Electricity Act 1989 the Mid Wales (Powys) Wind Farms

MID-WALES CONJOINED WIND FARM INQUIRY SESSION 1: STRATEGIC SEARCH AREA C

LANDSCAPE PROOF OF EVIDENCE PG Russell-Vick DipLA CMLI on behalf of Powys County Council

September & October 2013

CONTENTS PAGE

1.0 Qualifications and Experience 1

2.0 Scope of Evidence 3 3.0 Landscape Context ELECTRICITY 8 ACT 1989 4.0 Landscape Related Planning Policy Context 17 5.0 Llandinam Repowering 23 6.0 Llaithddu 28 THE MID WALES (POWYS) WIND FARMS PUBLIC INQUIRY 7.0 Llanbadarn Fynydd 35 8.0 Cumulative Effects 41

9.0 Summary and Conclusions 46 The Electricity Generating Stations and Overhead Line (Inquiries Procedure) APPENDICES (provided under separate cover) (England and Wales) Rules 2007

Appendix A Figures (see below) Appendix B Receptor Visual Sensitivity Criteria Appendix C Visual Impact Assessment Criteria SESSION 2: SSA B Appendix D Visual Impact Assessment Table: Llandinam Repowering Appendix E Landscape Impact Assessment Tables: Llandinam Repowering Appendix F Visual Impact Assessment Table: Llaithddu Appendix G PROOFLandscape OF Impact EVIDENCE Assessment ON Tables: LANDSCAPE Llaithddu AND VISUAL MATTERS Appendix H Visual Impact Assessment Table: Llanbadarn Fynydd

Appendix I Landscape Impact Assessment Tables: Llanbadarn Fynydd

Appendix J Cumulative Visual Impact AssessmentBy TablePHILIP RUSSELL-VICK DipLA CMLI Appendix K Cumulative Landscape Impact Assessment Tables Appendix L Sequential Cumulative Visual ImpactOn behalf Assessment of POWYS Table COUNTY COUNCIL

FIGURES (in Appendix A)

Figure PRV1 Topography OCTOBER-NOVEMBER 2013 Figure PRV2 Stylised Sections Figure PRV3 TAN 8 Boundaries, Turbine and Viewpoint Locations

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MID-WALES CONJOINED WIND FARM INQUIRY SESSION 2: STRATEGIC SEARCH AREA B

LANDSCAPE PROOF OF EVIDENCE PG Russell-Vick DipLA CMLI on behalf of Powys County Council

October & November 2013

CONTENTS PAGE

1.0 Qualifications and Experience 1 2.0 Scope of Evidence 3 3.0 Landscape Context 12 4.0 Landscape Related Planning Policy Context 21 5.0 Carnedd Wen and Llanbrynmair Overview Assessment 27 6.0 The Five Carnedd Wen North-Eastern Turbines 35 7.0 The Llanbrynmair Local Highway Proposals 39 8.0 Conclusions 45

APPENDICES (provided under separate cover)

Appendix A Figures (see below) Appendix B Receptor Visual Sensitivity Criteria Appendix C Visual Impact Assessment Criteria Appendix D Visual Impact Assessment Table: Carnedd Wen Appendix E Landscape Impact Assessment Tables: Carnedd Wen Appendix F Visual Impact Assessment Table: Llanbrynmair Appendix G Landscape Impact Assessment Tables: Llanbrynmair Appendix H Relevant LANDMAP VSAAs

FIGURES (in Appendix A)

Figure PRV1 Topography Figure PRV2 TAN 8 Boundaries, Turbine and Viewpoint Locations Figure PRV3 Carnedd Wen: PCC Viewpoints 1 & 2 Figure PRV4 Carnedd Wen: PCC Viewpoint 3 & 4 Figure PRV5 Carnedd Wen: Wireframe from Viewpoint U A458 X B4395 Llangadfan Figure PRV6 Carnedd Wen: Wireframe from Viewpoint V Glyndŵr’s Way near B4395

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Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

Figure PRV7 Carnedd Wen: Wireframe from Viewpoint W A458 Figure PRV8 Carnedd Wen: Wireframe from Viewpoint Z Foel Figure PRV9 Llanbrynmair: Nant yr Eira Valley photographs Figure PRV10 Llanbrynmair photographs: Neinthirion and Gosen Bridge photographs Figure PRV11 Photograph of the proposed PCC valley crossing

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

1.0 QUALIFICATIONS AND EXPERIENCE

1.1 I am Philip Russell-Vick, a Director of Enplan, landscape, planning and environmental consultants. I hold a Diploma in Landscape Architecture and I am a Chartered Member of the Landscape Institute. I have over twenty-five years of experience in landscape planning and landscape architecture and have provided consultancy advice on a wide range of residential, commercial, industrial, mineral and other development projects throughout the UK and overseas.

1.2 I formed Enplan in December 2000. We offer consultancy advice in fields of landscape architecture, environmental and planning. My landscape and visual impact assessment work has included proposals for the Medway Cement Works and chalk quarry adjoining the North Downs AONB, mixed use redevelopment proposals for the former Shoreham Cement Works in the former Sussex Downs AONB, the 2010 Ryder Cup Golf Course project at the Celtic Manor Resort in South Wales, various major green and brown field residential development projects in the south-east, east and north-east of England, flood defence projects in Oxford, London, Dorset and Somerset, telecommunication developments in The Gower Peninsula AONB, Cornwall AONB, Exmoor and Dartmoor National Parks and the Sussex Downs AONB, various on and offshore wind farm proposals, mainly in Lincolnshire and Nottinghamshire, and a large solar farm in the New Forest National Park. My landscape design experience includes a new visitor’s centre for Sir Edwin Lutyens’ WWI ‘Memorial to the Missing’ at Thiepval on the Somme, various historic landscape restorations of Repton, Marnoch, Jekyll and Paxton parks and gardens, a British Construction Industry award winning flood defence project at Weymouth and a proposed 6* hotel and leisure complex at Mentmore Towers in Buckinghamshire.

1.3 Prior to forming Enplan I worked in private practice for seventeen years, during which time I worked on a wide range of projects. Significant infrastructure schemes included the M25 widening J12-15, A1(M) improvements at Peterborough, BAA projects at Heathrow, Gatwick and Stansted and on-shore oil exploration schemes. Development projects included green and brownfield residential schemes, urban regeneration projects in London, south and north Wales and Northern Ireland and urban expansion masterplans. I also worked on several major quarrying and waste disposal schemes as well as flood alleviation projects including the Jubilee River on the Thames. I prepared best practice guides and strategies for various Government agencies and 4

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

for the Highways Ministry of Hong Kong and I led the design of and was responsible for the implementation of public spaces and parks, including five new urban parks in Kuwait City.

1.4 I have given evidence at a number of major public inquiries such as the Medway Cement Works Call-in inquiries, ‘SnOasis’, promoted as the UK’s the largest indoor winter sports complex near Ipswich, the South Downs National Park Inquiry, redevelopment of the former hospital at Leybourne Grange in Green Belt, 850 dwellings at Bromley also in Green Belt, a scheme for 750 houses at Uckfield, East Sussex, as well as several wind farm inquiries including Crow Holt Wind Farm at Grove, Nottinghamshire, The Grange Wind Farm, Orby Marsh Wind Farm and Gayton le Marsh Wind Farm proposals, all in Lincolnshire, and Asfordby Wind Farm in Leicestershire.

1.5 Enplan was appointed by Powys County Council in April 2013 to advise the authority on landscape and planning policy matters in connection with this inquiry and various other wind farm applications they have received both within and outside Strategic Search Areas B & C (SSAs). My co-Director Martin Carpenter will deal with planning matters. My specific role since this time has been to review the past stages of work of the Council and their consultants but to form my own overview of the many and significant landscape and visual issues raised and to advise the Council afresh in advance and in preparation for the inquiry. I am familiar with the landscape character of this part of Wales and of the landscape that forms the context of SSA B and I have visited it on several occasions in preparing for the inquiry.

1.6 I understand my duty to the Inquiry and have complied, and continue to comply, with that duty. I confirm that this evidence identifies all facts which I regard as being relevant to the opinions that I have expressed and that the Inquiry’s attention has been drawn to any matters which would affect the validity of those opinions. I believe that the facts stated within this proof are true and that the opinions expressed are correct.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

2.0 SCOPE OF EVIDENCE

2.1 This second session of the Public Inquiry concerns applications for the development of two wind farms at Carnedd Wen and Llanbrynmair together with associated ancillary infrastructure, as follows but subject to various amendments:

 An application by RWE NPOWER RENEWABLES LIMITED DATED 11th December 2008 for consent under section 36 of the Electricity Act 1989 to construct and operate a 150MW Wind Turbine Generating Station (Carnedd Wen – application no. BERR/2009/0001); and  An application by RES UK & IRELAND LIMITED DATED 27th March 2009 for consent under section 36 of the Electricity Act 1989 to construct and operate a 100MW Wind Turbine Generating Station (Llanbrynmair – application no. BERR/2009/0004).

2.2 Subsequent to the 2008 application the Environmental Statement for the Carnedd Wen scheme was supplemented in 2009 (addressing cumulative issues), in 2011 (addressing landscape, ecology, grid connection and felling issues and reducing the number of turbines from 65 to 50) and in 2013 (addressing ecology and mitigation/enhancement and phasing measures). The scheme before the Inquiry is for 50 number turbines, up to a maximum of 137m high to tip with an indicative hub height of 90m, 3MW machines, with an installed maximum capacity of up to 150MW. The associated infrastructure would include 16.99km of new site tracks and 26.99km of upgraded existing tracks, upgrading of the site access from the A458, a control building and substation, two 90m high met masts, underground cabling, together with a Habitat Restoration Scheme.

2.3 The 2009 application for Llanbrynmair was supported by an ES. This was for 43 2.3MW turbines. Supplementary Environmental Information was submitted in 2010 (addressing cumulative landscape, ecology and cultural heritage issues), in 2011, (addressing ecology, cultural heritage, landscape, noise, grid routing and habitat management issues and reducing the scheme from 43 to 34 turbines), in 2012 (infrastructure design, hydrology, landscape/visual – particularly in relation to the highway works, ecology, socioeconomic and noise issues) and in 2013 (an overarching document bringing together all of the various ES and SEI information and

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

effectively superseding the earlier assessments). The scheme before the Inquiry is for 30 turbines of a maximum tip height of 126.5m with a capacity of between 2MW and 3MW per machine providing an installed capacity of between 60MW and 90MW. The ancillary infrastructure would include one met mast, a control building and substation, underground cabling, new and improved site tracks and the local highway proposals to the Llanerfyl to Talerddig road.

2.4 My evidence for this Public Inquiry concentrates upon the landscape and visual impacts of the proposals and by way of introduction to each site specific section of the proof I set out my general views about the acceptability of much of the respective schemes in landscape and visual terms both individually and cumulatively. Specifically my evidence relates to Powys County Council’s objections, in particular upon the character and qualities of the Banwy Valley and the Nant yr Eira Valley, and the visual effects on a range of publicly accessible viewpoints, as follows:

 To the Carnedd Wen proposal in respect of the five north-easternmost turbines (nos. R23, R26, R28, R29 and R30) and the landscape and visual impact these would have on the landscape and visual receptors within the Banwy Valley; and  To the Llanbrynmair proposal in respect of the local highway proposals for the Llanerfyl to Talerddig Road (C2031/U2319) and the landscape and visual impact these would have on the landscape and visual receptors within the Nant yr Eira Valley. I will compare these with the effects of Powys’ alternative access scheme.

2.5 In assessing the landscape impact of the development proposals I have used standard methodologies accepted by my professional body The Landscape Institute. My evidence consists of this proof and appendices including a set of figures that are under separate cover.

2.6 In considering these items I shall:

 Describe the distinctive landscape context of this part of Mid-Wales;  Review the landscape related planning policies relevant to the proposals;  Discuss in turn the individual landscape and visual impacts of the proposals on the landscape in terms of character and appearance and on a range of visual receptors;

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

 Compare the proposed local road access arrangements for Llanbrynmair with PCC’s alternative; and  Conclude as to the overall landscape and visual effects of the proposals in the planning context.

Landscape Statements of Common Ground

2.7 In the course of preparing this evidence I have had discussions with the landscape witnesses (Mr Stevenson and Mr van Grieken) appointed by the two applicants respectively. Together we have jointly sought to agree as much evidence as we can and the two Landscape Statements of Common Ground (LSOCG) set out the level of agreement we have reached in each case. I have also had discussions with the landscape consultants appointed by Snowdonia National Park (Mr Evers) and National Resources Wales (Mr Campion). I am grateful to Mr Stevenson and his clients for the preparation of an additional wireframe and photomontage viewpoint and for preparing several wireframes highlighting specific turbines as per the Powys objection to Carnedd Wen.

Approach and Methodology

2.8 My approach to the landscape and visual impact assessment evidence within this proof is in accordance with the 2nd Edition ‘Guidelines for Landscape and Visual Impact Assessment’1, as this has been the prime methodology used by the applicants in their LVIAs, although I do raise some issues of revised methods of approach and assessment advocated by the recently published 3rd Edition GLVIA2. I have used an example approach provided by the 2nd Edition GLVIA (Appendix B) and used the terms and criteria used to describe the magnitude of visual effects as advocated by the Scottish Natural Heritage Guidelines for the ‘Visual Assessment of Windfarms: Best Practice’ 20023 (Appendix C). For landscape character effects, under the umbrella methodology of the GLVIA, I have followed the approach advocated by LANDMAP Information Guidance Note 34 for the assessment of effects against the LANDMAP criteria. In respect of cumulative impact assessment I have adopted the principles of the approach advocated by the March 2012 guidance

1 Landscape Institute, Guidelines for Landscape and Visual Impact Assessment 2nd Edition, 2002 [CD-CPL-LAN-004] 2 Landscape Institute, Guidelines for Landscape and Visual Impact Assessment 3rd Edition,17 April 2013 [CD-CPL-LAN-005] 3 Visual Assessment for Wind Farms: Best Practice. Report No F01AA303A University of Newcastle commissioned by SNH. 2002 [CD-VATT-LAN-003] 4 LANDMAP Information Guidance Note 3: Using LANDMAP for Landscape and Visual Impact Assessment of Onshore Wind Turbines. CCW. May 2013 [CD-VATT-LAN-005]

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

issued by Scottish Natural Heritage in ‘Assessing the Cumulative Impact of Onshore Wind Energy Developments’5.

2.9 What constitutes a significant effect, what is the meaning of a significant effect in a broad planning context and what weight should be attached to it, is without specific definition in any related guidance. The GLVIA requires the process of the assessment of significance to be clearly defined for each project and for this to be expressed as transparently as possible. The 2002 SNH Guidance states that in the absence of unequivocal guidance “best practice requires that the bases for all judgments are made clear and explicit on a case by case basis”. I have adopted a ‘simple’ method in which I consider the effects to be either significant or not significant, where one that is significant is of sufficient weight to be material to the planning consideration and potentially the decision on a nationally important infrastructure project. In general significant visual effects would occur when the receptor is of at least High sensitivity and the magnitude of change would be Dominant, Prominent, and Conspicuous. Significant landscape effects would generally occur when the special qualities or key characteristics of a particular landscape character would be substantially altered and this would include where the wind farm would become the new dominant characteristic or a co-dominant characteristic.

2.10 For the assessment of landscape effects I have adopted the approach often used in wind farm assessments, whereby a landscape in which the turbines become the dominant characteristic is judged to become a ‘wind farm landscape’. The magnitude of this effect is inevitably substantial because the existing characteristics, although largely retained in wind farm development, are subjugated to the presence of the turbines. The size of the area that becomes a wind farm landscape is determined by the characteristics of the receiving landscape and the size and number of the turbines.

2.11 Beyond the wind farm landscape a ‘landscape with a wind farm sub-type’ is created where the turbines would become a co-dominant or an equally prominent characteristic. The magnitude of this effect is moderate-substantial because although there would not be a total alteration of the key elements of character, the introduction of prominent, large scale elements would be likely to be substantially

5 Scottish Natural Heritage, Assessing the cumulative impact of onshore wind energy developments, March 2012 [CD-CPL- LAN-007]

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

uncharacteristic. Beyond this area the existing landscape characteristics reassert their dominance over the wind farm where the wind farm would be seen as an object within the landscape, prominent but not dominating or changing overall character. The effects of this change are moderate to moderate-slight and not significant. Beyond this the wind farm becomes incidental to existing landscape characteristics.

2.12 This approach means that in seeking to identify the significant landscape impacts, rather than all, the extent of assessment can be refined. Using the methods above the visual and landscape impact assessment of each scheme has identified the extent of significant effects and accordingly I have focussed the landscape impact assessment on an area of up to 7.5km from the schemes, although the nature of the topography considerably limits the extent of significant effects in some directions and accordingly I have restricted my considerations to those where significant effects are likely rather than simply where there may be potential. LANDMAP Guidance Note 3 advocates appropriate study areas of 5 to 15km.

2.13 The general premise of the methodologies developed and practised by the landscape profession is essentially a test of the degree of change to a particular scene, in which the proposed elements are perceived to be different to the character of the scene and which usually result in an adverse effect where the proposal is not in character with that scene. Typically in rural scenes the general proposition is that new built forms are assessed to be out of keeping with character, thus having an adverse effect. However, the approach adopted by the LVIA chapters of the ESs, is one where the assessor in expressing the magnitude and significance of the effects, does not express whether the effect would be adverse or beneficial. This is unusual in landscape and visual impact assessment but is a method commonly practised in wind farm assessments. I adopt the approach whereby, on the precautionary basis, the impacts would be adverse unless the contrary is demonstrated. I note that EIA Regulations require that positive and negative impacts should be identified in assessments and I also note that the 3rd Edition GLVIA also now advocates that impacts are adverse or beneficial. I take this to mean that the assessor should not only consider this but also state the outcome. To this end all impacts in my proof can considered to be adverse unless specifically stated.

2.14 Not all significant adverse landscape and visual effects are necessarily unacceptable effects. Definitions of a threshold of unacceptable effects do not form part of the standard methodologies because inevitably there can be no absolute definition and

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

because such considerations are ultimately a matter of professional judgement. I consider that unacceptable effects are likely to occur where an impact or, more likely, an accumulation of impacts would be so severe or so widespread on a highly valued receiving landscape or range of receptors, so as to substantially diminish that value.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

3.0 LANDSCAPE CONTEXT

Published Landscape Character Data and Assessments

3.1 The relevant published landscape character data and assessments are the LANDMAP data (published by Natural Resources Wales), the Powys Landscape Character Assessment and the Regional Landscape Character Map for Wales (draft 2009). The above information all forms part of the landscape baseline and is considered in the various ESs and SEIs, as well as in the LSOCG.

3.2 The LANDMAP data has and continues to be refined by NRW. I understand that the Regional Landscape Character Map of Wales has not been progressed since the publication of the draft in 2009.

3.3 The key matters that arise for the Inquiry from the LANDMAP information are:

 The LANDMAP Visual and Sensory Aspect Areas (VSAAs) within the immediate landscape context of the two adjoining application areas, or sites, have an overall evaluation ranging from Low to Outstanding (there being four categories Outstanding, High, Moderate and Low). Carnedd Wen would lie largely within Low (with some four turbines in the north-east sited within a Moderate area) and the Llanbrynmair turbines split broadly equally between Low and Moderate areas. Other than four north-eastern turbines Carnedd Wen would lie entirely within the Banwy Forest VSAA (MNTGMVS320); the north-east turbines would be in the Pen Coed Upland (MNTGMVS571). Llanbrynmair would straddle the Banwy Forest VSAA, the Pen Coed Upland VSAA and the Banwy Upland VSAA (MNTGMVS264). The Nant yr Eira Valley and part of the Banwy Valley sides are within Llanerfyl Mosaic Farmlands (MNTGMVS422) which has a High overall evaluation and Outstanding scenic evaluation; the local highway improvements for the Llanerfyl to Talerdigg road lie within this VSAA;

 Carnedd Wen would lie partly within Historic Landscape Aspect Area of Low evaluation (MNTGMHL790) and one of High value (MNTGMHL859). 12

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

Llanbrynmair would lie entirely within the latter High value area. These adjoin a further area of High value (MNTGMHL352) which covers the Nant yr Eira and Banwy Valleys;

 Carnedd Wen and the Llanbrynmair would lie wholly within a Cultural Landscape Aspect Area of a High evaluation (MNTGMCL051) and would adjoin a further High evaluation area covering the Nant yr Eira and Banwy Valleys.

3.4 The Powys Landscape Character Assessment (PLCA) is drawn from the LANDMAP work and I understand that it is an agreed position between the parties at the inquiry that the character assessment is ‘fit for purpose’. The PLCA identifies ‘Special Qualities’ (or key landscape characteristics) for each of the character areas and these provide an appropriate basis against which to assess the landscape character effects of the applications but given the strong relationship between LANDMAP and the PLCA I have chosen to concentrate on the LANDMAP VSAAs.

3.5 As set out in the section on methodology above I have considered at my Appendix E those PLCA character areas where I consider there is the likelihood for there to be significant landscape character effects; these being limited to the host landscape character areas and those within 7.5km of the wind farms, both individually and cumulatively, where topography permits (in so doing I have excluded M15 – Dyfi Valley and Catchment and M16 – Dyfi Forest). The relevant areas are as follows:

 M5 – Dyfnant Forest/Llanbrynmair Moors (host for both Carnedd Wen and Llanbrynmair);  M7 – Pont Llogel;  M11 – Mynydd y Cemmaes;  M12 – Banwy Valley;  M13 – Tregyon/Llanerfyl;  M14 – Esgair Cwmowen;  M17 – Dyfi and Twymyn Hillsides;  M22 – Trannon; and  M23 – Carno Valley.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

Designated Landscapes

3.6 The nearest point of Snowdonia National Park (SNP) at Nant-y-Dugoed would lie approximately 2.5km to the north-west of the north-westernmost turbine of Carnedd Wen, with the southernmost lying some 8km from the same point of the SNP. The nearest equivalent turbines of Llanbrynmair would be 6km and 10km away respectively. The ZTVs for both schemes indicate that visual impacts and consequently landscape character effects would generally be restricted to the higher parts of the landscape only.

3.7 The Ceredigion Uplands Special Landscape Area (CUSLA) lies approximately 20km south-west of Carnedd Wen and Llanbrynmair. The ES ZTVs indicate that there would be very few locations with views of the wind farms, limited to areas of high ground at the western edge of the area. As the visual effects would be limited, I consider that the impact on the landscape character of the CUSLA would be negligible and I do not consider this further.

ES and SEI Landscape Baseline Data

3.8 The various ESs and SEIs include reference to much of the published assessment material, as well as independent character assessment discussion and assessment, including assessments of landscape sensitivity to wind farm development. My understanding is that for Carnedd Wen the SEI material updates the original ES material with the original material remaining ‘live’, whilst in the case of Llanbrynmair the August 2013 SEI supersedes the earlier assessments. In addition, a combined set of photomontages for both schemes were made available

3.9 The most relevant documents are as follows:

 Carnedd Wen ES LVIA December 2008 for 65 turbines6  Carnedd Wen SEI cumulative LVIA August 20097  Carnedd Wen SEI LVIA September 2011 for 50 turbines8

6 [AD/RWE/004-007] 7 [AD/RWE/011] 8 [AD/RWE/015-018]

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

 Carnedd Wen SEI LVIA July 2013

 Llanbrynmair SEI LVIA August 2013 for 30 turbines

 Carnedd Wen and Llanbrynmair Cumulative Photomontages 2013

Landscape Context

3.10 The highly varied topography of this part of central Wales is essentially a high upland plateau, the highest parts of which exceed 500m AOD, which has been deeply eroded into a complex series of plateaux and rolling ridges by sharply incised valleys with narrow, twisting valley floors (refer to Figure PRV1). The nucleated rural hamlets, villages and a few small towns are linked by transport corridors that run along the valleys. The valley sides are populated by scattered and generally small farmsteads whilst the plateaux and high moorland areas have little or no development. The contrast between upland moor and forest on the one hand and partially developed valleys on the other, is typical of central Wales and gives this landscape its particular and special character.

3.11 The distinctive landscape is thus a product of both its striking topography and the mosaic of different land uses. The upland plateaux are a combination of extensive moorlands or large scale forestry comprising commercial conifer species such as spruce and fir. In contrast, the agricultural landscapes of the lower, undulating uplands and valley sides are characterised by small to medium sized irregular fields of mainly pasture delineated by native hedgerows, fences and occasional stone walls. Deciduous tree belts and woodland blocks tend to be confined to watercourses, lanes and the valley floors. Whilst there are clear variations in character across the area, the landscape is unified by its dramatic topography, high level of intactness and strong sense of rurality.

3.12 The upland mass which forms the immediate setting for the two applications is framed in the north by the Banwy Valley (which is essentially a contiguous feature with the Dugoed Valley), by the Dyfi Valley in the west and by the Carno Valley (contiguous with the lesser Twymyn/Laen Valley) to the south. To the east the landform diminishes gradually towards the Severn Valley. This landform, which rises to a maximum of 523m AOD at Carnedd Wen, has been carved into by various 15

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

subsidiary water courses including by the Afon Carfan a tributary of the Afon Dugoed, which has formed a deeply incised north-south valley (Cwm Tafolog) and which separates the high Carnedd Wen-Llanbrynmair Plateau from the Mynydd y Cemmaes upland mass to the west with its distinctive ridge. The Carnedd Wen-Llanbrynmair Plateau is a very large-scale, ‘simple’ landscape with a broad domed landform and a regularised landcover dominated by massive continuous coniferous plantations blocks with open moorland on the lower slopes. It is not crossed by roads and has relatively few footpaths, is generally inaccessible and has almost no settlement. Its substantial scale is its overwhelmingly dominant visual characteristic.

3.13 The Afon Gam has eroded a broad, gentle valley (the Nant yr Eira Valley) which runs east of the Carnedd Wen/Llanbrynmair Plateau from south-west to north-east towards the Banwy Valley. This valley or vale is a highly unusual landform in this part of upland mid-Wales, in which most significant valleys are narrow, steep-sided and deeply incised. The Nant yr Eira Valley divides the Carnedd Wen-Llanbrynmair plateau from the Mynydd Waun Fawr ridgeline to the east and the Esgair Cwmowen uplands to the south-east. By contrast to the adjoining Carnedd Wen-Llanbrynmair Plateau the Nant yr Eira Valley is smaller scale, more intimate and has variety and landscape features of charm and value, including the winding Afon Gam and the open grazed areas along its length. It is sparsely settled and accessible but retains a strong sense of remoteness and tranquillity. It also changes from south to north, being more open with an upland moorland character in the south and becoming to the north more deeply enclosed by landform, with grass pastures and richer vegetation, including hedgerows.

3.14 The Banwy valley floor and sides, from Llanerfyl west to Foel, has a more settled and less remote and tranquil character than the Nant yr Eira Valley; the A458 runs along it and there are several small villages. However, its valley sides are cut by numerous streams and tributaries of the Afon Banwy, which have produced a complex and varied topography of interlocking, rounded hills and steep-sided valleys, above all of which the high moorlands of the Carnedd Wen-Llanbrynmair Plateau to the south and Dyfnant Forest to the south form the ultimate horizon. The farmed valley has a high level of intactness and the combination of this with upland horizons, rolling topography and attractive villages means the landscape is of high scenic quality and of some considerable value.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

3.15 To the north of the Banwy Valley the landform rises to the Dyfnant Forest plateau which rises up to 483m AOD and beyond that to the Berwyn Mountains which rise to well above 500m AOD and which provide the setting for Lake Vyrnwy. To the north- east the land rises again but less distinctively into a complex undulating landscape up to around 300m AOD. The Dyfnant Forest plateau shares some similar characteristics with the Carnedd Wen-Llanbrynmair Plateau in that it is high, although not as high, and is substantially forested. However, it is more rolling and a less substantial topographical ‘block’, meaning that its scale, whilst large, is not its overwhelmingly dominant characteristic.

3.16 To the north-west and west of the Dugoed and Dyfi Valleys lies the edge of Snowdonia. This rises steeply and dramatically out of the valleys and initially takes the form of high rounded hills but which turns to mountainous topography with typical glacial features beyond. The enclosed and settled character of the valley floors, which also act as the main transport corridors, contrast strongly with the high, open mountain moorlands from the summits of which wide panoramas are possible into the National Park and also out of the National Park across the north-western part of Powys.

Existing Wind Farms

3.17 By virtue of a combination of distance and topography, Cefn Croes Wind Farm, just within Ceredigion to the west, and the Bryn Titli and P&L Wind Farms within Powys to the south are barely perceptible from within the context of the application sites and do not exert any significant effect on the existing landscape appearance, character or quality.

3.18 The existing wind farms which have some material influence on the character of this landscape are Cemmaes Wind Farm 5-6km due west of the centre of the Carnedd Wen-Llanbrynmair Plateau, the Carno complex some 11km to the south and Mynydd Clogau Wind Farm 12km to the south-east.

3.19 Cemmaes Wind Farm is the most influential in areas west and north of the Carnedd Wen-Llanbrynmair Plateau, including on some views from summits within the National Park. It consists of 18 turbines, 66m high to tip, lined out for 3.5km along the Mynydd y Cemmaes ridgeline (440m AOD) but due to the depth of the valleys its 17

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

zone of visibility is largely limited to other areas of high ground, e.g. from within the National Park, as above, and from south of the Twymyn Valley, although the blades and some nacelles are seen on the horizon from the A470 in the Dyfi Valley to the immediate west. Overall it has a comparatively restricted visual envelope due to the scale and height of the surrounding topography, the number of turbines and the relatively modest height of its older-technology turbines. Cemmaes would have the potential to have significant cumulative visual effects with the Carnedd Wen and Llanbrynmair proposals, particularly from the high ground to the west and north of the Dyfi Valley both within and outside the National Park.

3.20 The Carno complex is sited on a high upland plateau at just under 500m AOD. It consists of some 56 older turbines of either 54m high to tip (Carno A&B) and 12 more recently constructed turbines of 80m high to tip (Carno II) and is influential on areas south of the Carnedd Wen-Llanbrynmair Plateau. Carno II is particularly visible from sections of the A470 from Carno to Talerddig in the Carno Valley, with the earlier phases of the Carno complex more visually prominent from the upland moors and minor valleys to the south-west and west. Carno II has a wider visual envelope than Carno A&B by virtue of its location at the high point of the plateau, close relationship to the Carno Valley and the height of the turbines. Together the Carno complex has the potential to have significant cumulative visual effects with the Carnedd Wen and Llanbrynmair proposals, particularly from the high ground south and north of the Carno and Twymyn/Laen Valleys.

3.21 The Mynydd Clogau Wind Farm is something of an anomaly as it does not follow the ‘rules’ loosely followed by not only Cemmaes and Carno but also by the other existing wind farms to the south, P&L, Bryn Titli and Cefn Croes. Mynydd Clogau is sited in upland but on a site of under 400m AOD and on the side of the minor valley of the Nant Llyn Mawr. It consists of 17 turbines 66m high to tip and is laid out across a farmed landscape of fields of pasture and sited immediately below a 440m AOD high ridgeline of upland moorland. As the minor valley forms part of a broader topographical mass of Esgair Cwmowen plateau, Mynydd Clogau has a limited visual envelope and does not exert much significant influence visually on the surrounds or on the wider landscape context.

3.22 As a general proposition a key characteristic of the effects of the existing wind farms on the landscape relates to their precise location in respect of their host landforms. 18

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The nature of the deeply incised valleys and the rolling upland plateaux with domed ridgelines at some edges means that so long as the turbines are set back from the edges of the ridges and plateaux, the impact on the settled valleys and main transport corridors can be limited. Where turbines are set too close to the edges or have locations which have ‘spilled over’ the edges, then the impacts on the valleys can be substantial, where turbines can be seen at close range on high, prominent ground and can dominate the smaller scale, more domestic character of the valley floors. When one is moving through the landscape, along the valley transport routes, after many miles of attractive rural landscape, one can come upon turbines in this way and their impact is sudden and acutely jarring. Two of the three relevant existing wind farms do break this ‘rule’ to some degree. For example, Carno II impacts quite substantially on the Carno Valley whilst its neighbours Carno A&B are better sited in this regard and Cemmaes has some significant visual impacts on adjacent the Dyfi Valley. Therefore, the precise location of turbines on ridgeline and plateau sites is critically important to determining the extent of likely significant landscape and visual effects.

3.23 From the upland plateaux and high ground, unless the viewer is within the immediate vicinity of one of these wind farms, they are generally seen at a distance, in a large- scale often open landscape, punctuated by huge blocks of forestry. In this context the scale of the landscape is generally absolutely dominant and the wind farms are seen as features within it; alien and sometimes starkly in contrast but not significant detractors. Setting aside Mynydd Clogau, the common thread shared by the two nearby wind farms and the three to the south, is that that they all occupy high domed ridgeline or plateau sites (at around 500m AOD, although Cemmaes is somewhat lower than this), in general the highest parts of this landscape, this provides a sense of consistency of approach and an apparent logic to their siting which fits well with their role. Their sites are generally open moorland with some afforested blocks and so in tandem with their highest locations are sited in landscapes of the maximum available scale to best absorb them. Also, importantly, they have maintained a generous separation distance which means their radii of significant landscape influence do not overlap leaving large swathes of landscape relatively unaffected in between. Maintaining substantial distances between wind farms and finding the highest, largest scale sites in the landscape are the twin ‘golden rules’ I would adopt from this analysis.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

3.24 There are several single turbines, sub 80m to tip, scattered throughout this landscape (for example south of Llanerfyl). Most are associated with farmsteads and consequently are sited within the valleys although often on the valley sides to capture the wind. Their effects are restricted by the relatively enclosed nature of their location and by their size. It is rare that there is an overlap of landscape impact between single turbines and to date, single turbines have at most a negligible cumulative effect with the existing wind farms. Sequentially however, single turbines can have a cumulative visual cluttering effect on the landscape of the valleys and maintaining reasonable levels of separation between them is important in minimising this effect. In respect of the influence they might exert on the applications before the Inquiry, in my judgement, their absence or presence is a factor but not a weighty one in respect of the decisions to be made about the proposed wind farms.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

4.0 LANDSCAPE RELATED PLANNING POLICY CONTEXT

Introduction

4.1 Mr Carpenter has set out Powys’ position in respect of planning policy at the Opening Session. The purpose of this section in my evidence is to consider the process of defining the boundaries of SSA B, both the original work by Arup (July 2004 and June 2005) for TAN 8 and subsequent iterations undertaken by Arup for Powys (2006 and 2008), and to consider the particular relevance of this work to the inquiry. I understand that RWE npower will refer to the Aecom October 2012 report to PCC. Whilst I accept this is a relevant document (as per the Carnedd Wen Landscape Statement of Common Ground), the work was primarily to do with establishing renewable energy resources and I do not consider that it adds anything of any particular importance to the consideration of the planning applications at the Inquiry and I do not refer to it again.

Arup 2004, 2005 and TAN 8

4.2 Arup’s 2002-20049 work was founded on a substantive sieve mapping exercise using a Geographic Information System (GIS) to store and map various ‘layers’ of spatial constraint data, principally environmental designations. At a second stage, strategic search areas were identified capable of delivering the Welsh Assembly Government’s Renewable energy target of 4 Terrawatt hours by 2010. The methodology employed is summarised in the Executive Summary to the Final Report as follows:

Arup and its sub-consultants developed further the GIS established during the Stage 1 research contract in accordance with the following methodology:

a) An initial screening exercise - ‘absolute’ and ‘variable’ environmental and practical constraint data were gathered and mapped. To these were added the outputs from a separate study of the capacity of the electric distribution network in Wales to accommodate distributed generation from renewable energy development. The results allowed the elimination of several broad zones of Wales from the available land for strategic areas. Spare electrical capacity sufficient to accommodate large-scale onshore wind energy

9 Facilitating Planning for Renewable Energy in Wales: Meeting the Target (Arup) July 2004 [ALL-011C]

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developments was shown to be scarce and unevenly distributed. Without the implementation of planned improvements to the network by 2010/2015 in mid- and north-Wales, there would not be sufficient gird capacity to allow achievement of the 4 Terrawatt hour target.

b) A refinement exercise – the areas which ‘fell-through’ the initial screening exercise were subject to a further more detailed review at 1:50 000 scale in which more site-specific constraints (such as the presence or absence of isolated properties, land availability and access) were considered.

c) Testing and validation – In order to inform the subsequent debate about the strategic areas arising from the results of a) and b) above, the draft areas were subject to a further review stage. In this, the derived areas were examined with respect to visibility from National Parks/Areas of Outstanding Natural Beauty/National Trails, visibility of other existing (or committed) wind farms, landscapes likely to be ‘wild’ in character and higher wind speeds. The strategic areas were also subject to a capacity exercise, in which likely scale of developments possible in each was determined (to +/- 50 Megawatts). This was felt to be an important part of conveying the magnitude of development that was required in some areas in order to meet the 2010 target.

4.3 The work was computer based and did not, to the best of my knowledge, involve fieldwork. This work advised the revised draft TAN 8 published in July 2004.

4.4 In the winter of 2004 Garrad Hassan and Partners carried out a further technical assessment study10 of the seven SSAs to provide a view on the capacity of these areas. This work was based on noise limits and was not an assessment of landscape capacity nor did it suggest changes to the boundaries.

4.5 Arup was commissioned by the Welsh Assembly Government in December 2004 and the study, reported in June 200511, considered whether the draft SSA boundaries should be amended taking into account matters such as noise and wind speed. This study informed the final TAN 8 of July 2005. The Arup work advised changes to the SSA B draft boundaries, taking into account wind speeds and noise issues at properties. In respect of landscape, visual and cumulative matters the report responded to observations about the lack of reference to LANDMAP and landscape character data and, in particular, that matters of landscape capacity are best dealt with at a regional/local level “where knowledge and understanding of the areas can

10 Energy Assessment of TAN 8 Wind Energy Strategic Areas of Search (Garrad Hassan and Partners) April 2005 [CD/COM/031] 11 Facilitating Planning for Renewable Energy in Wales: Meeting the Target (Arup) June 2005 [CD-CPL-MIS-002]

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be brought to bear” (paragraph 3.5). An outline methodology was included for consideration by local authorities in this regard.

Arup White 2006

4.6 The Arup White Study of 200612 was commissioned by Powys County Council as envisaged by Annex D of TAN 8. It was primarily a landscape and visual assessment exercise seeking to identify, what were termed, ‘Preferred Areas’ within the Strategic Search Areas B and C (SSAs), supported by a range of other technical and environmental data, such as electrical connection information. The report was not consulted upon.

4.7 LANDMAP Visual and Sensory value data was used as the basis for the landscape character work from which landscape capacity of the various aspect areas was derived. The methodology employed for this analysis was based upon industry best practice guidance but would appear to have been essentially a ’simple’ conversion of landscape sensitivity, as determined by LANDMAP, into landscape capacity, whereby lower sensitivities became higher capacities and so on. The visual work was based on 3D GIS modelling of zones of visibility with a site visit to the areas to verify the desk study.

4.8 Ultimately the focus for the study was to determine refined boundaries for the SSAs and to ensure a sufficient yield capacity was available, as follows:

The results of the relative environmental and landscape performance of the zones or sub-areas of SSA are then brought together in the report within a summary matrix which includes the approximate estimated capacities (in MW) for the respective zones. In bringing the data together in the final summary matrix appropriate weight is given to visual effects. In addition the study has considered the “developable capacity” of the defined zones in terms of the amount of Megawatts ( MW ) of wind energy that may be possible in each, based upon an average yield of 7.5MW per sq. km (typically around 3-5 modern wind turbines) where the areas are not constrained.

4.9 The executive Summary of the 2006 report concluded:

12 TAN 8 Annex D Study of Strategic Search Areas B (Carno North) and C (Newtown South): Final Issue Report (Arup) January 2006 [CD/COM/017]

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The study concludes that a land area is required that is slightly larger than the minimum needed to meet the MW indicative capacity figures stipulated in TAN 8; it is therefore recommended that the refined SSA boundaries encompass zones with an estimated cumulative capacity of 125% of the TAN 8 indicative capacity(s). Note that this does not necessarily endorse the ultimate development of the refined SSA boundary to this extent, simply that the TAN indicative capacity figures should be allocated to a slightly enlarged area to offer a greater degree of spatial flexibility in the planning for onshore wind farms for both the local planning authority and developers. This should ultimately greater facilitate achievement of the Welsh Assembly onshore wind target to 2010 whilst minimising local environmental impacts.

TAN 8 contains an indicative target of installed capacity of 290MW for SSA B, Carno North. Therefore sufficient land is needed within SSA B for 290MW x1.25 i.e. 362 MW approx. The implications of the data gathered for this study are that the five environmentally lowest ranked zones within and around SSA B need not be developed.

For SSA C Newtown South, TAN 8 contains an indicative target of installed capacity of 70MW. Therefore following the same arguments as above, sufficient land is within needed within SSA C for 70MW x1.25 i.e. 87.5 MW approx. The implications of the data are that the six environmentally lowest ranked zones within and around SSA C need not be developed.

It is recommended that the SSA boundaries are therefore modified to remove the environmentally worst performing zones.

4.10 Evidently the 2006 was not a detailed landscape and visual assessment; its work is useful and relevant but is indicative only and not of sufficient detail to be reliable enough to the form the basis of a determination of the appropriateness or otherwise of specific development proposals. What the 2006 work did achieve was to develop the 2004 boundaries through a form of sensitivity testing and to test these on the ground, albeit apparently only in a cursory manner. However, the 2006 work did not assess all of the land currently included within the Carnedd Wen application area (specifically an area proposed for four turbines to the north-east of Zone B6) and ultimately defined a refined boundary in the same area which would now exclude some 12 turbines.

Arup 2008

4.11 The 200813 review was commissioned by Powys following the Wern Ddu appeal decision. The brief was as follows:

13 Local Refinement of TAN 8 Strategic Research Areas B and C: Review Exercise, (Arup) April 2008 [CD/COM/10A]

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The brief for this study, agreed in dialogue with PCC, was to undertake a new local refinement of the boundary of the nationally published Strategic Search Areas (SSAs) for SSA B (Carno North) and SSA C (Newtown South). The new local refinement exercise was to follow the principles as set out below:

• It was to comply as far as possible with the guidance contained within TAN 8 Annex D. • It was not to serve to ‘cap’ development levels at the TAN 8 indicative capacities (in MW) for each SSA where the data indicated that greater levels of development might be possible i.e. the outcomes were to be driven by the landscape capacity of the area, within the context of an overall national policy objective to allow landscape change.

4.12 The study has more landscape and visual focus than the previous work involving a review of the 2006 boundaries plus a 5km ‘buffer’ to focus the further landscape and visual analysis. The work which was predominantly desk based included further GIS sieve mapping of ‘constraints’ “similar to that undertaken by all wind farm developers when selecting sites” which, again as per the previous study, identified ‘unconstrained’ land which could then be tested for its “suitability in landscape and visual terms”. Again, with the case of the 2006 report, the various zones for analysis were derived from LANDMAP (and were verified in the field).

4.13 The computer based visual assessment work involved some assumptions about the sensitivity of receptors and assumed 4 no. 125m high turbines per 1km square but took no account of the presence of existing wind farms (unlike the 2006 study). The likely significance of visual effects was calibrated to distance using the 2002 SNH guidance as a basis. Nevertheless, this study is essentially an exercise in assessing the extent of visibility and is more a study in establishing quantitative effects than it is in qualitative effects (as the results at 2.4.3 reveal); areas which are widely visible perform poorly against those that are more contained.

4.14 The effects on settlements were addressed in a similar way. Zones which were visible from several or many settlements up to 15km away performed worse than those which are more enclosed. No apparent account is taken of the much more substantive qualitative effects that would most likely be experienced by those settlements close by.

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4.15 As a refinement process of the 2006 study, the 2008 work also did not consider the area immediately north-east of Zone B6, the site of four potential Carnedd Wen turbines. What is evident from the 2008 work is that it recommended a refined boundary which although it slightly extended the 2006 boundary in the north-east, it also specifically excluded parts of the relevant zones (1a, 1b and 6) because of the visual exposure to the Banwy Valley and Nant yr Eira Valley (or Afon Gam as it referred to it). Five of the Carnedd Wen turbines would be sited outside the 2008 refined boundaries.

4.16 In as much as this exercise was primarily targeted at refining the 2006 boundaries essentially through extension, not contraction, the additional landscape and visual work undertaken was a reasonable basis, particularly as the edges of many of the otherwise acceptable zones were ruled out where turbines in these locations would potentially impact substantially on more enclosed adjoining areas. However, as I have argued at the Inquiry in respect of SSA C, I firmly believe that the Arup work is not a sound basis for assuming all of the land within the area is similarly suitable for wind farm development. Likewise I am consistent in this regard in respect of the weight to be given to the refined boundaries. They are not and should not be considered absolute rather they inform the judgement as to what may or may not be acceptable but should yield to the more detailed site specific assessments before this Inquiry. In terms of the five Carnedd Wen turbines it does, however, highlight an aspect of the scheme which suggests a potential sensitivity. Whilst I accept the TAN 8 policy context, which presumes significant landscape change across the SSAs, the full implications of this stand to be assessed at this inquiry and at a level of detail beyond that employed by the 2004, 2005, 2006 and 2008 studies.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

5.0 CARNEDD WEN AND LLANBRYNMAIR OVERVIEW ASSESSMENT

Introduction

5.1 The purpose of this section of my evidence is to provide an overview of the principal reasons as to why I consider the majority of the turbines of the two schemes to be acceptable in landscape and visual terms (the specific points of objection to both schemes are dealt with in section 6.0 – five Carnedd Wen turbines and section 7.0 – the Llanbrynmair local highway proposals, below).

5.2 In preparing this evidence I have undertaken fieldwork including visiting most of the selected individual and cumulative viewpoints and have also viewed the sites for the proposals from a wide range of other publicly accessible locations, including from all of the main highways, many of the minor highways and main settlements in the area and I have also walked lengths of many Public Rights of Way including sections of Glyndŵr’s Way through SSA B and beyond. I have also visited the Carnedd Wen and Llanbrynmair sites, not on Public Rights of Way, on two occasions with appropriate permissions.

5.3 The principal features of the Carnedd Wen and Llanbrynmair proposals are set out in section 2.0 of this evidence and their details are defined in the relevant ESs and SEIs, whilst the local highway proposals for the Llanbrynmair proposal are defined by the Aecom drawings, issued 7th June 2013, and entitled ‘Local Traffic Management Plan - Appendix A: Local Highway Proposals’. An important aspect of both proposals, particularly so of Carnedd Wen, is the landscape character and visual enhancement proposed by clearing forestry and replacing it with open moorland. I judge this to be a material long term landscape benefit which would assist in offsetting the otherwise negative landscape effects of both proposals. Whilst substantial in the case of Carnedd Wen it would still not, in my view, entirely offset the visual and landscape harm caused by the presence of the turbines.

5.4 It should also be noted that the reduction of the original Carnedd Wen, from 65 scheme to 2011 50 turbine scheme, has assisted in reducing the visual impact on the National Park, although significant effects remain, and that the reduction of

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Llanbrynmair from 43 to 30 turbines, has had a considerable beneficial effect on the Laen and Carno Valleys such that significant effects have almost been eradicated from this area.

Visual Effects

5.5 The ESs, SEIs and the 2013 cumulative assessment viewpoints provide a reasonable selection of representative locations from where the visual impacts of the proposals can be effectively judged. For Carnedd Wen I have only identified the Banwy Valley as an area where, in my judgement, additional viewpoints would assist in appreciating some of the worst case of the effects of the scheme on the valley (a further wireframe/photomontage has been prepared by the Carnedd Wen applicants and I have provided three photographs from other locations in this evidence). For Llanbrynmair, the viewpoint selection for the principal aspect of the scheme, i.e. the turbines, is satisfactory, although the visual information for the local highway proposals appears to be limited to the photographs in the Local Traffic Management Plan Appendix A.

5.6 My visual impact methodology and my detailed assessment from each of the selected viewpoints for Carnedd Wen and Llanbrynmair are set out at Appendices B, C, D and F. Although I use different criteria to the other assessors, in most cases my individual impact assessments of magnitude and significance essentially concur with those of the respective SEIs and I have included these for comparative purposes in my tables. Where I do not agree with the visual impacts assessments are in respect of the conclusions that can be drawn from the assessments for the acceptability of the significant effects of Carnedd Wen on the Banwy Valley and the apparent limited consideration and magnitude and significance of these visual effects of the Llanbrynmair scheme on the local highway between Llanerfyl and Talerddig. In addition, although this is of no particular consequence, I do not agree with the Carnedd Wen assessors’ point in concluding the 2011 SEI that the scheme “would draw the response (of whatever valency – positive or negative) in a positive direction” (paragraph 118). In my judgement, the visual effects of Carnedd Wen, notwithstanding the extensive landscape enhancement, would remain negative overall even in a residual long term scenario.

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5.7 I have studied the Carnedd Wen access proposals and note that whilst there would be the need for the felling of some coniferous trees and some lengths of earthworks for widening purposes, that the visual impact of these changes on views from the Dugoed Valley and high ground from within the National Park, would be limited in degree, extent and in duration. I do not consider the visual effects to be significant and I consider the proposals acceptable in landscape and visual terms.

5.8 Overall, as the SEIs identify, there would be a range of significant long term visual effects of the Carnedd Wen and Llanbrynmair turbines. The greatest and most significant visual impacts of the turbines of both schemes would be experienced across the whole Nant yr Eira Valley and the Banwy Valley, specifically its valley floor and its northern valley side. In the case of the Nant yr Eira Valley, the Llanbrynmair turbines would have greater effects, whilst in the case of the Banwy Valley it would be the Carnedd Wen turbines that would have the greater magnitude of impact. In my judgement the visual change experienced by receptors within the Nant yr Eira Valley of the turbines would be substantial but that the scale and simplicity of the landscape of the plateau above the valley can visually accept the turbines. The same does not apply to the impacts on the Banwy Valley as discussed in the following section.

5.9 With regards to the National Park I judge that one of the selected viewpoints would be clearly significantly affected by the Carnedd Wen scheme this being the nearest high ground to the proposal (Carnedd Wen viewpoint L at Foel Dungoed). Other selected viewpoints from deeper into the National Park (such as Llanbrynmair viewpoint 16, Carnedd Wen viewpoints M and G) would record small to medium magnitude of effects for Carnedd Wen and would be on the cusp of being significant given the high sensitivity of the receptors at these locations. Other more distant viewpoints would not be significantly affected. I agree with the Llanbrynmair 2013 SEI assessment that individually Llanbrynmair would not have a significant visual impact on the National Park. My conclusion is that whilst some high viewpoints would experience a significant visual change, given the highly limited extent of these effects I do not consider that the effects of either scheme would individually amount to a significant visual effect on the National Park.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

Landscape Effects

5.10 There is a broad range of agreement between my assessment of landscape character impacts and that of the assessors in the SEIs in respect of the characterising effect of the wind farms (refer to my Appendices E and G for my assessments of both schemes against LANDMAP and the PLCA) although I disagree with both assessments in respect of the extent of such effects. The Carnedd Wen 2013 SEI assessment identifies characterising effects extending up to a consistent potential 2km from the turbines, whilst Llanbrynmair 2013 SEI a distance of some 3km. I consider that the extent of such characterising effects is driven by existing character of course, but mainly by topography and the resultant visibility and as such the judgements of both SEIs appear to be rather simplistic in approach. I consider that the landscape of the Nant yr Eira Valley would be characterised by both the schemes, especially Llanbrynmair, to a distance of 3km from the turbines and that the presence of the Carnedd Wen turbines breaking the horizon of the Banwy Valley would also have a characterising effect across its breadth, to a distance of some 3- 5km.

5.11 The key aspects of the landscape character assessment to draw out are as follows:

 Except for four in the north-east (VSAA 571) all of the other Carnedd Wen turbines are sited in a VSAA of Low overall evaluation (VSAA 320). The Llanbrynmair turbines would be split equally between VSAAs of Low (VSAA 320) and Moderate evaluation (VSAAs 264 and 571);

 The substantial scale and simplicity of the host landscape, as supported by the LANDMAP and PLCA assessments for the plateau, is able to accept the turbines with a substantial and significant change but one is acceptable by virtue of its inherent characteristics and its comparatively low scenic value. Put simply, it is a landscape suitable for exploitation by wind farms;

 The landscape enhancement of removing the forestry and replacing it with moorland is particularly noteworthy in the Carnedd Wen scheme and valuable. The much smaller but nonetheless beneficial effects of the Llanbrynmair proposal are also important. Neither, in my judgement, wholly outweighs the adverse character impacts of the turbines, such that the 30

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scheme would be a benefit overall, but it is a material factor to weigh in the balance of the overall judgement of landscape character impacts;

 The landscapes of value that would be affected by the schemes are those of the Nant yr Eira Valley and Banwy Valley; both are wholly, or largely, landscapes of High overall evaluation and of outstanding scenic quality. The impact of the proposals would be significant in both cases and both valleys would become in part characterised by the wind farms. In my judgement the impact of both turbine schemes on the Nant yr Eira Valley would be substantial but acceptable in landscape terms. The landscape impact on the Banwy Valley of Carnedd Wen would not be acceptable as detailed below; and

 The relatively limited visual effect and the separation distance between Carnedd Wen and the National Park (at least 4km before the turbines can be seen) mean that there would be no characterising effects on the designated landscape. I have also considered the special qualities (Management Plan 2010-2015) and confirm that there is nothing in these which would be significantly adversely affected by either scheme.

Cumulative Effects

5.12 The relevant baseline of relevant operational and consented wind farms for the cumulative impact assessment of Carnedd Wen and Llanbrynmair include the existing Cemmaes, Carno A, B and Carno Extension and Mynydd Clogau Wind Farms, together with the consented but as yet not commenced Tirgwynt Wind Farm. Tirgwynt was consented by Powys County Council in 2012.

5.13 In a second scenario, the application schemes need to be assessed in the context of the operational, consented and the in-planning wind farms. These include Esgair Cwm Owen (submitted 2010 but undetermined), Cemmaes III (refused 2012 and now appealed) and Carno III (undetermined) and Waun Garno (refused 2012 and now appealed). The application for Mynydd Waun Fawr was withdrawn in mid-2013 and I understand that a planning application for a revised scheme linked with an earlier proposal at Ffridd-Rhyd-Ddu, to the south-west of Mynydd Waun Fawr, is at a pre-

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application scoping stage. The proposal at Dyfnant Forest for a 50MW plus scheme is at a similar stage but as yet no application has been submitted.

5.14 Evidently Carnedd Wen and Llanbrynmair would be read together in this landscape as a single substantial 80 turbine wind farm spreading over an area of around 8.5km, north-south, by 4km, east-west. Their combined effects would be an amalgam of their individual impacts as outlined above. In incremental cumulative terms the effects of the 50 turbine Carnedd Wen proposal would be more significant than the 30 turbine Llanbrynmair scheme, not simply because it is larger but also because it has a significant and, in my judgement, unacceptable effect on the Banwy Valley.

5.15 The outer extent of a combined Carnedd Wen and Llanbrynmair wind farm would lie around some 5km away from Cemmaes, Carno Extension and the Tirgwynt sites respectively and around 8km from Mynydd Clogau. Whilst these are not substantial distances, it is principally the nature of the landscape between which means the cumulative landscape effects are not significant. Between the combined wind farm and Cemmaes would lie the 300m deep Cwm Tafolog and similarly deep Afon Cwm tributary, which together would provide a substantial area of visually contained landscape and would ensure that there would not be any overlapping significant landscape effects. Visually the combined wind farm would effectively be seen as a distant backdrop to views of the Cemmaes turbines in views from some peaks and higher ground from within the National Park to the west through to the north-west (Carnedd Wen viewpoints Q and M and cumulative viewpoint 4). Whilst from further around to the north (from Carnedd Wen viewpoints L, G and W9 or cumulative viewpoints 5 and 12) the combined wind farm would be seen at around the same distance as Cemmaes but considerably the dominant of the two (due to the greater numbers of turbines). As with Carnedd Wen individually the visual impact of the in- combination cumulative arrangement would be significant on the high ground at the south-east extremity of the National Park (e.g. at Foel Dungoed). Other significant cumulative visual effects would occur on the high ground at locations north of the Twymyn Valley, including lengths of Glyndŵr’s Way (e.g. cumulative viewpoint 1) but the occurrences are relatively few.

5.16 Between the southern end of Llanbrynmair and Carno Extension lies the comparatively broad and 250m deep Twymyn/Laen valley. Whilst the effects of the Carno Extension turbines spill over into this valley, the Llanbrynmair scheme has 32

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

been modified to ensure similar types of effects are not experienced to any great extent from within the valley. This has not only substantially reduced the effects of the scheme individually but, importantly, also reduced what otherwise would have been significant landscape cumulative effects with the Carno Extension scheme on parts of the Twymyn Valley and significant visual effects on Talerdigg and lengths of the A470 between Talerdigg and Carno.

5.17 The Tirgwynt scheme would be sited at about 400m AOD and around 5km to the south-east of the Carnedd Wen and Llanbrynmair schemes. The landscape between includes the open upper Nant yr Eira valley, the Ffridd-Rhyd-Ddu rising to nearly 440m AOD and the upper end of the Cwm Llwyd tributary of the Carno Valley. This ‘section’ cuts across several landscape VSAAs and some topographical variation, but the Tirgwynt and eastern edge of the Llanbrynmair scheme would lie at around the same elevation. However, the presence of Ffridd-Rhyd-Ddu on slightly higher ground would mean that significant landscape character effects of the schemes would not overlap. The impact of Tirgwint on the landscape character of the Nant yr Eira valley would be highly limited and not significant. The most significant cumulative visual effects would be experienced from the Mynydd Waun Fawr ridgeline, broadly mid- way between the schemes (e.g. Carnedd Wen viewpoint N and cumulative viewpoint 13), and from Glyndŵr’s Way at Pen Coed (cumulative viewpoint 9).

5.18 The existing Mynydd Clogau Wind Farm is some 8km from the eastern edge of Llanbrynmair and some 2.5km further south-east than Tirgwynt. Lying in a separate valley beyond the Esgair Cwm Owen ridge means that the cumulative effects with a combined Carnedd Wen and Llanbrynmair would be more limited than Tirgwynt.

5.19 Other than in respect of the two respective individual points of objection raised by Powys, the in-combination cumulative effects of the schemes together with the existing baseline of all other operational and consented wind farms would be acceptable in landscape and visual terms. The most sensitive consideration relates to the National Park. As set out above, in my judgement, there would not be any significant landscape character effects on the National Park, but there would be some significant cumulative visual effects where Cemmaes and the combined Carnedd Wen and Llanbrynmair would be seen in conjunction with each other at comparatively short range. The Carno turbines are already part of the existing baseline and

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

contribute only minimally to the cumulative visual impact. Adding in the Tirgwynt would have almost no effect at all (e.g. refer to cumulative viewpoint 4).

5.20 In the second scenario, with all of the in-planning schemes plus the operational and consented in-combination, there are elements of the some of the schemes which would be significant and unacceptable in landscape and visual terms which would lead to the overall in-combination effect being unacceptable. However, this is more to do with individual aspects of the schemes themselves as opposed to the overall combined effect (for example the impact of Carno III on the upper Clywedog Valley, Cemmaes III on the Cwm Tafolog or Dyfnant Forest on the landscape character of the National Park).

5.21 Significant sequential cumulative effects on Glyndŵr’s Way would be experienced from some 2km of path south of Cemmaes, in which the existing and proposed Cemmaes schemes would be visible in the same view with Carnedd Wen and Llanbrynmair turbines (cumulative viewpoint 1) and from the south, rising out of the Twymyn/Laen Valley from Llanbrynmair village, all along the length of the Llanbrynmair moors and down into and along the Nant yr Eira valley to Pen Coed, a total length of around 11km. This second longer length would run through the Llanbrynmair scheme for around 4km although some of this would be within forestry. Both this and the remaining length to the north would be affected by Llanbrynmair and by Carnedd Wen; no other wind farm, operational, consented or in-planning would have any significant visual effects on users of the route. There would be other views from Glyndŵr’s way to the north of the Banwy Valley which would be significantly affected but these would be relatively few and occasional. The overall impact on the national trail would be significant at this location and of significance to the experience of the trail as a whole. However, I judge these adverse effects to be acceptable in this particular landscape context given its characteristics and overall suitability to wind farm development.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

6.0 THE FIVE CARNEDD WEN NORTH-EASTERN TURBINES

Approach

6.1 My visual and landscape character assessment identifies that the north-eastern turbines of the Carnedd Wen scheme would have a significant impact on a large swathe of the Banwy Valley, in particular the areas around Foel to Llanerfyl and landscapes to the north of these settlements on the valley floor. I have sought to focus on which turbines have the greatest effect and the extent to which the scheme could be modified by a reduction in number to be deemed acceptable in landscape and visual terms.

6.2 In this regard I have focussed firstly on the group of 12 turbines at the north-eastern end of the scheme and slightly separated from the larger group to the west which would be sited in the promontory area of forestry or close to it in moorland, west on the hill Pen Coed, these being the closest and most visually intrusive from the Banwy Valley. I also considered carefully the northernmost turbines which would be visible on the horizon along the western part of the valley but have concluded that the extent of visibility of these turbines and their comparatively limited effect on the valley is acceptable (e.g. Carnedd Wen viewpoints S and W).

6.3 It is evident that the southern turbines of this group of 12, whilst they would be intrusive in some of the more elevated views from the within the valley, they would be less so than those on the northern edge in views from the valley floor and from the southern valley side (e.g. CW viewpoints W, U, V and the more distant viewpoint P plus my PCC viewpoints 1 to 4). I have concluded that a reduction in the number of these turbines by five would reduce, although by no means completely negate the effects on the Banwy Valley, to make the Carnedd Wen scheme acceptable overall. The five most intrusive would be turbine numbers R23, R26, R28, R29 and R30. These are sited closest to Foel and my viewpoint PCC 3. They also lie outside of the 2008 refined TAN 8 boundary and three of these lie in a zone scoped out by the 2006 Arup study, presumably because of the Outstanding scenic value attributed by LANDMAP to the Llanerfyl Mosaic Farmlands VSAA (422).

Visual Effects

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

6.4 I have selected and illustrated at Figures PRV 3 and 4 three additional viewpoints from the vicinity of Foel, one of which (PCC viewpoint 4) I have selected for the preparation of an additional wireframe (referred to as Viewpoint Z). These views are more central to and more representative of the Outstanding evaluation area than Viewpoints U, V and W and reveal the magnitude of the most significant visual effect on the Banwy Valley. The wireframe of the view at Foel at Figure PRV 8 and the wireframes from Viewpoints U, V and W at Figures PRV 5-7 each highlight the five turbines that I consider should be removed from the Carnedd Wen scheme in order to make it acceptable in landscape and visual terms.

6.5 Viewpoints U and W are located at the edge of the Banwy Floodplain (VSAA 119) and the Llanerfyl Mosaic Farmlands (VSAA 422). Viewpoint U illustrates that the five turbines would be the closest to the viewer, bar one, and that their removal would reduce the stacking effect of the scheme in this view. Viewpoint W lies beyond the western limit of the part of the valley most affected and, therefore, does not fully reveal the extent of the visual impacts experienced to the east.

6.6 Viewpoint V is located close to Glyndŵr’s Way on the northern valley side and on the boundary between VSAA 422 and the Pont Logel Farmlands VSAA (278) with its High overall evaluation. As with Viewpoint U the five would be the closer of the turbines to the viewpoint and their removal would reduce stacking. Also evident from the slightly higher elevation is the extent to which these turbines appear to ‘step- forward’ off the plateau and down the valley sides.

6.7 My selected viewpoints are all from Foel. PCC 1 is located at the immediate eastern edge of the village and the five turbines would be seen just above the landform in-line with the road. PCC 2 is located at Foel Church with the turbines visible on the skyline slightly behind and to the right of the foreground landform. PCC 3 is located on the A458 at the Dyffryn café with the five turbines seen on the horizon between the two prominent landforms. PCC 4 (Wireframe Z) is located above Foel village, with Foel Church seen set up on the valley side. Whilst some 30 or so turbines would be visible on the horizon line, in my judgement, the removal of the five closest turbines would remove most of those turbines that would give rise to the greatest visual effects, reduce the amount of stacking that would inevitably occur with this arrangement and ‘lighten’ the whole appearance of the scheme on the Banwy Valley.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

Landscape Effects

6.8 The Banwy Valley is comprised of four VSAAs of which two are of High overall evaluation (Llanerfyl Mosaic Farmlands 422 and Pont Logel Farmlands 278) and two of Moderate overall evaluation (Banwy Floodplain 119 and Pen Coed Upland 571). LANDMAP’s description of Llanerfyl Mosaic Farmlands notes the strong visual link with the Banwy Forest and Pen Coed (i.e. Carnedd Wen site), its Outstanding scenic values, as well as its settled domestic setting, its intimate scale, enclosed, harmonious, tranquil, and safe characteristics and its strong sense of place. The description concludes that the VSAA has “high aesthetic qualities and limited intrusion from modern development”. The Pont Logel Farmlands share some of the same characteristics and is of High scenic value. The description of the Banwy Floodplain notes the strong sense of place, the relatively narrow, distinct valley bottom “with distinct valley sides dominating the bottom” and the main arterial route which detracts from the overall aesthetic quality. Notwithstanding the effects of the A458, with which I accept the LANDMAP evaluation, the overall impression of the Banwy Valley is, however, a combination of all of these characteristics and has high aesthetic qualities, a modest scale and relative absence of intrusive features. It is a landscape of some value and of considerable landscape sensitivity due to these qualities and scale.

6.9 The prime purpose of Powys’ objection, through my evidence in-part, is to seek a partial mitigation of landscape (and visual) impacts on the landscape of the Banwy Valley through the removal of these five turbines. In my judgement, the removal of these, whilst this would not reduce by any means all of the effects on the valued characteristics and the valley’s high aesthetic quality, but it would remove those turbines which are closest, would have the greatest individual impacts and would help reinforce a desired perception that the wind farm is contained on the plateau and has not spilled-over into the valley.

6.10 It might be argued that if the widespread effects of Carnedd Wen (and Llanbrynmair) on the Nant yr Eira valley (part of the Llanerfyl Mosaic Farmlands VSAA 422) are acceptable in landscape terms then the same should apply to Banwy Valley. I consider the scale and character of the upland landscapes fringing the Nant yr Eira valley is so vast and simple, and that the upper valley (the most greatly affected 37

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

section) is in itself relatively open, simple and of a larger scale that the landscape character impacts would be acceptable. The more sensitive and smaller scale northern section of the valley would benefit considerably from the screening effects of the Pen Coed hill and by the sense of visual separation this would provide between the turbines and the valley.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

7.0 THE LLANBRYNMAIR LOCAL HIGHWAY PROPOSALS

Introduction

7.1 My landscape and visual impact assessment is based upon the proposals defined by the Aecom drawings, issued 7th June 2013, and entitled ‘Local Traffic Management Plan - Appendix A: Local Highway Proposals’. The Landscape Statement of Common ground (not complete at the time of exchange of evidence) will, it is intended, set out the agreed total loss of existing landscape features. At the time of exchange draft tree and hedgerow loss figures were available (as set out below).

Landscape Baseline

7.2 The Nant yr Eira valley lies within the Llanerfyl Mosaic Farmlands (422). As set out above in respect of Carnedd Wen, LANDMAP’s description of Llanerfyl Mosaic Farmlands notes the strong visual link with the Banwy Forest and Pen Coed (i.e. Carnedd Wen and Llanbrynmair sites), its Outstanding scenic values, as well as its settled domestic setting, its intimate scale, enclosed, harmonious, tranquil, and safe characteristics and its strong sense of place. The description concludes that the VSAA has “high aesthetic qualities and limited intrusion from modern development”.

7.3 In addition, given the comparatively localised nature of the effects of the highway scheme on the valley, it is worth considering the characteristics of the landscape at a somewhat finer grain to that considered by LANDMAP. In this regard a distinction can be drawn between the character of the upper Nant yr Eira valley in the south and the lower valley to the north.

7.4 The upper valley has the character of a broad vale with relatively gently sloping valley sides rising to upland moorlands and forestry to both the east and west (refer to PCC 5 at Figure PRV 9). Lightly settled, with occasional farmsteads and cottages, the farming is low level intensity grazing across moorland or large open rough fields. Significant vegetation is sparse and mainly consists of forestry blocks and very occasional evergreen shelterbelts. The area has a strong sense of remoteness, tranquillity and wildness. The meandering watercourse, the grazing of its floodplain and general absence of field enclosures along the lane which twists and turns along the length of the valley, crossing cattle grids and minor bridges, gives rise to an attractive local character and a uniqueness which gives the upper valley a special sense of place.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

7.5 Where Pen Coed hill protrudes into the valley, it takes on a strongly contrasting character between Pen Coed and the Banwy Valley (refer to PCC 6 at Figure PRV 8). Through its lower section the topography is more complex and undulating, the watercourse is more deeply set into the landscape and secretive with fields that are hedged with many hedgerow trees and copses. The narrow lane undulates and turns between the hedged fields. Views out are infrequent and rely generally on a sharp rise in the ground to provide long views out. In this section the valley shares common characteristics with the Banwy Valley, is small scale and of high aesthetic quality.

Landscape and Visual Effects

7.6 Powys objects to the local highway proposals on landscape grounds for the length of the works between Llanerfyl to Site Access 4 (CH 12300), that is those parts of the existing highway which would need to be changed to accommodate the AIL traffic. The works needed to accommodate the construction traffic, from Talerdigg to Site Access 4, are considered acceptable on landscape grounds as these works comprise small-scale widening of the highway to form passing bays. Powys considers that an with the current access proposals the Llanbrynmair proposal is unacceptable in terms of its landscape and visual impacts. That is a view with which I concur. Further, an alternative via the Carnedd Wen AIL access, amended to provide two points of access track connection with Llanbrynmair, is both feasible and environmentally acceptable (the evidence of Mr Woodfield addresses the nature conservation aspects that would arise).

7.7 The highway proposals would have a substantial impact on the character of the rural lane between Llanerfyl and Site Access 4, in particular the loss of existing vegetation and other landscape features, including structures and verges, the widening proposals for the Neinthirion Bypass, the Dolwan Isaf bridge diversion, the Gosen Access Track and the Gosen Bridge and the overall change and harm to the rural character of the lane and the effects of this on the characteristics of the Nant yr Eira valley and the Llanerfyl Mosaic Farmlands VSAA (422).

7.8 The total tree loss between Llanerfyl (chainage 00) and chainage 12300 would be 52 (53 for the whole length) and hedgerow loss of just over 1.4km (1.5km for the whole length). Whilst it will be argued by the applicants that the replacement trees and hedgerows (143 and 2.1km respectively) would exceed these figures and would result in a long term benefit, in my view the impact of the loss in the short to medium term (up to 20 years in this landscape before any adequate maturity could be 40

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

achieved) would significantly outweigh the longer term mitigation. Further details of landscape features to be lost will be included within the final Landscape Statement of Common Ground but the other most notable loss would be the impact to the verges of the over-run lengths, which would be almost continual on one or other side of the lane from Site Access 4 (ch 12300) to around Sychtyn Farm at chainage 5050, around some 7.25km in all, and in shorter isolated lengths thereafter. Whilst the over- run areas would be reinforced grassed and, therefore, essentially ‘green’, the earthworks required and engineering involved, cutting into the adjoining banks or building up adjoining lengths, would mean that the character of the current lane would inevitably be substantially altered and over a very considerable distance. The whole appearance would be radically altered from that of a narrow country lane, currently around 4m wide, to a widened ‘engineered’ corridor of typically around 6m wide, with the enclosing features pushed back beyond the over-run strips. At some bends in the lane the corridor would be as wide as around 12m (at chainage 4400 for example).

7.9 In addition to the more generic impacts above, there are four locations where additional substantial landscape harm would occur. The Neinthirion Bypass (chainage 8900 to 9650) would be a 1km length of off-line reinforced grass access track to bypass the hamlet of Neinthirion (refer to the photograph at Figure PRV 10) measuring in width from 5.5m to up to 12.73m. The new route would swing out into fields west of Neinthirion requiring the removal and replacement of stone walls, diversion of a channel, two new culverts and one bridge structure plus some considerable embankment earthworks to achieve a suitable vertical alignment. The route of the lane at Neinthirion is part of Glyndŵr’s Way and whilst this would not need to be diverted the visual impact of the works on users of the national trail would be significant. The landscape and visual impact of the works in the short to medium term would be substantial and significant for the Nant yr Eira valley as a whole.

7.10 In order to achieve a suitable alignment at the Dolwan Isaf Bridge (chainage 7300 to 7550) significant re-alignment would be required on the approaches to both structures. These new alignments would require substantial arcs of new reinforced grass highway to be constructed, up to 17m in width, and for the section south of the Dolwen Isaf Bridge for there to be a 6m deep cutting with a ‘harsh’ 1:1 profile made to facilitate the alignment. The Dolwen Isaf Bridge itself would require some modification, although it is a modern structure and relatively not a particularly

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

valuable landscape feature. The landscape and visual impact of these works would be locally significant.

7.11 At Gosen (chainage 4620 to 4970) and 350m length of diversion would have to be provided to bypass an unsuitable section of existing vertical alignment. The diversion would be a 7.5m width of reinforced grass with tarmac lengths at either end to tie-in to the existing highway and would require a cutting that I estimate from the drawings to be 4m deep. The landscape and visual impact of these works would also be locally significant.

7.12 At Gosen Bridge (chainage 4350 to 4600) the change from the narrow, highly rural character of the existing twisting alignment of the lane, the traditional stone arch bridge spanning high across a tributary stream and the relationship the two residencies has with the crossing of the watercourse would be dramatically altered (refer to the photographs at Figure PRV 10). East of the bridge, the lane would need to widened from around 4m to a corridor of 13m wide with existing hedgerows on either side requiring removal. At and either side of the bridge the hard surface would need to be widened from around 3.5m to around 8m. The bridge itself would be widened accordingly with a new stone arch structure placed on its northern side. Mature tress both east and west of the bridge would be removed to facilitate construction. In all the impact would be severe; the charming appearance of the twisting narrow approach and traditional bridge, a feature which is important and valuable to the Nant yr Eira valley as a whole, would become an engineering feature of A-road proportions and character. Whilst the bridge design is an appropriate design approach (i.e. to mimic the existing stone arch), this does not in itself mean the overall proposal is acceptable in landscape terms. The impact of this aspect of the road improvements would be significant on the character of the Nant yr Eira valley and wholly unacceptable in my judgement.

7.13 The Llanbrynmair local highway proposals would have a severe impact on the small- scale, rural character of the lane and would significantly alter the experience of this part of the Outstanding scenic value of the Llanerfyl Mosaic Farmlands VSAA 422 area. In my judgement these effects would be unacceptable in landscape and visual terms and sufficient to render the whole Llanbrynmair proposal unacceptable.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

The Powys Alternative

7.14 An alternative access arrangement has been put forward by Powys which would require the Llanbrynmair AILs to use the access arrangement through the Carnedd Wen site which, I understand, would be used by the Carnedd Wen AILs and construction access traffic. This would mean that the local highway proposals from Llanerfyl to Site Access 4 would not be required, thereby negating the impacts I have highlighted above. The Powys alternative has been generated with the input of Mr Woodfield (ecology), Mr Williams (highways) and myself in consultation with Powys CC officers. The scheme is illustrated in principle in Mr Williams’ evidence at Figure 2.

7.15 There would be two new links needed between the Carnedd Wen and the Llanbrynmair existing access tracks. The northern link would be via a circa 400m length of track running south from Carnedd Wen turbine 21 to Llanbrynmair turbine 27. The southern link would connect Llanbrynmair turbine 8 to turbine 12 via a section of new track that would intercept the Carnedd Wen access track network, providing a link between the two schemes. In total, it would involve some 585m of existing/upgraded forestry track and around 300m of new track construction. The connection of turbines 8 and 12 would also obviate the need for at least one of the proposed Site Accesses 2 or 4, potentially saving on at least 615m of upgraded and/or new track construction if access 2 is omitted, 900m if access 4 is omitted and over 1.5km if both were no longer required, together with some reduction in the number of new construction site traffic passing bays on between Talerdigg and Site Access 4. I note that Site access 4 is Mr Williams’ preferred site access point for construction traffic.

7.16 Both the northern and southern links would be located partially in the Low overall evaluation VSAA Banwy Forest (320) with the northern section, where it crosses the Nant Ffriddycastell, in the Moderate value Pen Coed Upland VSAA (571), and the southern link partially in the Moderate value Banwy Upland VSAA (264).

7.17 With a proportion of the new access probably aligned through forestry, the principal landscape concern regarding the northern access track would be the crossing of the Nant Ffriddycastell and the detail of how this should be achieved in respect of vertical alignment (refer to the photograph of this minor valley at Figure PRV 11). However, the point of the crossing of the minor valley is not visible from any nearby public rights of way and only visible at long distance from the east side of the Nant yr Eira 43

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

valley. Given this limited visibility and also that these works would be seen in the context of many other access tracks and wind turbines, the landscape and visual impact is considered to limited and not significant.

7.17 The southern access link would also be aligned through forestry for part of its length, this section following the route of an existing track. The new section between turbines 9 and 12 would run along a relatively level bank requiring some earthworks I assume to fit it into the side slope. But again, the location is not widely visible and the impact in the context of the rest of the scheme would be limited and not significant.

7.18 The Powys alternative would not be entirely without landscape effects, there would be some impact on intrinsic features such as the minor valley, but these would be barely perceptible from the publicly accessible locations within the wider landscape and the visual harm barely perceptible on the VSAAs affected and negligible on the High value Llanerfyl Mosaic Farmlands VSAA (422), host of the Nant yr Eira valley. The Llanbrynmair highway proposals would cause substantial and unacceptable harm to the Nant yr Eira valley and the Powys alternative, if employed, would avoid this harm.

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

8.0 CONCLUSIONS

8.1 The highly varied topography of this part of central Wales is essentially a high upland plateau, the highest parts of which exceed 500m AOD, which has been deeply eroded into a complex series of plateaux and rolling ridges by sharply incised valleys with narrow, twisting valley floors. The contrast between upland moor and forest on the one hand and partially developed valleys on the other, is typical of central Wales and gives this landscape its particular and special character.

8.2 Whilst I accept the TAN 8 policy context, which presumes significant landscape change within the SSAs, the full implications of this stand to be assessed at this inquiry and at a level of detail beyond that employed by the Arup studies of 2004, 2005, 2006 and 2008 respectively and by Garrad Hassan in 2005. Throughout its evolution through to the local studies for Powys in 2006 and 2008, the landscape and visual work has been very largely desk based with some field checks. In as much as the 2008 exercise was primarily targeted at refining the 2006 boundaries essentially through extension, not contraction, the additional landscape and visual work undertaken was a reasonable basis, particularly as the edges of many of the otherwise acceptable zones were ruled out where turbines in these locations would potentially impact substantially on more enclosed adjoining areas. However, as I have argued at the Inquiry in respect of SSA C, I firmly believe that the Arup work is not a sound basis for assuming all of the land within the area is similarly suitable for wind farm development. Likewise I am consistent in this regard in respect of the weight to be given to the refined boundaries. They are not and should not be considered absolute rather they inform the judgement as to what may or may not be acceptable but should yield to the more detailed site specific assessments before this Inquiry. In terms of the five Carnedd Wen turbines it does, however, highlight an aspect of the scheme which suggests a potential sensitivity.

8.3 In respect of the two SSA B schemes, I consider the majority of the turbines of the two schemes to be acceptable in landscape and visual terms. The specific points of objection relate five of the Carnedd Wen turbines and to the Llanbrynmair local highway proposals.

8.4 The greatest and most significant visual impacts of the turbines of both schemes would be experienced across the whole Nant yr Eira Valley and the Banwy Valley, specifically its valley floor and its northern valley side. In the case of the Nant yr Eira Valley, the Llanbrynmair turbines would have greater effects, whilst in the case of the 45

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

Banwy Valley it would be the Carnedd Wen turbines that would have the greater magnitude of impact. In my judgement the visual change experienced by receptors within the Nant yr Eira Valley of the turbines would be substantial but that the scale and simplicity of the landscape of the plateau above the valley can visually accept the turbines. The same does not apply to the impacts of Carnedd Wen on the Banwy Valley.

8.5 Other than in respect of the two respective individual points of objection raised by Powys, the in-combination cumulative effects of the schemes together with the existing baseline of all other operational and consented wind farms would be acceptable in landscape and visual terms. The most sensitive consideration relates to the National Park but, in my judgement, there would not be any significant landscape character effects on the National Park, although there would be some significant cumulative visual effects where Cemmaes and the combined Carnedd Wen and Llanbrynmair would be seen in conjunction with each other at comparatively short range. The Carno turbines are already part of the existing baseline and contribute only minimally to the cumulative visual impact.

8.6 The prime purpose of Powys’ objection to the five Carnedd Wen turbines is to seek a partial mitigation of landscape and visual impacts on the landscape of the Banwy Valley through the removal of these five turbines. In my judgement, the removal of these, whilst this would not reduce by any means all of the effects on the valued characteristics and the valley’s high aesthetic quality, but it would remove those turbines which are closest, would have the greatest individual impacts and would help reinforce a desired perception that the wind farm is contained on the plateau and has not spilled-over into the valley.

8.7 The Llanbrynmair local highway proposals would have a severe impact on the small- scale, rural character of the lane and would significantly alter the experience of this part of the Outstanding scenic value of the Llanerfyl Mosaic Farmlands VSAA 422 area. In my judgement these effects would be unacceptable landscape and visual terms and sufficient to render the whole Llanbrynmair proposal unacceptable.

8.8 The Powys alternative would not be entirely without landscape effects, there would be some impact on intrinsic features such as the minor valley, but these would be barely perceptible from the publicly accessible locations within the wider landscape and the visual harm barely perceptible on the VSAAs affected and negligible on the High value Llanerfyl Mosaic Farmlands VSAA (422), host of the Nant yr Eira valley. 46

Mid-Wales Conjoined Wind Farms Inquiry Session 2: Strategic Search Area B Landscape Proof of Evidence of PG Russell-Vick October/November 2013

The Llanbrynmair highway proposals would cause substantial and unacceptable harm to the Nant yr Eira valley and the Powys alternative, if employed, would avoid this harm.