mounted PV considering the likely constraints presented by

a range of land-based designations. This is a process known as constraints mapping.

As a relatively new phenomena, the Toolkit notes that there is currently no standard agreed method to

constraints mapping for Solar PV Farms. Consequently, the Toolkit presents only one ‘potential

approach’ which is not enshrined by any means within planning policy, nor binding to the Local

Authorities using the guidance.

Moreover, the toolkit is intended only to enable a visual overview of potential sites locations which are

in general terms less ‘constrained’ than other locations in the plan area. It acknowledges that the

process of constraints mapping will not automatically identify sites which are suitable for the deployment

of PV and that consideration of a wider range of factors will be required in order to determine such

suitability. Indeed, the guidance explains that:

. . “detailed assessment of a particular site may reveal proposed PV farm impacts to be manageable

and to meet regulatory and policy requirements.”

“Conversely, land indicated as suitable through GIS mapping may prove to be technically and/or

financially unviable”

This is due to the specific challenges of solar PV farm development and the range of additional

considerations which are not factored within the toolkit’s proposed methodology for a high level

assessment. The guidance notes that such considerations include the requirement for an economically

viable (relatively short distance from the solar array to an appropriate connection point) grid connection,

practical access to sites required for development, landowner willingness for development to proceed,

Wentlooge Renewable Energy Hub 41

and the likely impact on landscape character.

5.9 Newport Local Development Plan 2011 - 2026

Provisions made through Section 38(6) of the Planning and Compulsory Purchase Act 2004 indicate

that for any application for planning permission made to the local authority, the determination must be

made in accordance with the development plan unless material considerations indicate otherwise.

Despite the application being made as a Development of National Significance (DNS), this legislation

establishes the primacy of the development plan in the determination of the planning application.

For the purposes of this application, the pertinent development plan is the Newport Local Development

Plan 2011 – 2026 which was formally adopted in January 2015.

It is explained within the Foreword to the LDP that “Sustainability is at the heart of the Plan” and that

“Newport City Council is very keen to support development”. In this respect, the plan presents itself as

a ‘sustainable development strategy’ which has been prepared in the “context of the growing awareness

of the need to produce and use energy in more sustainable ways”.

In setting out is strategic vision the plan outlines 10 specific objectives which seek to address the key

issues facing Newport and the wider agenda for Wales.

Objective 1 refers to the Sustainable Use of Land and aims “to ensure that all development makes the

most efficient use of natural resources by seeking to locate development in the most sustainable

locations, minimise the impact on the environment and make a positive contribution to local

communities”.

Objective 2 outlines the plan’s objective to tackling Climate Change. It states:

“To ensure that development and land uses in Newport make a positive contribution to minimising,

adapting to or mitigating against the causes and impacts of climate change by incorporating the

principles of sustainable design, changes to travel behaviour, managing the risks and consequences

of flooding, and improving efficiency in the use of energy, waste and water.”

Objective 6 relates to the Conservation of the Natural Environment. The objective aims “To protect and

enhance the quality of the natural environment, including… protected habitats and species of principal

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importance for biodiversity in Wales (regardless of greenfield or brownfield status) and the protection

of controlled waters”.

Policy SP1 – Sustainability states that ‘Proposals will be required to make a positive contribution to

sustainable development… reducing energy consumption, increasing energy efficiency and the use of

low and zero carbon energy sources’.

Policy SP5 relates to development in the countryside and explains that such development “will only be

permitted where the use is appropriate in the countryside, respects the landscape character and

biodiversity of the immediate and surrounding area and is appropriate in scale and design… rural

diversification and rural enterprise uses, beyond settlement boundaries, will only be appropriate where

they comply with national planning policy.

Policy CE10 [Renewable Energy] states that renewable energy schemes will be “considered

favourably, subject to there being no over-riding environmental and amenity considerations.” It further

states that “large scale proposals may be more appropriately located outside of the defined settlement

boundary if no appropriate brownfield sites exist” and that the “cumulative impacts of renewable energy

schemes will be an important consideration”.

Paragraph 4.51 of the supporting text to the policy explains that particular care should be taken when

assessing proposals for renewable energy projects in sensitive, designated areas, such as areas of

high landscape quality, and areas of nature conservation, or archaeological or historical importance. It

continues to state that:

“The Gwent Levels are recognised as an internationally important resource in terms of landscape and

heritage and nationally important for ecology. Proposals which affect the special qualities of the Gwent

Levels, or any other protected site, will be resisted unless it can be demonstrated that there will be no

significant adverse effects.”

As a starting point Paragraph 4.55 explains that:

“Brownfield sites within the settlement boundary will be favourably considered and where possible,

should be considered before greenfield options“. However, it continues to state that:

Wentlooge Renewable Energy Hub 43

“Development of larger scale renewable energy schemes may be acceptable on greenfield sites where

it can be demonstrated that there will be no significant adverse impacts on the environment and local

communities.“

In accordance with the planning guidance set out within the ‘Toolkit’ the Council has undertaken a

Renewable Energy Assessment, which sets out the potential for renewable energy resources and

technologies within the plan area. The Development Plan states that this assessment should be

considered when evaluating renewable energy proposals.

The application site lies within the Gwent Levels, which is one of four Archaeologically Sensitive Areas

designated under the local development plan. As such the following extract of Policy CE6 Archaeology

is relevant to the proposals:

“Development proposals will normally be required to undertake an archaeological impact assessment

before the proposal is determined:

Where groundworks and/or the installation of services are proposed within the Archaeologically

Sensitive Areas of , the Levels, Lower and the City Centre”

Adopted Supplementary Planning Guidance to this policy explains that this designation highlights the

archaeological potential of these areas and the need to seek professional archaeological advice to

ascertain the true significance of a site. It further states that:

“The designation of an ASA is not intended to introduce new policies or restrictions to development but

to indicate to developers, areas where it is likely that the effect of the development on the archaeological

resource may become an issue during the determination of a planning application.”

The site lies within the Caldicot Levels Special Landscape Area as designated on the basis of the

LANDMAP assessment process. Special Landscape Areas (SLAs) are a non-statutory local landscape

designation used by Local Planning Authorities to define areas of landscape importance.

Policy SP8 explains that proposals in these areas “will be required to contribute positively to the area

through high quality design, materials and management schemes that demonstrate a clear appreciation

of the area’s special features”.

Wentlooge Renewable Energy Hub 44

NCC have prepared a ‘Topic Paper’ which provides a background to the policies contained within the

Local Development Plan on the subject of Special Landscape Areas (SLAs) within the plan area.

The paper outlines the primary landscape qualities and features for the Wentlooge Levels Area as

follows:

“Part of an extensive tract of low lying, reclaimed marsh and wetlands that extends from Cardiff to

Chepstow. Rarely rising above 10 metres AOD they form a large, open expanse of primarily pastoral

agricultural land. Having been subject to reclamation work since Roman times, a key landscape feature

is the distinctive pattern of drainage ditches or “reens”. Their pattern reflects the differing periods of

reclamation. Thus the fields on the western side of the area are more rectangular in pattern, and

enclosed by cut hedges or lined with willows. To the east the pattern in more sinuous and less defined

by vegetation.”

The site also lies within the Gwent Levels area of the ‘Undeveloped Coastal Area’. As such it subject

to the requirements of Policy CE9 Coastal Zone, which states that:

“Development will not be permitted in the coastal area or adjoining the tidal river unless:

In the undeveloped coastal area such development is required to be on the coast to meet an exceptional

need which cannot reasonably be accommodated elsewhere;

the area is not itself at risk nor will the proposed development exacerbate risks from erosion, flooding

or land instability”

In the supporting text to this policy, Paragraph 4.45 explains that the undeveloped coastal area will:

“Rarely be appropriate for major development. Proposals for such development will need to

demonstrate that such a location is essential and that the proposal is acceptable having regard to other

Policies of this Plan. Sufficient information will be required to demonstrate that the proposed

development can be carried out without significant adverse effects.”

In specific reference to the Gwent Levels and the Severn Estuary, the supporting text describes how

numerous statutory and non-statutory designations afford the area a variety of protections against

Wentlooge Renewable Energy Hub 45

inappropriate development.

The site is located within an area recognised for its importance to local wildlife and spans two Sites of

Special Scientific Interest (SSSI). As such Local Plan Policy GP5 General Development Principles –

Natural Environment is of relevance to the proposals. This states that:

“Development will be permitted where, as applicable:

the proposals are designed and managed to protect and encourage biodiversity and ecological

connectivity, including through the incorporation of new features on or off site to further the UK,

Welsh and/or Newport biodiversity action plans;

the proposals demonstrate how they avoid, or mitigate and compensate negative impacts to

biodiversity, ensuring that there are no significant adverse effects on areas of nature conservation

interest including international, European, National, Welsh section 42 and local protected habitats

and species, and protecting features of importance for ecology;

the proposal will not result in an unacceptable impact on water quality; the proposal should not

result in the loss or reduction in quality of high quality agricultural land (grades 1, 2 and 3a);

there would be no unacceptable impact on landscape quality;

the proposal includes an appropriate landscape scheme, which enhances the site and the wider

context including green infrastructure and biodiversity networks.”

Policy SP7 relates to the designation of Green Wedge areas which are ‘identified in order to prevent

the coalescence of settlements’. The site lies within the Green Wedge between Cardiff and Newport.

Within these areas, the policy states that:

“Development which prejudices the open nature of the land will not be permitted. an increase in size of

a dwelling of more than 30% of the volume of the original size of the dwelling, or as existed in 1948,

will not be approved.”

At paragraph 2.27, the supporting text to the Policy explains that “the prime purpose of Green Wedges

is to prevent coalescence between urban areas. The designation is not made necessarily on the basis

Wentlooge Renewable Energy Hub 46

of the physical quality of the landscape, but rather to maintain their openness. The areas designated

tend to have significant importance for their openness and for their role in maintaining the distinct

identify of separate communities.”

Newport Local Development Plan – Proposals and Constraints Maps

Figure 12 and Figure 13 respectively show the Proposals and Constraints maps in relation to the Local

Development Plan. The maps show the relevant Local Planning Policy and Statutory designations

which apply to the site and the wider geographic area.

Figure 13 shows the line of the previously planned M4 CAN project which was rejected by Welsh

Government in 2019.

Figure 12 NCC Proposals Map showing site area

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Figure 13 NCC Local Plan Constraints Map

5.10 Renewable and Low Carbon Energy Assessment: Torfaen County Borough Council and

Newport City Council

A joint study into the potential for the deployment of low carbon energy in Newport and Torfaen was

completed in 2013 by consultants Verco Global. The study provides an evidence base for the two local

authorities and help to facilitate renewable energy generation the pertinent local planning policies

(Policy CE10 in Newport).

The study aims to develop an understanding of local renewable resources, constraints and

opportunities, and to identify opportunities to include renewable energy schemes, district heating and

combined heat and power into development proposals. However, it is explained within the document

that:

“The spatial elements of this study are not intended for use by development management officers to

assess individual planning applications for either strategic new development sites that are incorporating

renewable energy, or for stand-alone renewable energy generating systems. Further detailed survey

Wentlooge Renewable Energy Hub 48

work would need to be undertaken to assess development potential and viability.”

The methodology for the study accords with the guidance set out within the Welsh Government’s

Planning for Renewable and Low Carbon Energy – A Toolkit for Planners (July 2010) which has been

described within Paragraph 5.8 of this document.

5.11 Capacity

The abovementioned study identifies the existing and proposed capacity of renewable energy and fossil

fuel generation within the NCC plan area at the time in which the study was undertaken (2013). At the

time of writing, the existing renewable energy capacity totalled 14.6MW with a further 42.8MW

proposed through the planning system. This comprised an estimated installed capacity of 5.5MW by

Solar PV (including an estimated 3MW of domestic rooftop solar) and a further proposal for a 2MW

solar farm at Clearwell Farm.

Since the time of this study a DNS application for a solar farm with a generating capacity of 49.9MW

was approved in the plan area on land to the south of the Llanwern Steelworks. Furthermore, a 3.9MW

was approved in the plan area, on land to the west of Park Farm, Malthouse Lane, Caerleon (ref

15/0902) and another application for a 5.3 MW solar farm was withdrawn on the 13th October 2013 (ref

14/0531). There is also likely to have been a further increase in capacity from rooftop solar, although

the level of this increase is difficult to estimate.

The study also identifies the presence of two large fossil fuel generating plants within the plan area; the

Uskmouth Power Station, a 360MW coal-fired power station and Severn Power, a 850MW gas-fired

power station. Therefore, despite these increases in renewable energy capacity, the study has shown

that the area’s generating capacity from renewable sources continues to fall far short of the its non-

renewable capacity.

5.12 Targets

Projections made within the abovementioned study indicate that by the end of the plan period (2026)

electricity demand within the NCC plan area will be 863 GWh/yr.

In terms of supply, the study identifies the ‘renewable energy potential’ for each renewable technology,

based upon the analysis completed to appraise the associated constraints an opportunities for their

Wentlooge Renewable Energy Hub 49

deployment. For ground-mounted solar PV the total ‘Potential accessible resource’ is estimated at 17

GWh whilst the combined total potential all renewable technologies is projected at 338 GWh.

In accordance with guidance set out in the Planning for Renewable and Low Carbon Energy Toolkit the

study outlines ‘High’ and ‘Low’ target scenarios for how much of this potential might actually be realised

within the period to 2026. Assuming a ‘High’ (75%) take up of this theoretical potential, the total possible

supply from renewable sources would be 237 GWh. This would provide 27% of the projected demand

by 2026. A ‘Low’ (50%) take up would provide 152 GWh, meeting just 18% of the projected demand.

5.13 Identified Opportunities

The study continues to form an assessment of the potential for ground mounted PV, based upon a GIS

analysis of the following land based constraints:

 Grade 4 and 5 Agricultural land only

 Areas of Outstanding Natural Beauty

Nature conservation designations:

 Sites of Special Scientific Interest (SSSIs), Special Protection Areas (SPAs), Special Areas of

Conservation (SACs), Ramsar Sites, National Nature Reserves (NNRs), Local Nature

Reserves (LNRs)

Sites of Historic Interest:

 World Heritage Sites, Scheduled Ancient Monuments, Registered Parks and Gardens

 Common Land

 5m Buffer Zones around rights of way

Figure 14 Ground-mounted solar PV constraints and technical potential - Verco Renewable and Low

Carbon Energy Assessmentshows the mapped outcome of this analysis for the Newport area and has

been annotated to show the approximate location of the application site. The areas shown in yellow are

those which are considered to possess technical potential for ground-mounted PV based upon the GIS

analysis of the abovementioned ‘constraints’.

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Figure 14 Ground-mounted solar PV constraints and technical potential - Verco Renewable and Low Carbon Energy Assessment

It is important to note that the mapped constraints present only a basic and high-level representation

of the areas which are least constrained by the above designations. Indeed, the study itself

acknowledges that only a small proportion of the total available land would actually be suitable.

Therefore, it assumes that only 1% of the unconstrained land could be used for the deployment of solar

PV. It is then explained that although this is a somewhat arbitrary figure, it is deemed to reflect the

various other constraints, which will further influence the potential of the land. These include the fact

that solar farms will have to compete with other land uses, need an economic grid connection and will

require unshaded flat land or land inclined to the south

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6.0 Assessment of proposals against planning policy

6.1 Principle of Development

At a National level PPW seeks to support the principle of renewable energy, stating that “the benefits

of renewable and low carbon energy, as part of the overall commitment to tackle climate change and

increase energy security, is of paramount importance”. This commitment is reiterated in the emerging

NDF which states that Welsh Government is committed to “maximising the potential use of renewable

energy”.

Local Planning Authorities (LPAs) are not required to allocate land for renewable energy development

and instead, proposals for these developments must be tested against the pertinent planning policies

relating to the site.

In this instance, the proposal is for a large-scale renewable energy development within the open

countryside, on land between Newport and Cardiff. Local Plan Policy CE10 [Renewable Energy] is of

most relevance to the principle of development and states that renewable energy schemes will be

“considered favourably, subject to there being no over-riding environmental and amenity

considerations.” The policy also acknowledges that “large scale proposals may be more appropriately

located outside of the defined settlement boundary if no appropriate brownfield sites exist”

This DNS application is accompanied by a full Environmental Impact Assessment which demonstrates

that there would be no overriding impacts resulting from the scheme. Indeed, the impacts which are

identified would be suitably mitigated through on and off-site ecological mitigation measures, a careful

approach to construction and the temporary, reversible nature of the proposals.

The application is also accompanied by a site selection sequential test, which demonstrates the need

for the development to be sited in this location and not within a brownfield context.

Therefore, the planning submission demonstrates that the requirements of Policy CE10 would be

satisfied and that the principle of development is supported by the Development Plan.

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6.2 Site Designations

The site is also subject to the following designations, for which the associated planning policies must

also be considered:

Site Designation Assessment against related Planning Policy

Local Plan Policy SP5 relates to development in the countryside and explains that such development “will only be permitted where the use is appropriate in the countryside, respects the landscape character and biodiversity of the immediate and surrounding area and is appropriate in scale and design… rural diversification and rural enterprise uses, beyond settlement boundaries, will only be appropriate where they comply with national planning policy.

In the case of this DNS application the proposed use is appropriate in rural, countryside locations as recognised by Local Plan Policy CE10 and Open Countryside demonstrated through the site selection sequential test. The proposed solar farm would respect the landscape character and biodiversity as evidenced by the ES which accompanies the submission. The proposed development also represents a rural diversification which is clearly supported by National Policy through TAN 6 which states that “many economic activities can be sustainably located on farms and that the production of non-food crops and renewable energy, are likely to be appropriate uses”.

In light of the above, the open countryside location is considered to be a suitable, policy-compliant location for the development.

Local Plan Policy SP7 relates to the designation of Green Wedge areas which are ‘identified in order to prevent the coalescence of settlements. This policy aligns with Paragraph 3.73 of PPW, which clearly recognises that ‘renewable and low carbon energy generation’ may be appropriate Cardiff – Newport within the green wedge, providing that it would “preserve its openness and Green Wedge not conflict with the purposes of including land within it”.

The proposed development would be largely set back from the adjacent highway, would be screened by the railway to the north and would sit within existing field boundaries, which would be strengthened and

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reinforced where appropriate in order to provide additional screening. Responding to the concerns of key consultees, the removal of the wind turbines has further reduced the visual impacts of the solar panels would sit discretely within flat landscape of the area. As such, the proposed scheme would preserve the open character of the landscape.

Due to the inert static nature of the development, generating negligible traffic movements once operational, the development would also maintain the functional characteristics of the area, ensuring that the use profile of the land would be unchanged and that both Cardiff and Newport would remain as distinct urban locations.

Furthermore, the submitted LVIA has not concluded that the scheme would cause significant residual effects, demonstrating that the proposed development is compliant with the key planning tests relating to the Green Wedge designation.

Local Plan Policy GP5 General Development Principles – Natural Environment is of relevance to the proposals in this regard. This states that development will be permitted where the proposals demonstrate how they “avoid, or mitigate and compensate negative impacts to biodiversity, ensuring that there are no significant adverse effects on areas of nature conservation interest including international, European, National, Welsh

St Brides SSSI section 42 and local protected habitats and species, and protecting features of importance for ecology”.

Through the submitted ES it is demonstrated that this key test has been satisfied and that the proposals would not cause significant adverse effects to the SSSI. In fact the proposals would deliver important environmental benefits which would support the special features of the SSSI, supporting the conservation interests described by the policy.

This designation is set out through local plan Policy CE9 Coastal Zone, Undeveloped Coastal which stipulates that development will not be permitted in the UCZ unless Zone (UCZ) such development is required to “meet an exceptional need which cannot reasonably be accommodated elsewhere” and providing that “the area is not itself at risk nor will the proposed development exacerbate risks from

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erosion, flooding or land instability”

Proposals for major development in the UCZ are required to demonstrate that such a location is essential and that the proposal is acceptable having regard to other Policies of the Plan. Sufficient information is also required to demonstrate that the proposed development can be carried out without significant adverse effects.

The submitted Site Selection Sequential Test demonstrates the exceptional need for the site’s location inside the UCZ, which is driven principally by the availability of a local grid connection, the availability of sufficient land to accommodate the scale of development and other physical factors such topography and irradiation values. The submitted ES demonstrates that the development can be carried out without causing significant adverse environmental effects.

In combination, the submitted DNS application provides the required evidence to demonstrate that the planned scheme is compatible with the objectives and requirements of Policy CE9.

As such the following extract of local plan Policy CE6 Archaeology is relevant to this designation and requires that development proposals in ASA’s “will normally be required to undertake an archaeological impact assessment before the proposal is determined”. Adopted Supplementary Planning Guidance to the policy clarifies that its purpose is to ascertain the true significance of a site and “to indicate to developers, areas where it is Archaeologically likely that the effect of the development on the archaeological resource may Sensitive Area (ASA) become an issue during the determination of a planning application.”

As required by the policy, a full Archaeological Impact Assessment (AIA) has been carried out and is submitted as part of the Environmental Statement. Through this application it is concluded that impacts to below ground archaeology can be suitably mitigated through a robust Written Scheme of Investigation.

The site is located within Flood Zone C1 and Technical Advice Note 15 Flood Zone (TAN 15) provides the relevant guidance on flood risk in relation to these proposals. Its designation in Flood Zone C1 means that it sits within an

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area of the floodplain which is developed and served by significant infrastructure, including flood defences. The designation is used to indicate that development can take place subject to it passing the justification test, including acceptability of consequences.

The first step in considering whether the proposed development would comply with TAN 15 is to clarify which category it falls within. Especially vulnerable industrial development, including power stations, is categorised as Highly Vulnerable. TAN 15 was, however, written in July 2004 predating large-scale solar farm development. The reference to ‘power stations’ was not, therefore, intended to cover this type of renewable energy installation.

TAN 15 explains that ‘Highly vulnerable’ describes development whose occupants have a limited ability to decide whether they wish to accept the risks of flooding, or to manage the consequences of such a risk. It also includes industrial uses where there would be a risk to the public and the water environment should the site be inundated.

The proposed development would be unmanned with no occupants. The panels are inert and would not be a safety risk if the site did flood. The development could be easily disconnected from the grid and would not involve the use of toxic or hazardous substances. In addition, solar farms have a proven record of safe operation in flood zone locations and are compatible with them. Given its characteristics, it is thus appropriate to classify the proposed development as a ‘Less Vulnerable’ or ‘Other’ form of development. This would be consistent with the ‘Less Vulnerable’ classification of development such as general industrial and utilities infrastructure.

‘Less Vulnerable’ or ‘Other’ forms of development should only be permitted within zones C1 and C2 if they are justified in these areas. The submitted ‘Site Selection Sequential Test’ document provides a thorough explanation as to why the proposed development must be sited in this location. If the proposed development is justified in its location a Flood Consequences Assessment (FCA) must be undertaken to establish whether mitigation measures can be incorporated to ensure that the proposed development is sufficiently safe.

The submitted FCA has utilized the most up-to-date climate data and an

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appropriate methodology agreed with Natural Resources Wales (NRW). It has found that there is unlikely to be flooding in the site area under current or future projections of climatic conditions. The hydrology and runoff from the proposed development will not fall outside of the range expected from its current agricultural use.

The above understanding is endorsed by the Planning Inspector’s report in relation to DNS application 3150137 where an application for a solar farm development on the Gwent Levels near Llanwern (also in Flood Zone C1) was recommended for approval and subsequently granted consent by the Welsh Government in November 2018.

Furthermore, the FCA has found that if the existing, robust flood defences were to be breached sufficient warning could be given to any visitors of the development (for maintenance etc.) to avert potential danger. The document also details the specific mitigation measures which would be incorporated in association with the built infrastructure including solar panels, battery storage units and ancillary equipment. Through the report the following conclusions have been drawn:

 Soil compaction will be reduced resulting in an overall improvement in the soil condition and more natural management of surface water

 More uniform management of surface water

 The fields will be better able to naturally manage rainfall

Noting the beneficial impacts of the scheme and the outcome of the site- selection sequential test, it is evident that the proposed development is compatible with the site location in Flood Zone C1.

Special Landscape Areas (SLAs) are a non-statutory local landscape designation addressed through Policy SP8 of the local plan. The policy Wentlooge Levels requires that proposals in these areas “will be required to contribute Special Landscape positively to the area through high quality design, materials and Area management schemes that demonstrate a clear appreciation of the area’s special features ”. Being a renewable energy scheme comprised of electrical transmission componentry, the latter part of the policy is most relevant – that is the required management of the scheme to reduce its

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visual impacts and strengthen the special features of the SLA.

The primary landscape qualities and features for the Wentlooge Levels Area include its flat, open nature and the distinctive pattern of drainage ditches. It is precisely because of this topography that the visual impact of the proposed development is very limited. Furthermore, the existing trees, hedge lines and vegetation will provide a significant degree of screening to the installed panels and associated infrastructure. The submitted Landscape and Ecological Management Plan (LEMP) seeks to implement a careful approach to screening, proposing a targeted effort to ‘gap-up’ hedgerows only on the northern side of reen/ditch boundaries. This balances key ecological considerations whilst also reducing the visual impact of the scheme in a manner which is consistent with the special features described above.

Moreover, the submitted LVIA has concluded that the scheme would have a “moderate adverse impact on the immediate rural character within 1km of the site. Between 1km and 5km from the site the effect of the solar arrays and battery storage development would reduce to minor adverse.”

In combination, it is clear that the proposed scheme demonstrates an appreciation of the area’s special features, and that these would be protected through the implementation of the development.

A rural location is a suitable location for a solar farm scheme as a large area of land is required to

accommodate the development. There is no policy requirement for the scheme to be located within or

adjoining an existing settlement. Moreover, a location within or near to a settlement is not required on

the usual grounds of sustainability because the proposals attract only a low level number of traffic

movements per year. The proposed development does not therefore require a site within close

proximity to local services and is highly sustainable despite being located in open countryside.

The panels are extremely low maintenance; the grass underneath could be grazed by livestock and the

panels cleaned down annually. The panels would be monitored remotely via a CCTV link.

The development is entirely in line with planning policy at the local and national levels.

The key attributes of the proposed development are as follows:

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 The proposals seek to provide green energy for over 37,500 homes and save over 53,750

tonnes of CO2 per annum.

 Solar PV arrays have a low profile, no moving parts, and do not generate noise;

 The site has been assessed by professional consultants to ensure there are no significant

adverse impacts upon landscape or visual amenity.

 The development will bring about significant biodiversity enhancements to benefit the special

qualities of the SSSI in which the site is located

 The land will maintain its agricultural function through the grazing of sheep

 Once operational, it will require only Infrequent vehicle maintenance visits

 The incorporation of an integrated battery storage area will allow for the optimum use of the

renewable energy to match peak levels of demand

 Contributes to the UK and Wales’ renewable energy and carbon reduction objectives.

 The development will place no additional pressure on local infrastructure such as roads or the

drainage network

It should also be noted that a large scale solar farm with battery storage was granted planning

permission in 2018 on the Caldicot Levels to the south of Llanwern Steelworks Site. That site has very

similar characteristics to the application site and is also covered by almost identical planning

designations (SSSI, flood zone 3, Historic landscape Area, Special Landscape Area and in proximity

to SPA and SAC). The scheme was recommended for approval by the Inspector and granted consent

by the Welsh Assembly Government (ref: 3150137).

In recommending approval, the Inspector stated:

“All things considered, therefore, the proposed development would not result in significant harm to the

ecological, landscape or historic interests of the site or area. Any minor harm is more than justified by

the significant renewable energy benefits which would arise from the proposed scheme.”

While all proposals should be treated on their own merits, the very strong parallels in these proposals

and the accompanying planning context mean it is highly relevant and a strong indicator that the

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application proposals are acceptable in this context.

6.3 Project Ownership

The Draft NDF sets the objective for new renewable energy projects to have “at least an element of

local ownership by 2020”. Although the plan is not yet adopted it represents a clear direction of travel

for National Policy and is a material consideration for this application.

The applicant for this proposed development is Wentlooge Farmers Solar Scheme Ltd, who have an

agreement to lease the land from a collection of local landowners who currently farm the land.

Throughout the operation of the scheme the landowners would retain ownership of the site and would

retain rights to access the land for agricultural practices as agreed under the contract. All owners have

voluntarily entered into rental agreements in order to diversify their farming enterprise and to secure a

rental income from the scheme for the duration of the consent.

The agreed rental income would ensure a flow of benefits to be derived from the proposed scheme in

a manner preferred by the landowners as demonstrated by the landowner statements under chapter 4

of this report. This rental income is guaranteed under the contract and is insulated from market

fluctuations relating to the electricity markets.

To this extent the rental agreement represents a sensible and straightforward mechanism for the

landowners to secure a stake in the benefits of the scheme. This would be preferable to becoming a

minority shareholder in the company leasing the land for the purposes of the scheme or owning its

constituent componentry.

It is therefore fair to assert that the current arrangement represents a reasonable element of local

ownership in the scheme, whereby the economic benefits of the scheme would flow to local landowners.

It is therefore considered that the proposed scheme is in accordance with the objective of Welsh

Government in this regard.

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7.0 Assessment of Environmental Impacts

7.1 Overview

The application is supported by a full Environmental Impact Assessment (EIA), the results of which

have helped to inform the design of the proposals. The conclusions that are reached in relation to

environmental impact are based on several years of environmental survey and assessment work.

This section of the planning statement summarises the findings of this assessment. Full details are

provided within the Environmental Statement which accompanies the submission.

7.2 Traffic and Transport

Site Traffic

A Transport Assessment has been undertaken in the form of a Construction Traffic Management Plan

(CTMP). This section explains the proposed vehicular access arrangements for the scheme and

outlines the proposed approach to mitigating any impacts caused through the construction stage.

During construction, the site would be accessed via a single point of entry off Broadway.

Two routes of access are proposed 1) For HGVs and 2) for Abnormal Loads. These two routes are

indicated on the plans below:

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Figure 15 Proposed construction route for HGVs

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Figure 16 Proposed construction route for abnormal loads

These routes are based upon a survey of the proposed route and a swept path analysis has been

completed in respect of the proposed access off Broadway.

Management Measures

The CTMP has recommended a number of mitigation measures which will be implemented to reduce

nuisance during instruction. The full detail of these can be viewed in the CTMP. They include:

 Weight limits and signage;

 Construction site signage;

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 Restricted construction hours;

 Tool box talks and driver awareness;

 Public information;

 Wheel cleaning facilities;

 Dust Management; and

 Road condition surveys.

Once operational, the solar farm would require only occasional visits for maintenance purposes causing

a negligible impact upon the local highway network.

7.3 Cultural Heritage

Gwent Levels Historic Landscape

The site area lies within the Gwent Levels Historic Landscape Area as shown in Figure 6 as designated

under the Register of Landscapes, Parks and Gardens of Outstanding Historic Interest in Wales.

The area comprises discrete and extensive areas of alluvial wetlands and intertidal mudflats and

represent a 'hand-crafted' landscape having been recurrently inundated and reclaimed from the sea

since the Roman period. The areas have distinctive patterns of settlement, enclosure and drainage

systems belonging to successive periods of use.

This Area is further broken down into 21 ‘character areas’ which reflect the locally distinctive features

within the area as shown on Figure 17.

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Figure 17 Gwent Levels Historic Landscape Area

The application site stretches across the ‘Western St Brides’ and ‘Maerdy’ Character areas. These

areas are described within the Historic Landscape Character record and are briefly characterised as

follows:

3. Western St Brides: ‘simpler landscape, laid out within a framework of elements surviving from

the Roman landscape’

4. Maerdy: ‘Regular landscape" of medieval/post-medieval date in low-lying back-fen.’

Within the wider study area there are several listed buildings, the nearest are:

 Grade II: Former - Situated on the raised bank of the sea wall on the western shore of

the Usk Estuary approximately 2.85km southwest of the site.

 Grade I: Parish Church of St Peter - Located at the centre of Peterstone village, set back from the road,

approximately 1.1km from the site.

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 Grade II*: Parish Church of St Bridget - Located on the western side of Church Road in St Bride’s Wentlooge,

approximately 0.8km from the site.

 Grade II: Gelli-ber Farmhouse and Grade II*: Parish Church of St Mary are located north of the railway to the

north of Marshfield.

 At and grounds there are a further 16 listed buildings and structure, all located over 2.5km

northeast of the site.

Bearing in mind the flat nature of the land between the site and the nearest listed buildings, it is

considered that the visual impact upon heritage assets will be minimal.

A thorough assessment of the impact of the scheme on the historic environment has been undertaken

by Savills’ Heritage in support of this application. This identifies and evaluates heritage assets within

the application site and surrounding study area, and assesses how the scheme might affect these

heritage assets. Details relating to this assessment’s methodology and findings can be found in the ES.

Using the professional judgement of the Heritage Consultant and the thorough application of the

archaeological assessment and ASIDOHL2 process it is concluded that the impacts of the scheme can

be suitably mitigated through adherence to a robust Written Scheme of Investigation (WSI), including

a watching brief covering all works with the potential to disturb below-ground archaeology.

7.4 Landscape and Visual Effects

Summary

The site lies on the Wentlooge Levels and within the Gwent Levels Special Landscape Area as

designated under the Newport Local Development Plan. Policy CE10 (Renewable Energy) of the plan

sets out the relevant policy tests against which proposals for renewable energy schemes in these areas

must be assessed. Paragraph 4.51 of the supporting text to this policy explains that: “Proposals which

affect the special qualities of the Gwent Levels, or any other protected site, will be resisted unless it

can be demonstrated that there will be no significant adverse effects.”

The site lies approximately at sea level, is extremely flat and is not overlooked by rising topography in

the immediate vicinity. In England, the siting of large-scale solar farms is addressed within the National

Planning Practice Guidance (NPPG). This guidance favours flat sites over ‘undulating landscapes’ due

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to the lower level of visual impact that arises in such locations (Paragraph: 013 Reference ID: 5-013-

20150327).

In light of the topography of the site and the surrounding area, the visual impact of the proposed

development is very limited. Furthermore, the existing trees, hedge lines and vegetation will provide a

significant degree of screening to the installed panels and associated infrastructure.

A Landscape and Visual Impact Assessment (LVIA) has been prepared and accompanies the

submission of this application. This has identified and assessed the likely effects on the landscape of

the proposed development. Overall, this report has concluded that:

“Overall the solar arrays and battery storage development would have a moderate adverse impact on

the immediate rural character within 1km of the site. Between 1km and 5km from the site the effect of

the solar arrays and battery storage development would reduce to minor adverse.”

From between approximately 5km and 10km the proposed solar arrays would have negligible effect on

landscape character as it becomes integrated into the landscape.

These impacts must be viewed against the benefits of the scheme which are considerable with the

scheme generating clean, renewable power for approximately 37,500 dwellings. It follows that the

proposals satisfy the requirements of Policy CE10 and are acceptable in planning terms.

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7.5 Ecology

Introduction

The ecological assessment within the submitted ES has identified and assessed the likely significant

effects during construction, operation and decommissioning of all components of the proposed

Wentlooge Renewable Energy Hub, taking into account proposed mitigation measures. This also

includes assessment of the impact of the development of the sensitive area of the Gwent Levels SSSI

sites.

The St Brides SSSI is notified for having three features of special interest as follows:

 Reen and ditch habitat;

 Insects and other invertebrates and

 Shrill Carder Bee.

The application site also lies to the north of the Severn Estuary which is widely recognised for its

environmental importance as reflected by its international designation as a Special Protection Area,

Special Area of Conservation and a Ramsar wetlands site. It has been important to consider the

potential impact of the proposals on these sites (see also ornithology Chapter 12 of the ES).

Assessment of Impacts

A full suite of ecology surveys have been completed over the period 2017 - 2018 as detailed within the

Environmental Statement and appendices. This reporting has assessed the impact of the proposed

development upon the range of habitats and species identified within the area. Specific attention has

been paid to the assemblage of species for which the SSSI is designated. Other protected species

found on site, for example, water vole and bat species have also been considered.

Mitigation and Enhancements

In accordance with pre-application guidance received from Natural Resources Wales (NRW) the

scheme proposes to observe buffer zones around the reen habitats on the site. These are;

 12.5m from Main Rivers and

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 7m from field ditches.

A stock proof fence would be installed at the edge of these buffer zones (solar array areas) that would

leave unhindered access for routine reen and ditch management.

Where reens or ditches have hedgerows on both banks one side will be removed to enable reen and

ditch management to take place; the aim being to improve the SSSI features. Additional hedge planting

would take place to infill gaps in the hedgerows and improve habitat connectivity. All mitigation

proposed is detailed in the Landscape and Ecology Management Plan (LEMP).

During the construction phase, a strategy for the installation of the panels and associated infrastructure

will ensure minimal disruption to ecology which will be identified in a Construction and Environmental

Management Plan (CEMP).

Conclusion

Once operational the proposed development will not create any adverse ecological impacts and will

provide ecological enhancements to the benefit of biodiversity.

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7.6 Ornithology

Introduction

This is a non-technical summary of the ornithological assessment provided for the proposed renewable

energy hub on land near Peterstone in Newport.

Site Context

The application site lies to the north of the Severn Estuary which is widely recognised for its importance

to wintering birds as reflected by its international designation as a Special Protection Area and a

Ramsar wetlands site. Given their significance and their proximity to the site, it has been important to

consider the potential impact of the proposals on these sites.

Assessment of Impacts

Two years of bird surveys have been undertaken, covering wintering and breeding seasons. The

associated reports have assessed the impact of the proposed development upon the range of bird

species identified within the area. Because of the close proximity of the Severn Estuary SPA and

Ramsar Site, specific attention has been paid to the species associated with these sites. These are

mainly wintering populations of wading birds and water fowl, which could potentially use the application

area for roosting or foraging at high tide. Lapwing are of particular importance due to their current low

breeding status in Wales and decline across the UK generally.

SPA and Ramsar qualifying species were not found to be using the site at high tide during the winter

months in any significant numbers. During the breeding season most species were confined to

hedgerows and reens. Lapwing was found to be breeding in certain fields within the application area

and surrounding area.

Mitigation and Enhancement

A number of land management measures are being proposed which will benefit birds, including 44

hectares of nearby land which will be managed for breeding lapwing. During the construction phase,

timing of works has been targeted to avoid the core breeding bird season including sensitive times in

the crane breeding period. Grassland habitats will be protected from vehicle damage my avoidance

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and through the targeted use of trackway. A programme of post-construction bird monitoring will also

be introduced. Mitigation measures are detailed in the Landscape and Ecological Management Plan

(LEMP).

Conclusions

Overall the impacts of the solar farm on birds are predicted to be minimal and habitat will be enhanced

for species associated with reens and ditches and field margins. The loss of some fields used by

breeding lapwing will be compensated for by the provision of a larger area of specifically managed

fields for this species.

7.7 Flood Risk and Water Resources

Summary

Technical Advice Note 15 (TAN 15) provides the relevant guidance on flood risk in relation to these

proposals. The site is located within Flood Zone C1 In accordance with the categories set out within

this document. This means that it sits within an area of the floodplain which is developed and served

by significant infrastructure, including flood defences. This designation is used to indicate that

development can take place subject to it passing the justification test, including acceptability of

consequences.

To this end a Flood Consequences Assessment (FCA) has been prepared which considers the impact

of the proposed development on hydrology in the area. The document also details the specific

mitigation measures which would be incorporated in association with the built infrastructure including

solar panels, battery storage units and ancillary equipment.

With regards to the installation of the solar panels (which make up the bulk of the proposed

development), these will be individually spaced to allow thermal expansion and more even dispersal of

rainwater.

The proposal would bring an end to any arable farming, intense grazing and soil compaction by animals

and machinery. In turn, grassland would flourish, resulting in improved water quality due to the reduction

in silt runoff and the elimination of fertilizers and pesticides.

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The FCA report identifies specific changes brought about through the proposals which will affect

surface water drainage. These include:

 Reduced grazing intensity

 Reduced use of machinery on the land

 No harvesting, or seeding of new crop

 Longer grass and increased biodiversity in vegetation on site, particularly in buffer zone areas

adjacent to reens and ditches

The consequences of these changes have been assessed within the report and the following

conclusions have been drawn:

 Soil compaction will be reduced resulting in an overall improvement in the soil condition and

more natural management of surface water

 More uniform management of surface water

 The fields will be better able to naturally manage rainfall

Consequently the report has concluded that:

“The consequences of the solar farm during operation will be positive in terms of water flow and quality,

will be positive for the management of the Wentlooge Levels and the solar farm will become a haven

for wildlife.”

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7.8 Glint and Glare

Summary

Within the relevant planning policy context in Wales, the only specific reference to glint and glare can

be found in the supporting text of Policy CE10 of the Newport City Local Development Plan, where it is

explained that:

“The potential for reflective ‘glint and glare’ will need to be explored as well as potential ecological and

visual impacts from installation techniques such as cable trenches and the removal of hedgerows.”

English planning guidance set out within the NPPG outlines the factors which should be considered in

the assessment of proposals for solar farm development, including the “visual impact, the effect on

landscape of glint and glare and on neighbouring uses and aircraft safety”.

A technical assessment of glint and glare resulting from the proposals was undertaken by qualified

consultants Pager Power.

Whilst guidelines exist within the UK (produced by the Civil Aviation Authority) and in the USA

(produced by the Federal Aviation Administration) with respect to solar developments and aviation

activity, the assessment was completed in accordance with Pager Power’s own methodology which is

based on compiled guidance from these sources, industry experience and consultation with the relevant

bodies.

Under this methodology the solar development area is defined, as well as the relevant receptor

locations. A basic geometric assessment is then undertaken in order to determine whether a reflection

can occur, and if so, at what time it will occur. A more detailed assessment is then undertaken to

determine whether any significant effects would arise, based upon a range of criteria including the

duration and nature of the impact and the presence of any mitigating factors such as visual screening.

Through this assessment it is possible to determine whether a significant detrimental impact is expected

in accordance with the methodology.

Based upon the geometric assessment, it was determined that potential glint and glare effects could

occur at 5 dwellings and at 3 possible locations on nearby roads.

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However, through the subsequent detailed assessment It was determined that the nature of these

effects would be reduced due to a range of mitigating factors. Consequently, it was considered that

only a low significance of effect would occur in respect of all identified receptors.

No significant impacts are predicted to effect either dwellings or roads within the vicinity of the proposed

development. The site is not located within any flight path and therefore there would be no significant

effects on aviation.

The analysis undertaken considered 30 train driver observer points, covering a total of 3km of railway.

Results and available imagery show that an unscreened geometric reflection is possible and

unscreened for 5 points, but it will only affect trains travelling in south-west/north-east direction. For

these points, a moderate impact is expected which is considered to fall within a normal range, for which

there is existing case precedence to demonstrate that the impacts is acceptable.

7.9 Noise

Summary

Technical Advice Note (Wales) 11 refers to Noise impacts and outlines the main considerations which

local planning authorities should take into account when assessing the noise impacts resulting from

development proposals. The Note refers to assessment guidance set out in BS 4142:1990 and the

general guidance general guidance on acceptable noise levels provided in BS 8233: 1987.

A noise assessment of the significant affects associated with the proposed development was

undertaken by Acoustic Consultants Ltd. The assessment was completed in accordance with British

Standard 4142:2014 entitled ‘Method for rating and assessing industrial and commercial sound’ was

published on the 31st October 2014. This is the most up-to-date and relevant guidance to the

assessment of noise impacts for this type of development and was considered more suitable for use

than the guidance referred to in TAN 11.

Baseline site noise monitoring was undertaken between 2nd and 3rd September 2019 at three locations

considered to be representative of the noise sensitive locations in the vicinity of the development.

Based on the noise predictions undertaken it has been demonstrated that the British Standard

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4142:2014 assessment ‘difference’ can be no more than 0 dB. As such it is an indication that noise

from the scheme will be of low impact on the noise-sensitive receivers in the area and the proposals

will not have a significant impact on nearby noise sensitive receptors.

On the basis of the above assessment and with a suitable noise limiting condition imposed on the

scheme noise can be controlled to acceptable levels and will have no adverse impact upon residential

properties. It follows that there will be no residual impacts resulting from the solar farm component of

the scheme.

On the basis of the above assessment the scheme noise can be controlled to acceptable levels and

will have no significant adverse impact upon nearby noise sensitive dwellings.

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8.0 Additional Assessments

8.1 Agricultural Land Quality

Through engagement with the Soil Research Department in Welsh Government, it is considered that

the land is classified as grade 4 on the Predictive ALC Map for Wales, which is based upon the

Agricultural Land Classification System of England & Wales, the Revised Guidelines & Criteria for

Grading the Quality of Agricultural Land (MAFF 1988). As such, the site is not considered to comprise

“best and most versatile” agricultural land.

Figure 18 Predictive ALC Map for Wales

8.2 Tree Survey

An Arboricultural Impact Assessment in accordance with the guidance set out in BS5837 (2012) ‘Trees

in Relation to Design, Demolition and Construction, Recommendations’ was undertaken for the

proposed development.

All of the trees recommended for retention in the Tree Survey Schedule and on the Tree Survey Plan

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(see ES) can be protected for the duration of demolition and construction in accordance with current

best practice guidance set out in BS 5837 (2012). In this regard, the Tree Constraints Plan and

Arboricultural Method Statement provide further details of proposed working methodology and

protection measures.

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9.0 Sustainability Credentials

9.1 Introduction

Paragraph 12 of PPW explains that “The primary objective of PPW is to ensure that the planning system

contributes towards the delivery of sustainable development and improves the social, economic,

environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Well-

being of Future Generations (Wales) Act 2015 and other key legislation”.

This vision for sustainable development is reflected in the Newport LDP which is the pertinent

development plan against which these proposals should be assessed. As such, proposals for

sustainable development should be determined in line with the presumption in favour of sustainable

development and the policies set out within the LDP.

This chapter will now demonstrate how the proposals amount to sustainable development in economic,

social and environmental terms.

9.2 Economic Sustainability

The site will be eligible to pay business rates to the Local Authority. Given the scale of the site, this will

provide a significant financial income for the Council, with income filtering down to local communities.

The proposal will still enable the site to be grazed, retaining its agricultural function and providing

additional agricultural income for the landowners and help to support the local rural economy.

The scheme would be delivered without any government subsidy and would reduce the country’s

reliance on fossil fuels and the economic exposure to international price fluctuations.

Although there would be a number of employment opportunities created by the scheme during the

construction stage, one of the key benefits of solar energy are that it is a low-maintenance form of

energy generation, with relatively few workers required in the ongoing maintenance. Nonetheless, jobs

would be created in order to fulfil the ongoing land management and ecological enhancements

proposed by the scheme.

The appointed EPC will look to use local contractors for the construction process wherever possible,

Wentlooge Renewable Energy Hub 78

as well as local suppliers for key items such as aggregate, fencing and landscaping.

The scheme involves a group of local farmers and the scheme will enable the group to reinvest in their

farms and will result in increased spending in the local economy as well as the potential for longer term

job creation resulting from more locally successful farming enterprises subsidised by the solar farm

income.

The proposal will ensure that the farmers can secure their farms for future generations and guard

against going out of business, at a time where the single farm payment is being reduced, farmers are

reliant on subsidy to keep otherwise marginal farming operations viable and in an area where climate

change can pose a real threat, including in respect of flooding.

As set out above, the Best Practice Guidance for solar farms produced by BRE provides a number of

case studies which illustrate this point:

Eastacombe Farm, Holsworthy, Devon

“This farm has been in the Petherick family for four generations, but they were struggling to survive with

a small dairy herd. In 2011/12, a solar developer helped them convert eight hectares of the lower-grade

part of their land into a 3.6 megawatt solar farm with sheep grazing, which has diversified the business,

guaranteeing its future for the next generation of farmers.”

Newlands Farm, Axminster, Devon

“Devon sheep farmer Gilbert Churchill chose to supplement his agricultural enterprise by leasing 13

hectares of grazing land for a 4.2 megawatt solar PV development, which was completed in early 2013.

According to Mr Churchill, the additional income stream is “a lifeline” that “will safeguard the farm’s

survival for the future”.

As set out in the Solar Strategy Part II, the renewable energy sector is a major employer in the UK and

the proposal will contribute positively towards employment in this sector. Employment will include short

term jobs for installation, longer term jobs for site maintenance and security and indirect (but

nevertheless important) jobs for the service and manufacturing industry which supports the growth of

the renewable energy sector. The table below sets out the range of jobs associated with the sector:

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General Management, Sales Manufacturing and Design Installation and Maintenance and Admin

Design engineers, systems Planning and environmental Sales/purchase engineers, production consultants, electricians, administrators, sales and managers, production instrumentation engineers, business development teams, supervisors, electrical controls and electrical systems logistics – drivers, packers, engineers, laboratory technicians, installation warehouse staff, marketing technicians, quality assurance, engineers, installation teams. assembly line personnel, supervisors, scaffolders, chemists, surveyors, materials service engineers, panel scientists, warehousing/logistics cleaners, security. personnel.

Table 1: Summary of employment sectors supporting the solar industry

It is therefore evident that the proposal will play a major role in supporting economic development

through the creation of new jobs.

9.3 Social Sustainability

There is potential for engagement with local schools, educational establishments, and community

groups relating to both biodiversity enhancements and clean energy production & use. There is also

the opportunity to demonstrate the co-production of both energy and food in harmony.

UK Government has tracked public opinion on energy issues in a quarterly ‘public attitudes tracker’

since 2012. This survey is now in its 22nd iteration (‘wave’)10 and the survey findings reveal that support

for renewable energy has remained consistently high during the tracker at around 75-80%. The most

recent survey has shown 77% expressing support for the use of renewables, whilst opposition to

renewables was very low at 4%, with only 1% strongly opposed.

Specific questions relating to Solar were removed following wave 1711. However at the time of that

survey (April 2016), support for solar was particularly high, with 95% of respondents expressing their

support for solar energy development.

When respondents were asked if they would be happy to have a large scale renewable energy

10 Department for Energy for Business, Energy and Industrial Strategy (DBEIS) – Energy and Climate Change Public Attitude Tracker – Wave 22 (August 2017) 11 Department of Energy & Climate Change – DECC Public Attitudes Tracker – Wave 17 (April 2016)

Wentlooge Renewable Energy Hub 80

development in their area, 75% or respondents agreed that they would be happy.

This evidence demonstrates that there is strong public support for renewable energy and that solar

energy in particular is the most strongly supported.

The submitted ES demonstrates that the scheme would not bring about any significant adverse impacts

upon the residential amenity of nearby properties or the public highway and railway.

The proposal will also help to reduce the UKs reliance on imported fossil fuels and help the UK gain

more control over its energy provision and therefore more control over future energy prices and more

energy security going forward. This is particularly important considering the projected sharp rise in

energy prices over the next 5 years.

9.4 Environmental Sustainability

The most significant benefit of the proposals is the contribution towards the national and European

renewable energy targets and helping to facilitate a transition to a low carbon economy.

The proposals would generate approximately 125 MW of electricity. In accordance with guidance

outlined by the Solar Trade Association12 this would offset around 53,750 tonnes (21.2 kilotons) of CO2

per annum, and 2,150,000 tonnes over the life of the scheme. This equates to enough electricity to

serve the total power needs of around 37,500 average UK households per annum.

The benefits of the proposals in this regard are set against the context that the UK is one of the poorest

deliverers of renewable energy in the Europe.

Within the UK Wales has consistently generated a lower proportion of its electricity from renewable

sources than the UK average, as shown revealed by Figure 19, which shows the percentage of

electricity generated by renewable sources in each UK country. The chart shows that in 2013 Wales

generated the lowest percentage of electricity from renewable sources within the UK.

12 Solar Trade Association 2016: Resource Centre - http://www.solar-trade.org.uk/solar-farms/

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Figure 19 Welsh Government Statistical Bulletin: Energy Consumption and Generation for Wales 2013.

Solar farms are a simple and proven technology providing a source of safe, locally produced renewable

energy for many years after construction, with no by-products that cannot simply be recycled.

The land used for this solar farm will create a place for nature and wildlife to thrive, protected from

human contact. The land around the panels will be grassland with hedging retained, enhanced and

managed and newly planted around the fence. These environments provide better habitats than

intensively farmed land and are akin to a nature reserve.

The ground beneath and around the panels will also be used to graze sheep and to grow grass and

wildflowers to encourage invertebrates including butterflies and the shrill carder bee, which is

recognised under the SSSI designation.

Resting the land from intensive grazing use for a period of 40 years will have significant benefits in

terms of allowing native grassland species to re-establish and for the land to restore fertility for future

farming use after the solar farm has been removed. The development will also mean the land is no

Wentlooge Renewable Energy Hub 82

longer subjected to intensive use of pesticide or fertilizer, to the benefit of local soil and fluvial

environments which can lead to utrification of watercourses.

Intensive grazing by cattle and intensive arable use tends to result in compacted soil and much more

bare soil more of the time. This accelerates run off to watercourses. The solar farm will allow a rich mix

of plant and grassland species to become established which will help retain water and slow run off

rates, to the benefit of the area in respect of flood risk. The proposal will also provide new biodiverse

areas around the edges of the reens and ditches, which will encourage local biodiversity to thrive.

The potential ecological impacts of the proposed scheme have been comprehensively assessed

through a suite detailed surveying and reporting which can be viewed within the accompanying

Environmental Impact Assessment. This reporting has concluded that “the low ecological value of the

affected area in combination with the proposed ecological enhancements, such as the creation of

planted biodiversity areas and species rich grassland areas, means that the scheme has potential to

have a net benefit to biodiversity during the operational phase”.

The reporting also demonstrates that the special qualities of the St Brides SSSI (in which the site is

located) would be preserved and where possible enhanced through the implementation of the scheme.

The proposals are fully reversible and temporary for a period of 40 years. There would therefore be no

long term impacts from the development. The land can be quickly restored back to its former use.

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10.0 Conclusions

10.1 Summary

This Statement supports a planning application made under the Developments of National Significance

regime for a renewable energy hub and associated infrastructure on land on the a renewable energy

hub and associated infrastructure on land on the Wentlooge Levels in south Wales. The site extends

to circa 155 hectares of grade 4 agricultural land and the development will produce up to 125MW of

renewable electricity.

The proposal would make a vast contribution to reducing greenhouse gas emissions and combating

the causes of climate change. This key benefit is of central importance to both National and

Internationally binding political commitments to reduce CO2 emissions by 80% by 2050.

The scheme would be delivered without any government subsidy and would reduce the country’s

reliance on fossil fuels and the economic exposure to international price fluctuations.

The proposed development is sustainable in terms of the environmental, economic and social strands

of sustainability set out in Planning Policy Wales.

It is demonstrated that the proposals wholly comply with planning policies at national and local levels.

A solar farm has been permitted at Llanwern on a site which shares the same characteristics and

planning designations as the application site (including SSSI, historic landscape area, flood zone 3,

Special Landscape Area and in proximity to the SAC and SPA). The Inspector and the Welsh Assembly

Government both found that proposal to be acceptable in that location; the Inspector noted (para 345):

“All things considered, therefore, the proposed development would not result in significant harm to the

ecological, landscape or historic interests of the site or area. Any minor harm is more than justified by

the significant renewable energy benefits which would arise from the proposed scheme.”

The proposals bring about numerous and significant environmental, economic and social benefits

without giving rise to any unacceptable harm.

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Planning, Design and Access Statement

Gwent Farmers’ Community Solar Scheme

Wentlooge Renewable Energy Hub

Savills (UK) Ltd York House, Blackbrook Business Park, Taunton, TA1 2PX

www.savills.co.uk