Wentlooge Renewable Energy Hub, Peterstone, Newport Shadow

Wentlooge Renewable Energy Hub, Peterstone, Newport

Shadow Habitat Regulations Assessment

January 2021

A report on behalf of Wentlooge Farmers' Solar Scheme Ltd

Ref: 0475-sHRA-MW

Wentlooge Farmers' Solar Scheme Ltd Wentlooge Renewable Energy Hub, Peterstone, Newport

Site Details

Site Name Wentlooge Renewable Energy Hub

Site Location Peterstone, Newport

Central OS Grid Reference ST 2767 8186

Client Wentlooge Farmers' Solar Scheme Ltd

Quality Assurance

Report Title Shadow Habitat Regulations Assessment

Report Reference 0475-sHRA-MW

Author Mark Witherall BSc MCIEEM

Checked By Faye Midmore BSc MSc MCIEEM

Approved By Jon Garner BSc MCIEEM

Revision No. 3

Issue Date 08 January 2021

Summary of Changes Further information provided following NRW comments dated 07.12.20 (NRW ref. CAS-125224-Z4J1) in relation to potential for in-combination effects with Hendre Lakes proposals. Data also updated to exclude previously included data that was within the survey boundary but not within the final red line boundary.

Revised By Richard Pash BSc MCIEEM

Approved By Jon Garner BSc MCIEEM

The content of this report that has been provided by Green Ecology is true and has been prepared and submitted in accordance with the Chartered Institute of Ecology and Environmental Management’s Code of Professional Conduct. Its contents are compliant with British Standard BS42020: 2013 Biodiversity Code of Practice for Planning and Development.

This report has been prepared for the exclusive use of the stated client and unless otherwise agreed in writing by Green Ecology, no other party may use, make use of or rely on the contents of the report. No liability is accepted by Green Ecology for any use of this report, other than for the purposes for which it was originally prepared and provided.

Green Ecology has exercised due care in preparing this report. It has not, unless specifically stated, independently verified information provided by others. No other warranty, express or implied, is made in relation to the content of this report and Green Ecology assumes no liability for any loss resulting from errors, omissions or misrepresentation made by others.

Any recommendation, opinion or finding stated in this report is based on circumstances and facts as they existed at the time that Green Ecology undertook the work. Nothing in this report constitutes legal opinion. If legal opinion is required, the advice of a qualified legal professional should be secured.

Wentlooge Farmers' Solar Scheme Ltd Wentlooge Renewable Energy Hub, Peterstone, Newport

Contents

1 Introduction ...... 1 1.1 Description of Proposed Development ...... 1 1.2 Scope and Aims ...... 1 1.3 Consultation ...... 1 2 Natura 2000 Sites and HRA Requirement ...... 2 2.1 Natura 2000 Sites ...... 2 2.2 Legislative Context ...... 2 2.3 HRA Process ...... 2 3 European Sites Scoped into Assessment ...... 2 4 Screening Assessment ...... 3 4.1 Factors Affecting the Natura 2000 Sites ...... 3 4.2 Likely Significant Effect (LSE) Test ...... 3 4.3 Identification of Pathways ...... 8 5 Information for Appropriate Assessment ...... 9 5.1 Severn Estuary Existing Condition ...... 9 5.2 Evaluation of Baseline Data ...... 9 5.3 Change in Land Management/ Assessment of Functionally Linked Land ...... 16 5.4 Changes in Species Distribution/ Disturbance to SPA Assemblage Species ...... 18 5.5 Loss of Winter Foraging Habitat for Lapwing ...... 19 5.6 Siltation and Dust (SAC & SPA) ...... 19 5.7 Water Pollution – Impacts to European Eel in Freshwater Environment...... 20 6 Cumulative Assessment ...... 20 6.1 Cumulative Construction/Decommissioning Effects ...... Error! Bookmark not defined. 6.2 Cumulative Operational Effects ...... Error! Bookmark not defined. 7 Overall Assessment ...... 26 8 References ...... 27

Appendices

Appendix 1 – Location of Natura 2000 sites in relation to application site ...... 28 Appendix 2 – The qualifying interest features and supporting habitats of the Severn Estuary SPA...... 29

Shadow Habitat Regulations Assessment 08 January 2021 0475-sHRA-MW Wentlooge Farmers' Solar Scheme Ltd Wentlooge Renewable Energy Hub, Peterstone, Newport

1 INTRODUCTION

This report has been prepared on behalf of Wentlooge Farmers' Solar Scheme Ltd in relation to a proposed planning application at Wentlooge Renewable Energy Hub, Peterstone, Newport (central OS grid reference: ST 2767 8186).

The application site, hereafter referred to as the ‘Site’, extends to approximately 160 hectares (ha) and is located on the Gwent Levels near Peterstone and St Brides. An Ecological Impact Assessment has been produced as part of the Environmental Statement (Savills, 2019) which accompanies the planning application.

1.1 Description of Proposed Development

The applicant is seeking full planning permission for solar photovoltaic (PV) panels and includes boundary fencing, access tracks, battery storage units and associated infrastructure including grid connection buildings, transformer and inverter units. The proposed panelled area will be 128.4ha, grid yard 0.6ha and battery storage 0.9ha (total 129.9 ha) with an additional 2.6ha for ecological enhancement, plus 22.1ha of land set aside for lapwing compensation.

1.2 Scope and Aims

This shadow Habitats Regulations Assessment (sHRA) has been produced to provide Welsh Ministers with technical information to undertake the HRA under the provision of the Habitats Directive.

It should be read in conjunction with the corresponding application documents and drawings, in particular:

Environmental Statement Chapter 12 (Savills, 2012) Winter Bird Surveys Technical Report (Green Ecology, 2020) Breeding Bird Surveys Technical Report (Green Ecology, 2020) Draft LEMP (Green Ecology, 2020)

1.3 Consultation

Natural Resources Wales (NRW) in their Development of National Significance (DNS) Pre-application Consultation (Ref: CAS-107058-K8Q6) dated 24th February 2020 provided advice on HRA as follows:

‘Should the competent authority (Welsh Minister) conclude that the proposed development is likely to have a significant effect on the Severn Estuary, we will advise on the appropriate assessment under Regulation 63 of the Conservation of Habitats and Species Regulations 2017.

The purpose of the appropriate assessment would be to assess the implications of the proposed development with respect to the conservation objectives of the Severn Estuary.

The conclusions of the appropriate assessment should enable the Welsh Ministers to ascertain whether or not the proposed development would adversely affect the integrity of the SAC.

Based on the information submitted so far, we advise there is not sufficient information for the appropriate assessment to be carried out, as advised under both ecology and nature conservation and ornithology.’

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2 NATURA 2000 SITES AND HRA REQUIREMENT

2.1 Natura 2000 Sites

European Council Directive 92/43/EEC on the Conservation of Natural Habitat and of Wild Fauna and Flora (known as the Habitats Directive) and Council Directive 2009/147/EC (codified version of Directive 79/409/EEC as amended) on the Conservation of Wild Birds (the Birds Directive) established a network of internationally important sites (i.e. Special Areas of Conservation (SACs) and Special Protection Areas (SPAs)) designated for their ecological status. These sites combine to create the Europe-wide ‘Natura 2000’ network of sites, also known as ‘European sites’.

2.2 Legislative Context

In the UK, the requirements of the European Council Directives are transposed into domestic legislation via the Conservation of Habitats and Species Regulations 2017 (the ‘Habitats Regulations’). Under Part 6 ‘Assessment of Plan and Projects’, Regulation 63 (1) of the Habitats Regulations, an appropriate assessment needs to be undertaken by the competent authority in respect of any plan or project which:

Is likely to have a significant effect on a European site or a European offshore marine site (either alone or in combination with other plans or projects); and, Is not directly connected with or necessary to the management of that site.

As the application is not necessary to the management of the site for nature conservation, Welsh Ministers, (as the relevant competent authority), are required to carry out an HRA to ensure that the development decision does not adversely affect the integrity of European sites.

2.3 HRA Process

The HRA comprises:

An initial assessment, ‘screening’, of whether the proposal either alone or in combination with other plans or projects is likely to have a significant effect on the European site. This screening process is focused on the ‘Likely Significant Effect’ (LSE) test. This is essentially a risk assessment process that seeks to understand whether there are any mechanisms for identified impacts arising from the project to adversely affect the European site (e.g. cause-effect pathway); and, If a likely significant effect cannot be ruled out, an Appropriate Assessment under Articles 6 (3) and 6 (4) of the Habitats Directive to determine whether the proposal will adversely affect the integrity of the European site.

A significant effect can be defined as an ‘effect that is likely to undermine the site’s conservation objectives. Following the People Over Wind ruling (case C323/17) in April 2018, ‘it is not appropriate, at the screening stage, to take account of the measures intended to avoid or reduce the harmful effects of the plan or project on that site’ and therefore this screening is undertaken in the absence of standard mitigation.

3 EUROPEAN SITES SCOPED INTO ASSESSMENT

Two European (Natura 2000) designated sites lie within 10km of the Site and have been scoped into the assessment:

Severn Estuary SAC (UK0013030) Severn Estuary SPA (UK9015022)

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European site locations in relation to the application site are shown in Appendix 1 (provided by MAGIC1).

The proposed development was not considered to have effects on Natura 2000 sites beyond 10km as no potential pathways have been identified.

4 SCREENING ASSESSMENT

4.1 Factors Affecting the Natura 2000 Sites

The Assessment takes account of the current state of the Natura 2000 sites, the main sensitivities and the range and scale of potential impacts from the proposed development.

During the screening exercise, Natura 2000 Standard Data Forms produced by JNCC, have been used to identify threats, pressures and activities with high impacts on the European site’s designated features. In addition, Site Improvement Plans (SIP) which have been developed by Natural Resources Wales and Natural England for each Natura 2000 site outline the issues (both current and predicted) affecting the condition of the qualifying features.

4.2 Likely Significant Effect (LSE) Test

Table 1 below details the characteristics of the European Sites and identifies potential pathways for Likely Significant Effects (LSEs) as a result of the proposed development. These potential effects are as follows:

4.2.1 Alone:

Potential for siltation/pollution during construction and decommissioning entering SPA via reen network. Potential for siltation/pollution during construction and decommissioning entering SAC via reen network. Potential for siltation/pollution during construction and decommissioning entering reen network and effecting European eel in freshwater habitat. Change in land management with potential to effect qualifying features of Severn Estuary SPA; Possible change in species distribution if found to be functionally linked to SPA.

4.2.2 In-combination:

As above

1 https://magic.defra.gov.uk/home.htm

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Table 1: Screening Assessment for LSEs

Site Distance Qualifying Features Conservation Objectives SSSI Condition Threats, pressures Risk of Signficant Effect? Name from Site Assessment and activities with at negative impacts on closest the site (taken from point Standard Natura Form and SIP) Severn 500m 24700.91ha site comprising a large The objectives are to: Favorable 1/ Public No. Development has no Estuary estuary with extensive intertidal mud- 95.8% Access/disturbance additional visitors or SPA flats and sand-flats, rocky platforms Maintain the Annex 1 species, Unfavourable residents other than low Bewick’s swan population and Recovering and islands. Saltmarsh fringes the key maintainance. coast backed by grazing marsh with its supporting habitats in 0.08% Otherwise private land with freshwater ditches and occasional favourable condition; Unfavourable no public rights of way. Not brackish ditches. The seabed is rock Maintain the European white- No change likely to bring additional and gravel with sub-tidal sandbanks. fronted goose population and its 2.43% visitors into the area of The Severn Estuary qualifies under supporting habitats in Unfavourable SPA. Article 4.1: favourable condition; declining Maintain the dunlin population 1.69% 2/ Physical No pathways likely to cause by regularly supporting 3.9% of and its supporting habitats in modification any physical modification to the Great Britain population of favourable condition; the SPA. the Annex 1 species Bewick’s Maintain the redshank 3/ Impacts of Yes - Low risk of silt or dust swan Cygnus columbianus population and its supporting bewickii development contaminants entering the habitats in favourable condition; air and reen system and Under Article 4.2 as it regularly Maintain the shelduck indirectly into estuary supports the following migratory population and its supporting during construction and species of European importance: habitats in favourable condition; decomissioning only. Ringed plover Charadrius Maintain the gadwall population hiaticula; and its supporting habitats in 4/ Coastal Squeeze No pathways identified that Curlew Numenius arquata; favourable condition; and would contribute to this Dunlin Calidris alpina alpina; Maintain the waterfowl caused by the proposed Redshank Tringa totanus. assemblage and its supporting development. Pintail Anas acuta; and, habitats in favourable condition. 5/ Change in Land Yes - Change in land Shelduck Tordana tordana. Management management of potentially

supporting land to the SPA, Assemblage Qualification from sheep and cattle The area qualifies under Article grazing (in some areas) to 4.2 of the Directive (79/409/EEC) by solar panels with mowing regularly supporting at least 20,000 and/or sheep grazing not waterfowl: directly affecting SPA. Loss

of foraging areas for some

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Site Distance Qualifying Features Conservation Objectives SSSI Condition Threats, pressures Risk of Signficant Effect? Name from Site Assessment and activities with at negative impacts on closest the site (taken from point Standard Natura Form and SIP) The conservation objective for Favorable 1/ Public No. Development has no the “estuaries” feature of the 95.8% Access/disturbance additional visitors or Severn Estuary SAC is to Unfavourable residents other than low maintain the feature in Recovering key maintainance. favourable condition; 0.08% Annex I habitats (primary reason Otherwise private land with The conservation objective for Unfavourable for site selection): no public rights of way. Not the “subtidal sandbanks” No change likely to bring additional Estuaries feature of the Severn Estuary 2.43% visitors into the area of Sandbanks which are slightly SAC is to maintain the feature in Unfavourable SAC. covered by sea water all the favourable condition; declining time. (Subtidal sandbanks) The conservation objective for 1.69% 2/ Physical No pathways likely to cause Mudflats and sandflats not modification any physical modification to “mudflats and sandflats” feature covered by seawater at low of the Severn Estuary SAC is to the SAC. tide. (Intertidal mudflats and maintain the feature in sandflats) 3/ Impacts of Yes - Low risk of silt, , dust favourable condition; development or chemical pollution Atlantic salt meadows The conservation objective for (Glauco-Puccinellietalia contaminants entering the Severn the “Atlantic salt meadow” maritimae) air and reen system and Estuary 500m feature of the Severn Estuary Reefs. indirectly into estuary SAC SAC is to maintain the feature in during construction and Annex II species that are a primary favourable condition; decomissioning only. This reason for selection: The conservation objective for may effect european eel Sea Lamprey (Petromyzon the “reefs” feature of the Severn while in freshwater habitats marinus) Estuary SAC is to maintain the of reens and ditches within River Lamprey (Lampetra feature in a favourable the applicationn site, as fluviatilis) condition; well as qualifying habitats Twaite Shad (Alosa fallax) The conservation objective for within the estuary. the river lamprey Lampetra Assemblage of 114 marine fish fluviatilis feature of the Severn 4/ Coastal Squeeze No pathways identified that population including European Estuary SAC is to maintain the would contribute to this eel (Anguilla anguilla) feature in a favourable caused by the proposed condition; development. The conservation objective for 5/ Change in Land No pathways identified that the sea lamprey Petromyzon Management would contribute to this marinus feature of the Severn caused by the proposed Estuary SAC is to maintain the development.

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4.3 Identification of Pathways

The assessment process has shown that the proposed development will not involve any direct land take of any of the European sites, however some indirect LSEs on the Severn Estuary SPA/SAC cannot be totally ruled out. As outlined in Table 1, these are:

Change in land management, impacting potential SPA supporting land (functionally linked land). This could occur due to the change from sheep and cattle grazing to solar panels with mowing and/or sheep grazing resulting in loss of winter foraging area; Change in species (specifically SPA qualifying or assemblage bird species) distribution, due to loss of functionally linked land, or due to disturbance during construction and decommissioning; Risk of siltation or dust entering water courses and impacting supporting SAC features or habitats of birds of the SPA; Water pollution – impacts could occur to European eel from pollution and chemical contamination of freshwater habitats in reens and ditches.

These issues will be taken forward and assessed in Section 5 in the next stage: Information for Appropriate Assessment.

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5 INFORMATION FOR APPROPRIATE ASSESSMENT

5.1 Severn Estuary Existing Condition

The River Severn SPA/SAC comprises 82 units of the River Severn Site of Special Scientific Interest.

The overall condition of the Severn Estuary SSSI, assessed in 2010 and 2014, indicates that 95.88% (9,588.86ha) is in favourable condition, 0.08% (8.01ha) is unfavourable and recovering, 2.43% (243.42ha) is unfavourable with no change and 1.69% (168.92 ha) is unfavourable and declining2 (Figure 1).

Figure 1: Severn Estuary SSSI Condition Summary (Source Natural England, 2019)

Bird populations were assessed at an estuary level and bird assemblage feature counts were maintained with the shelduck population increasing, but redshank, curlew and dunlin populations decreasing, these were still within thresholds but considered at risk.

5.2 Evaluation of Baseline Data

The application site is located in Peterstone on the Wentlooge level. At its closet point it is approximately 500m from the SPA the nearest point being Peterstone Gut, just beyond the Peterstone Lakes golf course. Broadway reen runs into the Severn estuary and flow is managed via a sluice system at this point. The reen runs northwest to southeast to the west of the application area.

During ornithological surveys (Green Ecology 2020a3 & 2020b4) at the application site over a consecutive two-year period (2017-2019) the following Article 4.2 migratory species were found to use parts of the application area:

Greater white-fronted goose;

2https://designatedsites.naturalengland.org.uk/ReportConditionSummary.aspx?SiteCode=S1002284&ReportTitle=Sever n%20Estuary%20SSSI 3 Green Ecology (2020)a Wentlooge Renewable Energy Hub, Peterstone, Gwent Levels, Appendix 12.1 Winter Bird Surveys, Green Ecology, Christow. 4 Green Ecology (2020)b Wentlooge Renewable Energy Hub, Peterstone, Gwent Levels, Appendix 12.2 Breeding Bird Surveys, Green Ecology, Christow.

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Gadwall; and Shelduck. In addition, other named species on the Article 4.2 assemblage qualification were recorded on Site, namely:

Wigeon. Mallard. Teal. Tufted Duck. Lapwing. Curlew. Redshank. Lesser black-backed gull (Ramsar C6).

For ease of reference a summary of SPA assemblage species recorded on during winter surveys at the site is provided below in Table 2 taken from the Winter Birds technical report (Green Ecology, 2019a).

The penultimate column of Table 2 presents the peak count across all surveys within the final given red line boundary and not the peak count from all survey data as presented in previous iterations of this report. The survey scope had originally set out to survey a larger red line boundary plus a buffer zone due to previous development intentions to include wind turbines on the site and as such over inflated the potential impacts on relevant species.

The final column of Table 2 presents the same data but with records removed where they had exclusively been recorded on habitats that will not be impacted by the development. Certain species have been exclusively recorded using the reens, as these habitats will be retained an enhanced it was deemed relevant to present a baseline of species to be affected as well as a baseline of the species recorded across the Site.

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Table 2: Severn Estuary species recorded over two winter surveys (Figures referred to accompany the winter birds technical report (ES Technical Appendix 12.1)

Englis Scientifi SPA Rams BoCC BoCC WCA Annex E(W) Survey Findings Peak count across Peak count across h c Name Qualify ar 4 3 Sch. 1 A all surveys all surveys Vernac ing Criter Statu (Wale 1 (Birds 2016 excluding records excluding records ular Specie ia s s) Speci Directi Secti outside final red line from within reens Name s es ve) on 7 boundary that will be retained as part of the proposals Greater Anser Article C6 Red Red - ✔ ✔ Year 1: Recorded once only on 09/01/2018 0 0 White- albifrons 4.2 a small family group (3) were recorded with fronted albifrons the local feral greylag goose flock feeding in Goose fields adjacent to the Site (Figure 12.1.4). Year 2: Not recorded Gadwal Mareca Article C6 Ambe Ambe - - - Year 1: Recorded once on 16/01/18 where 0 0 l strepera 4.2 r r 23 were flushed from the northern fishing ponds off site (Figure 12.1.5) Year 2: Not recorded. Sheldu Tordana Article C6 Ambe Ambe - - - Year 1: Not recorded. 8 8 ck tordana 4.2 r r Year 2: Recorded on 2 dates: 8 birds were recorded in Field 48 and 5 on the off-site fishing ponds on 22/02/19. Two were recorded on the off-site fishing ponds on 13/03/19 (Figure 12.1.6). Wigeo Mareca Article - Ambe Ambe - - - Year 1: Two high tide records, one from 0 0 n penelope 4.2 r r 09/11/17 of one bird flushed from northern assemb most off-site fishing ponds and nine birds on lage 09/01/18 from the same area (Figure 12.1.4). Recorded on 5 dates on low tide surveys in Year 1 flushed from the northern fishing ponds off-site. The peak count being 19 on 20/12/17. Year 2: Two birds flushed at low tide on three occasions from the off-site northern fishing pond on 07/12/18, 15/01/19 and 04/03/19 (Figure 12.1.7).

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Englis Scientifi SPA Rams BoCC BoCC WCA Annex E(W) Survey Findings Peak count across Peak count across h c Name Qualify ar 4 3 Sch. 1 A all surveys all surveys Vernac ing Criter Statu (Wale 1 (Birds 2016 excluding records excluding records ular Specie ia s s) Speci Directi Secti outside final red line from within reens Name s es ve) on 7 boundary that will be retained as part of the proposals Teal Anas Article C6 Ambe Ambe - - - Year 1: High tide records of teal were mainly 11 0 crecca 4.2 r r from the off-site northern fishing ponds assemb where low numbers were recorded on three lage occasions with a peak count of five birds on 06/03/18. There was one single record within the Site on a reen in the west of the Site on 09/01/18 (Figure 12.1.12). At low tide there was a peak count of 13 birds on the off-site fishing ponds on the 19/03/18 (Figure 12.1.13). Year 2: There were four high tide surveys where teal were recorded. The peak count being 30 on 13/03/19 associated with the off-site fishing ponds. Eleven birds were also recorded within the Site on the 14/12/18 where they were flushed from ditches in the centre of the Site (Figure 12.1.14). Teal was recorded on two survey visits in Year 2 at low tide; the peak count was 35 birds on 14/02/19 mainly associated with the off-site fishing ponds, but some were also flushed from reens in the north centre of the Site (Figure 12.1.15). Tufted Aythya Article - Green Green ✔ ✔ - Year 1: Three birds were recorded once on 0 0 Duck fuligula 4.2 the northern off-site fishing ponds on assemb 20/10/17 at low tide (Figure 12.1.12). lage Year 2: Not recorded.

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Englis Scientifi SPA Rams BoCC BoCC WCA Annex E(W) Survey Findings Peak count across Peak count across h c Name Qualify ar 4 3 Sch. 1 A all surveys all surveys Vernac ing Criter Statu (Wale 1 (Birds 2016 excluding records excluding records ular Specie ia s s) Speci Directi Secti outside final red line from within reens Name s es ve) on 7 boundary that will be retained as part of the proposals Lapwin Vanellus Article - Red Red - - ✔ Year 1: Lapwing were recorded during four 300 300 g vanellus 4.2 high tide surveys in Year 1 with the peak assemb count being 300 birds feeding and moving lage around in the central area of the site on 09/01/18, the next highest count being 80 birds on 06/02/18 (Figure 12.1.16). At low tide there were far fewer records with lapwing recorded on two survey visits only, with the peak count being 34 birds in centre of the Site on 30/11/17 (Figure 12.1.17). Year 2: Lapwing were recorded on three high tide visits with a peak count of 170 on the 14/12/19 (Figure 12.1.18). During low tide surveys lapwing were recorded on three dates with a peak count of three birds on Site on 04/03/19. Others were recorded flying over the Site. See also Table 12.1.14 for wider area survey. Golden Pluvialis - - Green Red ✔ ✔ A single record in Year 1 of one bird from a 0 0 plover apricaria field in the buffer zone to the west was recorded on 19/03/18. There were no other records of this species.

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Englis Scientifi SPA Rams BoCC BoCC WCA Annex E(W) Survey Findings Peak count across Peak count across h c Name Qualify ar 4 3 Sch. 1 A all surveys all surveys Vernac ing Criter Statu (Wale 1 (Birds 2016 excluding records excluding records ular Specie ia s s) Speci Directi Secti outside final red line from within reens Name s es ve) on 7 boundary that will be retained as part of the proposals Curlew Numeniu Article - Red Red - - ✓ Year 1: Curlew were recorded during high 30 30 s arquata 4.2 tide surveys on two dates: on 06/02/18 five assemb birds were record in a tussocky ungrazed lage and unmown field in the southeast corner of the Site and on the 06/03/2018, 30 birds were recorded in the same field then flew north landing again before flying off northwest (Figure 12.1.16). During low tide surveys one curlew was seen in flight heading east on 30/11/17 (Figure 12.1.17). Year 2: No curlew was recorded during high tide surveys in Year 2. During low tide surveys one bird was seen in the same field as Year 1 in the southeast of the Site on 07/12/18 and four were seen in flight over the same field on the same day (Figure 12.1.19). Redsh Tringa Article C6 Red Red - - - Redshank was only recorded twice over 0 0 ank totanus 4.2 both survey years. During Year 1 a single assemb bird was recorded in flight on 06/02/18 and lage again one in flight on 13/03/18 (Figure 12.1.17). Lesser Larus No C6 Ambe Ambe - - - Recorded regularly on Site and in the buffer 20 20 black- fuscus r r zone during both years either feeding in back- fields or flying over the Site with a peak gull count of 20 birds on 22/02/19. Total 404 358

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5.3 Change in Land Management/ Assessment of Functionally Linked Land

Whether effects are likely to be significant away from the SPA itself largely depends on whether it is considered that the land on Site is ‘functional linked’ to the SPA i.e. whether significant numbers of qualifying or assemblage species from the SPA use the land in question, away from the SPA, for example at high tide.

As a rough rule of thumb ≥1% of a SPA species population or assemblage may be used as a guide to start to assess whether land is likely to be Functionally Linked to an SPA. However, other factors need to be considered, such as frequency of use, type of use, availability of other suitable habitat in the area as well as the numbers of birds using the land. The weight of importance given to each named component species of an assemblage varies. In addition, the land should be demonstrated to be essential to a qualifying species such that it is important in sustaining and maintaining the viability of the European Site population before it can be classed as functionally linked.

5.3.1 Assemblage

The published SPA assemblage as a whole amount to 84317 waterfowl (5-year peak mean 1991/2 - 1995/6)5. Taking the peak count of all assemblage species recorded (excluding lesser black-backed gull which are not an assemblage species) within the application area over the two-year period this amounts to 384 birds this equals 0.46% of the Severn Estuary SPA Assemblage. This figure falls below the 1% threshold and therefore the application site is not considered to be functionally linked and is considered of Local importance to the assemblage.

5.3.2 Individual Species

The following Table 3 gives the percentage of the Severn Estuary internationally and nationally important populations of the main component assemblage species recorded on Site. The Article 4.1. qualifying species Bewick’s swan, greater white-fronted goose, dunlin, redshank and gadwell were not recorded on Site during any surveys. The data presented has been updated to reflect a revised redline boundary for the scheme.

Table 3: SPA populations of individual species recorded on Site and their percentage of the SPA population

Qualifying Peak Published Latest Percentage Percentage Notes Assemblage Count Severn 5-year of of Latest Species on Site Estuary Averag Published Average (revised Population e SPA Population Population red line) (based on Popula on Site (%) on Site (%) 5-year Av. tion7 1991/92- 95/966 ) Shelduck 8 3333 4450 0.2 0.5 Field 48 Mallard 35 3162 2440 1.1 1.4 Exclusively using the reens. Teal 11 3270 5374 0.3 0.2 Exclusively using the reens.

5 Natural England (2015) Natura 200 Standard Data Form UK: 9015022 Severn Estuary. 6 JNCC (2016) Natura 2000 Standard Data Form - Severn Estuary UK9015022. 7 Frost, T.M., Austin, G.E., Calbrade, N.A., Mellan, H.J., Hearn, R.D., Robinson, A.E., Stroud, D.A., Wotton, S.R. and Balmer, D.E. (2019), Waterbirds in the UK 2017/18: The Wetland Bird Survey. BTO/RSPB/JNCC. Thetford.

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Qualifying Peak Published Latest Percentage Percentage Notes Assemblage Count Severn 5-year of of Latest Species on Site Estuary Averag Published Average (revised Population e SPA Population Population red line) (based on Popula on Site (%) on Site (%) 5-year Av. tion7 1991/92- 95/966 ) Lapwing 300 8636 10541 3.5 2.8 Central site. Curlew 30 4009 3571 0.7 0.8 Field 48 in SE of Site. Total 404

Table 3 shows only one species which fits the criterion of ≥1%: Lapwing which used the site regularly.

Shelduck (Article 4.2 Species)

Shelduck had a peak count of 8 and was only recorded during winter transect surveys on two occasions in year 2 but not in year 1. Associated with the off-site fishing ponds or fields close by. This represents 0.2% of the 5-year average population (4450) for the Severn Estuary These records and the lack of other records, suggests the application area is not used with any regularity and with the fishing ponds and adjacent fields being retained. The application area is considered not likely to be functionally linked land for this species and therefore no likely significant effects to this species are anticipated.

Lapwing (Assemblage Species)

Lapwing were recorded through the winter period in both years, a peak count of 300 (09/01/18) was recorded on one occasion with the next highest count being 170 (14/12/18), they were recorded on the ground foraging on Site on seven survey occasions during the two year period over a total of 20 survey visits (October to February Inc.) (Table 4).

Table 4: Dates and peak numbers of lapwing recorded over two winters survey

Date Peak No. lapwing 09/11/17 7 30/11/17 34 09/01/18 300 06/02/18 80 22/02/18 1 11/10/18 1 14/12/18 170 Other species

Other assemblage species namely wigeon, mallard, tufted duck and teal were recorded in relatively low numbers and were mainly associated with the off-site fishing ponds and reens which are all being retained or are outside the red line boundary and these features will still be available to be used by wildfowl post development. The fields immediately surrounding the fishing ponds are not in the scheme and will remain. There will be grassland buffer zones of at least 7-12.5m buffers around ditches and reens respectively, therefore if some species e.g. wigeon wish to graze there will be suitable habitat available to them.

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5.3.3 Conclusion

Taking account of the records on Site discussed above, it is considered that the number of assemblage species (particularly main component species) using the Site is low and numbers and frequency of records are also very low with the exception of lapwing for which a de minimis effect (an effect that is more than not appreciable) is predicted in the absence of mitigation/compensation. Wildfowl species using the fishing ponds and reen system are not anticipated to be adversely impacted by the proposed development as these habitats are to be retained and will still be available to these species. It is considered that the Site does not qualify as functionally linked land for the Article 4.2 birds, or the assemblage as a whole.

Therefore, the change in land management from grazing to solar will not result in a likely significant effect on the integrity of the SPA.

5.4 Changes in Species Distribution/ Disturbance to SPA Assemblage Species

It should be noted that this Site is already quite disturbed in a number of ways:

Normal agricultural practice; The main line railway immediately north of the Site; Regularly low flying helicopters; Model aircraft club who currently fly from a field in the west of the Site.

It is considered that birds that currently use the Site have become accustomed to these sources of disturbance to some degree.

5.4.1 Potential Impact

Construction/Decommissioning

There is a potential for disturbance to SPA birds using the Site particularly at high tide, during the construction or decommissioning period by uses of machinery and human presence on Site, which may interrupt feeding patterns and available feeding time during high tide periods or interrupt roosting behaviour.

However, the design intervention, ground conditions and practicalities of building dictates that the majority of construction/decommissioning works would commence in March and would continue into the Autumn for a period of 8-9 months, thus avoiding most of the time when SPA wintering populations are present in the area. There will be a requirement for some enabling works over the preceding winter period which will involve some hedgerow removal and the installation of new reen crossing points where necessary or reinforcing existing ones where needed. This activity is likely cause temporary localised disturbance in some areas of the Site.

Operation

There is unlikely to be any significant disturbance to birds during operation as maintenance visits will be infrequent and generally involve one of two engineers arriving on site in a van. This is considered likely to be less disturbance than current agricultural practices.

5.4.2 Mitigation

As most of the construction period is outside the winter period minimal mitigation is required. However, during the enabling works over the preceding winter activities such as hedgerow removal will be restricted to working in one area at a time to minimise disturbance.

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5.5 Loss of Winter Foraging Habitat for Lapwing

5.5.1 Potential Impact

Operation

It has been assessed that there is a potential for de minimis LSEs on the SPA assemblage species lapwing that use the Site, particularly at high tide periods due to the loss of winter foraging habitat caused by the introduction of solar panels into the fields. However, it is considered unlikely that the land is functionally linked to the SPA. Although there will be 7m and 12.5m margins around solar fields and rides through the solar arrays, it is considered that this will make them unlikely to be used by certain species of wading birds, in particular lapwing which prefer more open fields to forage. The solar fields will be effectively lost as a foraging habitat for lapwing. During wider area surveys (up to approximately 2km) conducted in the winter of Year 2 specifically to look for lapwing using the wider area, birds were recorded on seven dates ranging from 1-45 and at distances of 400m to 1.2km from the Site boundary. In addition, during vantage point survey numerous lapwing were recorded flying over the site heading in all directions (ES Appendix 12.3) presumably to feeding grounds further afield at high tide especially. Given the amount of other similar habitat available to lapwing in the area, the Site fields are not considered crucial in sustaining and maintaining the viability of the European Site population, although they clearly are used and represent some importance to this species.

5.5.2 Mitigation

Following the precautionary principal compensation land will be provided for wintering lapwing. Twenty Two hectares (ha) of additional land has been secured belonging to one of the participating landowners in the solar scheme. This land will be managed for lapwing and is located directly west of the application site. Management will include hedge and tree removal along reens and ditches to create a more open landscape, rush management, stocking levels and grazing will be also be managed to benefit lapwing. Details of management will be provided in a lapwing management plan.

5.6 Siltation and Dust (SAC & SPA)

5.6.1 Potential Impact

Construction and Decommissioning

The risks of siltation, dust pollution or fuel/chemical spill during construction and decommissioning are considered to be of very low risk. This is due to the 7m and 12.5 m buffer zones which are incorporated around reens and ditches as part of the inherent design. However, some operations such as hedge cutting and new crossing point installation will take place prior to construction where there is an increased risk of minor pollution incidents.

If an accidental pollution event or siltation was to occur, it is likely to be small, very localised and isolated and even if siltation managed to get from the reen and ditch system into the SPA/SAC via the reen network this is highly unlikely to be a significant effect on the Natura sites, as the river and estuarine system itself moves and deposits huge quantities of silt as part of its natural processes and the addition of small amount of additional silt would have negligible effect on the protected sites alone or in combination.

Operation

Regular annual/biannual hedge cutting would take place and regular ditch and reen management that already takes place on major reens and ditches on Site by NRW will be extended to reens where the southern side of double hedgerows has been removed as part of enhancement measures to the SSSI. Again, this risk is considered to be low.

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Mitigation

In addition to the inherent 7m and 12.5m buffers which will be maintained to allow the management of ditches and reens a Construction and Environmental Management Plan (CEMP) will be implemented, which will include:

The Environment Agency Pollution Prevention Guidelines 5: Works and Maintenance in or Near Water (2007) and Pollution Prevention Guidelines 6: Working at Construction and Demolition Sites (2012). Such measures include:

Reducing the need for dewatering through the prevention of water entering excavations; Minimising the amount of exposed ground and soil stockpiles; The use of silt fences at the base of stockpiles; and Plant and wheel washing in designated areas as appropriate.

These measures will also be incorporated into methods statements for operational activities such as hedge cutting and ditch and reen management.

Herbicides used in weed control and hedgerow removal will be carefully controlled using spot treatments using e.g. non drip weed sticks and ‘Ecoplugs’ to deliver herbicide. These will be used under method statement with the appropriate ‘high risk’ licence from NRW in place.

5.7 Water Pollution – Impacts to European Eel in Freshwater Environment

The effects to European eel are only likely to be from siltation and pollution during construction and decommissioning as discussed above. Mitigation applied would minimise the risk of any LSEs to this species.

6 CUMULATIVE ASSESSMENT

In-combination effects have been assessed in relation to other major developments within the catchment of the River Severn and within 10km of the Natura 2000 sites. The proposals and plans that have been considered are as follows:

Môr Hafryn Energy Recovery Site Rush Wall Solar Park Gwent Levels Farmers Community Solar Scheme Llanwern Rail Facilities Hendre Lakes Môr Hafren Energy Recovery Facility:

Located approximately 4km south west of the Wentlooge Renewable Energy Hub site, the forthcoming application (DNS/3236340) Environmental Statement for Môr Hafren is not yet available to review. This Site received planning permission in 2009 (09/00246/E) to include an advanced waste treatment plant. The ES submitted (Sterecycle UK Ltd, 2009)8 found no significant impacts to ecological receptors during operation and no residual effects were reported. There were some potential construction impacts relating

8 Sterecycle UK Ltd (2009), Cardiff Waste Treatment Facility Environmental Statement, Chapter 7: Ecology, and Nature Conservation, Sterecycle UK Ltd

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to grass snakes and appropriate mitigation was recommended. Ecological surveys were updated in 2014 which concluded no significant change (Golder Associates, 2014)9.

Given the ecological habitats on this site identified from existing surveys (mainly successional scrub and grassland) and those at the Wentlooge Renewable Energy Hub being very different it is predicted that there is unlikely to be any significant in-combination effects to features of the Severn Estuary protected sites.

Rush Wall Solar Park:

This proposed solar scheme is located approximately 14km east near Redwick on the Gwent levels. The Site is within the Gwent levels SSSI – Redwick and Llandevenny and is within the zone of influence to five other Gwent Levels SSSIs. It is proposed to cover an area of approximately 100ha.

The ES is not yet available to review however the scoping report details the potential ecological features and the suite of surveys proposed which include surveys for bird species associated with the SPA/Ramsar Site

The site has similar ecological features to the Wentlooge renewables site.

Without the ES we cannot fully assess the cumulative impacts of this scheme, however if impacts are similar to those assessed in this application and if consented, it would result in the change of land use of potentially a further 100ha of coastal grazing marsh on the Gwent Levels, which may effect qualifying or assemblage species from the Severn Estuary protected sites.

Gwent Farmers’ Community Solar Scheme (GFCSS) Llanwern (DNS Ref. 3213968):

This project is approximately a 143ha solar farm with consent for 49MW south of the Llanwern steel works. The site is similar to Wentlooge in many ways as it is all on Gwent Levels SSSI and has similar notified habitats and species.

Two years of ornithological surveys and a suite of other ecological surveys was undertaken at this site.

The following Table 5 contains a summary of the LSEs taken from the GFCSS HRA screening report (Savills, 2017) included in the application for this Site.

Table 5: Summary Table of Likely Significant Effects In-Combination with GFCSS

SPA/ SAC/ Alone (GFCSS) In combination with Ramsar Wentlooge Feature Possible Significance Possible Significance Effect? Effect? Estuaries No. No direct N/A None N/A land take and no alteration in hydrology Mudflats and No. No direct N/A None N/A sandflats land take and no alteration in hydrology

9 Golder Associates (2014), Permitted Waste Treatment Facility, Newlands Road Wentlooge: Updates to Environmental Statement: Ecology and Nature Conservation, Golder Associates (UK) Ltd.

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SPA/ SAC/ Alone (GFCSS) In combination with Ramsar Wentlooge Feature Possible Significance Possible Significance Effect? Effect? Sandbanks No. No direct N/A None N/A land take and no alteration in hydrology Atlantic salt No. No direct N/A None N/A meadows land take and no alteration in hydrology Reefs No. No direct N/A None N/A land take and no alteration in hydrology Bewick’s Yes. Loss of Not Significant. None Not Significant. Swan supporting Not recorded Not recorded habitat on site, site not on site considered important. important supporting habitat for SPA population White fronted Yes. Loss Not Significant. None Not Significant. goose potential of Not recorded. Not recorded supporting on site habitat important Shelduck Yes. Loss of Not Significant. None Not suitable Not recorded in Significant., breeding significant Not recorded in habitat numbers, significant Single pair numbers, Low recorded but no numbers evidence of recorded but no breeding no evidence of considered breeding; not significant considered proportion of significant SPA population proportion of SPA population Gadwall No, Reen 1% of SPA as a None Not Significant. habitats and single breeding Not recorded margins to be pair recorded, on site retained and No winter important. managed records. Not significant. Waterbird Yes. Loss of Not Significant. In Not significant, assemblage supporting Total number of combination total number of habitat waterfowl with waterfowl recorded using Wentlooge recorded using the site less (404 peak the site less than 1% of SPA count) = than 1% of SPA assemblage 0.68% of SPA assemblage. (0.2%). assemblage Site not population. considered important in maintaining SPA assemblage Sea Lamprey No. No direct N/A None N/A land take and

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SPA/ SAC/ Alone (GFCSS) In combination with Ramsar Wentlooge Feature Possible Significance Possible Significance Effect? Effect? no alteration in hydrology River lamprey No. No direct N/A None N/A land take and no alteration in hydrology Twaite shad No. No direct N/A None N/A land take and no alteration in hydrology Allis Shad No. No direct N/A None N/A land take and no alteration in hydrology Salmon No. No direct N/A None N/A land take and no alteration in hydrology Sea trout No. No direct N/A None N/A land take and no alteration in hydrology European Eel No. No direct N/A None N/A land take and no alteration in hydrology

Construction/Decommissioning effects on both the Wentlooge and the Gwent Farmers’ Community Solar scheme are considered of a temporary nature and any land damage will be restored post construction. Siltation and pollution events are considered to be minimal and were screened out at the HRA stage for GFCSS and are considered to be low risk and if they occurred would be small and localised at Wentlooge. As the GFCSS Site is already consented and construction has started, there is no likely chance of overlap during the construction periods of both sites therefore cumulative effects on the integrity of the SPA and SAC are considered highly unlikely.

The Gwent Levels Farmer’s scheme and the Wentlooge application combined will result in the loss of approximately 155ha of grassland habitat which will be no longer available to bird species associated with the Severn Estuary and Ramsar site. However, surveys at both sites have shown that very low numbers of SPA species use the GFCSS Site with most birds being recorded outside the application area. The GFCSS Habitat Regulations Screening Report (Ecus/Green Ecology, 2017) concluded that there were no LSEs to the Severn Estuary SPA or SAC and did not consider Appropriate Assessment necessary.

The only feature of the SPA assemblage at Wentlooge that may be considered in combination is wintering lapwing as part of the SPA assemblage population and as wintering lapwing were mainly recorded outside the application area at GFCSS (max count in application area 54), the in-combination effects are considered to be negligible. Particularly when considering the compensation land provided at both sites to be managed for lapwing totalling 32ha which is/will be presented in their respective Lapwing Management Plans.

Overall, it is considered that there are no significant in combination effects between the Gwent levels Farmers’ Community Solar Scheme and Wentlooge Farmers’ Solar Scheme.

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Llanwern Rail Facilities:

The proposal (planning ref. 18/1109) was granted approval by the Newport City Council in January 2019. The approved development involves:

“….. the construction of 1.6km of rail formation in connection with the stabling of trains including associated engineering and landscape works on land adjacent to the existing Tata Steelworks service lines in Newport, Wales” The site is located approximately 10km to the north east of the Wentlooge Farmers’ Solar Scheme and 5km inland from the Severn Estuary Natura 2000 sites. It comprises a linear strip of land aligned roughly east - west supporting a mixture of scrubland and woodland. It is bordered by the existing South Wales Mainline to the north and the Tata Steelworks to the south.

A broad range of ecological surveys and assessments were undertaken in 2017 and 2018 to inform the planning application. An Ecological Impact Assessment and Habitat Regulations Assessment (Stage 1 Screening Report) (Mott McDonald 2018) accompany the application. The HRA considers a number of designated sites but does not screen in the Severn Estuary Natura 2000 sites for assessment.

The habitats which the site supports are unsuitable for over wintering birds and no pathways for adverse effects on the integrity of the Severn Estuary have been identified. It is considered that the site does not comprise land that is functionally linked to the Severn Estuary and the potential for in-combination effects to occur is considered to be negligible.

Hendre Lakes:

This site is allocated for employment development in the Cardiff Local Development Plan but at the time of writing this application has not been submitted. The development proposals consist of:

“Construction of a business park (up to 90,000m2 - Use Classes B1, B2 and B8), ancillary uses and infrastructure associated with; biodiversity; landscape; drainage; walking, cycling and other transport modes. Together with the construction of a new transport hub facility, comprising railway station buildings (up to 2,500m2 – Use Class Sui Generis) including ancillary uses); 4 no. platforms; surface car park (up to 650 no. spaces) and associated infrastructure works, at land to the south of St Mellons Business Park.”

The Hendre Lakes site lies approximately 1.5km to the west of the Site and comprises undeveloped farmland on the Gwent Levels. The site contains a reen system, formed of artificial drainage channels, historically used to drain the land in the surrounding Gwent Levels. The South Wales Main Line (railway) bisects the site.

A suite of ecological surveys and assessments have been undertaken between 2017 and 2019 to inform the intended planning application. An Environmental Statement including a biodiversity chapter (Chapter 7) has been produced accompanied by a series of technical reports and a Shadow Habitat Regulations Assessment (ARUP, 2020).10

The Severn Estuary Natura 2000 sites were screened into Appropriate Assessment due to the pathway for effect arising from being hydrologically connected to and lying downstream of the proposed development site. The following potential adverse effects on the integrity of the designated sites were identified; habitat degradation, in the form of dust deposition, pollution events, sediment runoff, changes in air quality, and the spread of INNS; habitat loss/severance; physical disturbance/damage of habitats for

10 https://www.cardiffhendrelakes.com/document-library/

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which qualifying features rely on; disturbance/displacement to qualifying fauna and mortality/injury of individuals.

Winter Bird Surveys (Arup, 2017-2018) were undertaken and did not record any species listed as qualifying features of the Severn Estuary SPA or Ramsar site. A total of 21 ‘target’ bird species were recorded and as waterfowl, were considered ecologically dependent on wetlands and thus contributing to the assemblage feature qualification of both the Severn Estuary SPA and Ramsar. A peak count of 659 target birds was recorded, representing 0.70% of the SPA assemblage population. Therefore, and as less than the 1% threshold of the winter bird assemblage the Site is not considered to be functionally linked land and alone is not considered to be of significance to maintaining the integrity of the Severn Estuary SPA.

The Shadow Habitat Regulations Assessment (ARUP, 2020) concludes that;

The information to inform the Appropriate Assessment considered effects in relation to the conservation objectives for the qualifying features of the International Sites and identified suitable mitigation measures. These measures along with the proposed monitoring are considered sufficient to ensure that the construction and operation of the proposed development do not, either alone or in-combination with other plans or projects, give rise to any adverse effects on the integrity of the International Sites.

The peak count of identified ‘target’ species during the Hendre Lakes Winter Bird Surveys (Arup, 2017- 2018) was 659 in February 2018 which included a peak count of 587 black-headed gull of which 150 were recorded outside the redline boundary to the south west and 87 which were recorded on Hendre Lake (retained by the proposals). However, all gull species are excluded from the Severn Estuary assemblage and therefore the Hendre Lakes sHRA has incorrectly included black-headed gull as a ‘target species’ which has been used to calculate percentages in relation to supporting SPA assemblage population.

Excluding the counts for black-headed gull, the peak count of target species during the Hendre Lakes Winter Bird Surveys (Arup, 2017-2018) was 333 in December 2017. This count includes 235 golden plover recorded overflying the site and therefore should not have been considered to be using the site as land functionally linked to the SPA. As a percentage of the overall SPA assemblage population a peak count of 333 equates to 0.39%. In-combination with the peak count from Wentlooge (0.46%) this represents a peak count in combination of 0.85% of the total SPA population, which is below the 1% threshold at which land can be considered functionally linked to the SPA.

The following Table 6 contains a summary of potential LSEs specifically in relation to the SPA assemblage for which a potential in-combination effect has been identified (Correspondence dated 07/12/2020 - NRW ref. CAS-125224-Z4J1).

Table 6: Summary Table of Likely Significant Effects on SPA Assemblage In-Combination with Hendre Lakes

SPA/ SAC/ Alone (Hendre Lakes) In combination with Ramsar Wentlooge Feature Possible Significance Possible Significance Effect? Effect? Waterbird Yes. Loss of Not Significant. In Not significant, assemblage supporting Total number of combination total number of habitat waterfowl with waterfowl recorded using Wentlooge recorded less the site less (0.46% + than 1% of SPA than 1% of SPA 0.39%) = assemblage. assemblage 0.85% of SPA Sites not 0.39% assemblage considered population important in maintaining

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SPA/ SAC/ Alone (Hendre Lakes) In combination with Ramsar Wentlooge Feature Possible Significance Possible Significance Effect? Effect? SPA assemblage resulting in LSE in-combination.

Overall, it is considered that both sites when considered alone and in-combination will not give rise to adverse effects on the integrity of the Severn Estuary Natura 2000 sites following implementation of appropriate mitigation and monitoring.

7 OVERALL ASSESSMENT

Considering all aspects of any potential impacts this report concludes that there are no LSEs alone or in- combination to the Severn Estuary Natura 2000 sites caused by this proposed solar development. The one possible LSE is loss of habitat to numbers of wintering lapwing (as part of the assemblage) that use the Site and although it is considered that the Site is not functionally linked to the SPA, large numbers do occasional use the Site and therefore the precautionary principle has been observed and compensation has been recommended that is considered to reduce the potential for likely significant effects on the integrity of the Severn Estuary Natura 2000 sites to a non-appreciable and non-significant level. The potential for in-combination effects with other plans and projects has been assessed and no in-combination effects have been identified.

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8 REFERENCES

Savills (2017) Gwent Farmers’ Community Solar Scheme – Habitats Regulations Assessment

Savills (2019) Wentlooge Renewable Energy Hub, Environmental Statement, Savills, Taunton.

Planning Inspectorate (2019) DNS: EIA Scoping Direction 3223413 - Llanwern Rail Facilities.

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Appendix 1 – Location of Natura 2000 sites in relation to application site

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Appendix 2 – The qualifying interest features and supporting habitats of the Severn Estuary SPA11.

Original SPA SPA Review Natura 2000 form Species Notes Supporting habitats citation (1995) *1 (2001) *2 (2006) *3 Internationally important populations of regularly occurring Annex 1 species [under Article 4.1 of the EU Birds Directive]. Intertidal mudflats and SPA interest feature 1: sandflats Bewick’s swan Cygnus columbianus bewickii ✓ ✓ ✓ Over-wintering Saltmarsh Internationally important populations of regularly occurring migratory bird species [under Article 4.2 of the EU Birds Directive]. SPA interest feature 2: European white-fronted goose ✓ x ✓ Intertidal mudflats and Anser albifrons albifrons sandflats SPA interest feature 3: Dunlin Calidris alpina alpina ✓ ✓ ✓ Saltmarsh Hard substrate habitats SPA interest feature 4: Redshank Tringa totanus ✓ ✓ ✓

Over-wintering SPA interest feature 5: Shelduck Tadorna tadorna ✓ ✓ ✓ (Freshwater coastal grazing SPA interest feature 6: Gadwall Anas strepera ✓ x ✓ marsh, improved grassland and open standing waters Curlew Numenius arquata x ✓ x also occur within the SPA but these habitats lie Pintail Anas acuta x ✓ x outside EMS boundary) Ringed plover Charadrius hiaticula x ✓ x On passage SPA interest feature 7: Internationally important assemblage of waterfowl (wildfowl & waders) [under Article 4.2 of the EU Birds Directive]. Bewick’s swan Cygnus columbianus bewickii The wintering waterfowl assemblage includes Intertidal mudflats and ✓ ✓ all regularly occurring waterfowl. Species that sandflats European white-fronted goose Anser albifrons ✓ ✓ qualify as a listed component of the Saltmarsh albifrons assemblage include all the internationally The Natura 2000 Hard substrate habitats important regularly occurring migratory species Dunlin Calidris alpina alpina ✓ ✓ data form does not as well as the Annex 1 wintering species. The list separate Redshank Tringa totanus ✓ ✓ list also includes species present in nationally waterfowl species (Freshwater coastal grazing important numbers or species whose Shelduck Tadorna tadorna ✓ ✓ within this marsh, improved grassland populations exceed 2,000 individuals assemblage. and open standing waters Gadwall Anas strepera ✓ ✓ also occur Within the SPA

11 Natural England & The Countryside Council for Wales (2009) The Severn Estuary/Môr Hafren European Marine Site, comprising: The Severn Estuary SPA, The Severn Estuary SAC, The Severn Estuary Ramsar Site, Natural England & The Countryside Council for Wales advice given under Regulation 33(2) (a) of the Conservation (Natural Habits,&c) Regulations 194, as amended. NE & CCW Peterborough & Cardiff.

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Original SPA SPA Review Natura 2000 form Species Notes Supporting habitats citation (1995) *1 (2001) *2 (2006) *3 Wigeon Anas penelope ✓ ✓ In the original citation, in winter, it is stated that but these habitats lie The area regularly supported 68,026 individual outside EMS boundary) Teal Anas crecca ✓ ✓ waterbirds *4. In the SPA Review it is stated that the area regularly supports 93,986 Pintail Anas acuta ✓ ✓ individual waterfowl in winter *5. In the Natura Pochard Aythya ferina ✓ ✓ 2000 form, in winter, it is stated that the area regularly supports 84,317 waterfowl *6. Tufted duck Aythya fuligula ✓ ✓ Ringed plover Charadrius hiaticula ✓ x Grey plover Pluvialis squatarola ✓ ✓ Curlew Numenius arquata ✓ ✓ Whimbrel Numenius phaeopus ✓ ✓ Spotted redshank Tringa erythropus ✓ x Lapwing Vanellus vanellus x ✓ Mallard Anas platyrhynchos x ✓ Shoveler Anas clypeata x ✓

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