Mrs Ann Picton Resident Wentlooge Community Councillor WENTLOOGE RENEWABLE HUB: Ref:DNS/3216558 SUBMISSION BY 31st August 2020 1. INTRODUCTION As a resident of the Wentlooge Levels for 41 years and a member of Wentlooge Community Council I make the following observations in opposition to the DNS/3216558 application for the erection of a renewable energy hub on 155/162 ha of land enclosed by Hawse Lane, Broadway, the B4239/ Coast Road and the Great Western Railway Line on the Wentlooge Levels. I have attempted to read,absorb and evaluate the paperwork, presented in the DNS/3216558 application,vast as it is, in the short time available, and in the very, very current extraordinary conditions created by COVID-19 and am responding as a member of the public. Wentlooge Community Council is submitting a representation on behalf of Wentlooge Community Council representing the villages of of St. Brides, Wentlooge and Peterstone, Wentlooge. Other expert groups will be submitting their objections and I have tried to avoid any repetition. To clarify my position. Climate emergency is forcing nations to look at how we currently live, work and co-exist. In order that we have a world with a future to pass onto future generations renewable energy is embraced. However it is also critical to consider carefully the locations for such installations on a suitability/damage limitation basis whilst also honouring, preserving and protecting our green spaces for those future generations. I am objecting to this proposal on the grounds that it is an inappropriate facility in an SSSI. There are a complexity of interconnected elements that will be touched upon briefly. 2.THE FIRST MINISTER’S PLEDGE TO THE LEVELS This development flies in the face of the First Ministers decision on the proposed M4 relief road. The First Minister, Mr Mark Drakeford, turned down the proposed M4 relief road through the Gwent Levels not only on financial grounds but on environmental grounds because he saw the M4 proposal as a destructive development in opposition to the need to protect the Levels as part of our beautiful Welsh countryside and its green spaces. The FM attached “very significant weight to the fact that the Project would have a substantial adverse impact on the Gwent Levels SSSI’s and their reen network and wildlife and on other species and a permanent adverse impact on the historic landscape of the Gwent levels”. The concerns that prompted the First Minister to reject the plans for the proposed M4 relief road are equally relevant to the proposal for a massive solar farm to be built on the same Levels in Wentlooge. Taking account of the First Minister’s decision on the proposed M4 relief road there would be zero grounds for sighting a solar farm in the St Brides, Peterstone and Marshfield area of the Wentlooge Levels that will irreparably damage and shrink the Gwent Levels. In addition how in a million years, and in anyone’s imagination, can a solar farm be given the go ahead in such a sensitive location, a site of Special Scientific Interest, a registered landscape of Outstanding Historic Interest and close to the Severn estuary with its multiple international designations. This is a proposal covering 155/162 hectares of countryside, covering an area greater than that proposed for the M4 relief road. Solar farms are advised to be located in the areas identified by the Welsh Government for such installations or in identified brownfield sites. It is beyond belief that this proposal has been submitted. 3. COVID -19 INEQUALITIES COVID _19 has created massive problems for Wentlooge Community Council and its members and for all individuals, groups, working alone and together, making it impossible, in the time available, even with the extension of 10 days granted by the Planning Inspectorate, to gather with others, to hold meetings, to create and distribute leaflets, to knock on neighbours doors and generally go out and about and have important one to one discussions. These activities form part of the democratic process that on line facilities such as TEAM and ZOOM barely compensate for. Compare and contrast these difficulties faced by individuals and by our communities and groups with those faced by Savills, as the agents for Wentlooge Farmers’ Solar Scheme. Their preparation and planning had been completed by lock-down whilst our local population were drastically confined and constricted by lock-down. COVID -19 has had an enormous impact on the lives of people across the world. We must heed the lessons for how we will live in the ‘’normal future’. Building Better Places, The Planning System, Delivering Resilient and Brighter Futures, Placemaking and the COVID -19 Recovery , July 2020 have produced guidance for planners in which it is stated that living space must be better planned and outside green space for every family in gardens, parks and other areas is a prerequisite for well-being and survival in the future. 4. CHERISH, VALUE, PRESERVE AND PROTECT THE LEVELS The Gwent Levels of which the Wentlooge Levels forms a part is an ancient, beautiful, iconic landscape of international significance and is of exceptional historic and unique environmental value with nationally important wildlife habitats. It is the largest surviving area of grazing marshes and drainage reen and ditch systems in Great Britain, if not in Europe, and the Levels, in its entirety, is the largest of its kind in Wales. One of the roles of Welsh Government, Local Councils, Community Councils and individual citizens to protect the Levels. For any of us to allow the Levels, 155/162 ha of the St Brides SSSI, to be covered by solar panels, is unacceptable. We are all the guardians of our land and heritage. Our local Wentlooge Community Council and Marshfield Community Council, backed by our residents, work so very hard to maintain and improve the quality of life and the environment for the people who live and work on the Levels, for those who live further afield and for visitors from far and wide. We have recognised that it is our responsibility to protect the Levels, and for us our Wentlooge Levels, for the present and for the future, for our children and our children’s children and we ask that the authorities do the same. We would be failing in this duty should this solar farm be allowed to go ahead and a solar farm on such a massive scale! The proposal is so inappropriate for such a sensitive environment. The National Development Framework 2020- 2040 • Outcome 10, “ The variety of flora and fauna found across Wales makes Wales a special place. While biodiversity has declined in recent decades we will reverse those losses and enhance the resilience of ecosystems. The planning system will ensure wildlife is able to thrive in healthy diverse habitats, both in urban and rural areas, recognising and valuing the multiple benefits to people and nature. 5. NATIONAL RESOURCES WALES (NRW) NRW in their final submission to the M4 Public Inquiry rejected the proposed M4 relief road because the land take from the Gwent Levels was excessive. The land take in the Wentlooge Levels would be more, in fact one and half times plus more than that proposed to be taken from the Gwent Levels. This surely adds weight to the case for rejection of the DNS/3216558. “NRW considers the scale of permanent loss of SSSI in the Gwent Levels under the scheme is unprecedented and would not be in accordance with the statutory duties with respect to SSSIs under Section 28G of the 1981 Act and / or with respect to biodiversity and ecosystem resilience under Section 6 of the 2016 Act and would be contrary to national planning policy.” 6. PRE APPLICATION CONCERNS Concerns that Savills complied with the law with reference to the requirements of the pre- application period have been mooted? Have the rules been stretched in order to disempower local communities? Have Savills operated as a huge Goliath using a massive imbalance in resources to push through a proposal against small village communities. These concerns have been identified elsewhere by others in their representations. My concerns include: • Pre Application Notices for the exhibition organised by Savills in Peterstone Village Hall on 10th February 2020. None were found. • Pre Application contact with residents whose land or property adjoined the area of the proposed solar farm.This failed on numerous counts. Five households, to date, were not contacted • The Community exhibition on 10.02.2020 was of very poor quality with 5 or 6 photographs displayed, with limited text. Three then 4 representatives from Savills were there to answer questions. There were no handouts. On leaving, attendees were requested to fill in a questionnaire. • Accuracy of numbers attending the exhibition? Savills claim that the exhibition was well attended with 50 plus people. How this figure was arrived at is a mystery as in the two and a quarter hours of the three hours, 4pm – 7pm, that I was in attendance there were approximately 15 people maximum there. There was no attendance register to complete. • Publicity for this exhibition was exceedingly poor. There is no one who can vouch for seeing advertising for the exhibition in St Brides. Information was spread by word of mouth. • The community of Marshfield and Marshfield Community Council have been neglected by the agent Savills in all communications with regard to this solar farm application. The proposal does not include any land in Marshfield. However, the ES (2.12) states that the site lies between the settlement of Marshfield, Peterstone and St. Brides, but Marshfield Community Council was not contacted nor were any on its residents although the Y Meurin Public House, residents on Ty Mawr Lane, residents off the Broadway, residents in Pentwyn Terrace are all very close by to this proposal and all Marshfield residents will be within easy reach of it.