Mrs Ann Picton Resident 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 , 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 . 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 . 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. • Did the Pre application stage complied with the guidance: The Planning Inspectorate ‘DNS Procedural Guidance Version 2.1 June 2019. • It states in 2.9: “After the notification stage, prior to submitting a full DNS the proposed application must be publicised and consulted on for a period of at least six weeks. Unsure if ‘publicised and consulted and for six weeks was complied with. • In 2.10: It states, “ As a minimum, the applicant must “Consult specific community consultees, specialist consultees and any relevant persons” This was not complied with as the Community Council was not consulted with but only contacted to arrange the hiring of Peterstone village hall for 10.02.202. A ZOOM type meeting was suggested but never followed up or organised by SAVILLS. • It also states ‘Serve written notice on owners or occupiers of land adjoining the site’. This was not complied as a local livery business on the proposed site had no notification, neither did a business that owns land on the east side of Hawse Lane. • Also stated was ‘Display site notices, eligible for the DNS process, in at least one place on or near the site’. ‘Nil points’ on this one. Is it acceptable to fix notices in places least likely to be observed? What obligation is the developer under to replace lost defaced or damaged notices and ensure they are in place for 42 days? • Place a notice in a local newspaper. A notice was placed in the SW Argus although no one claims to have seen it! However, no notice was placed in the SW Echo, the preferred newspaper for Peterstone residents, the closest village to and whose residents all have Cardiff, CF postcodes. • The Community Council(s) in which the site is situated, as consultees, was consulted on the hiring of the village hall but the community council was never consulted as a body. A meeting was mooted by the developer but nothing further was pursued by them.

7. DESIGNATIONS THAT HAVE BEEN AWARDED MUST BE DEFENDED There are zero grounds for sighting a solar farm on the proposed land. This land has been awarded high value designations, designations that the First Minister recognised and has declared needs protection. The Wentlooge Levels and specifically here the St. Brides SSSI is located in • a Site of Special Scientific Interest (SSSI) as the wildlife, reens and ditch flora, fauna and and locality is of such a high quality. • a Register of Landscape of Outstanding Historic Interest • a designated Green Wedge by in the Local Development Plan • a Special Landscape Area • a close proximity to the Severn Estuary with its designations of RAMSAR a site for the Conservation and Protection of the Severn Estuary, also a Special Protection Area (SPA) and an SSSI • an Archaeological Sensitive Area • in the Cadw Register of Landscapes of Historic Interest in Wales • in close proximity to the Wales Coastal Path. The Coastal Path is the only pathway that runs alongside the entire coastal area of a country and is in close proximity to this proposal. In the autumn and winter, when the leaves have fallen from the trees what will be visible from the Wales Coastal Path? These designations are awarded for very, very special and specific reasons. Stringent conditions have to be satisfied before a designation is awarded. It is worth noting that all local people and those who rent land in the area have legally to comply with the strict rules and regulations of these designations both in their daily lives and in all planning applications.

8. MAINTENANCE OF THE GREEN WEDGE AND GREEN BELT BETWEEN NEWPORT AND CARDIFF Two proud cities. Two separate cities. Two cities intent on providing the best for its citizens. Two cities working hard alone and together as a team to ensure that they are thriving hubs, ensuring all its towns and villages are linked so that we become and remain places in which residents can live and prosper. Newport’s LDP makes repeated reference to maintaining the green space between Cardiff and Newport. To this end a Green Wedge status is awarded to St Brides and Green Belt status has been awarded to Peterstone in order to maintain that separation and prevent the one city sliding into the boundaries of the other. Keeping the openness and permanence in tact is the main aim of Green belts. Due to their strategic nature Green Belts have significance beyond a single local authority as the purpose of Green Belts is to: - prevent the coalescence of large towns and cities with other settlements; - manage urban form through controlled expansion of urban areas; - assist in safeguarding the countryside from encroachment - protect the setting of an urban area; and - assist in urban regeneration by encouraging the recycling of derelict and other urban land. The acceptance of this solar farm proposal by the Planning Inspectorate will counter this purpose.

9. ST BRIDES GREEN WEDGE AND THE CUMULATIVE IMPACT OF THE PROPOSED CARDIFF HENDRE LAKES DEVELOPMENT The Green Wedge was created by NCC in order to maintain green space between the cities of Newport and Cardiff, seeking definition and separation – see Newport City Council LDP. Cardiff as a city has few areas left into which it can expand. Their last forage towards Newport will be into land between Newport and Cardiff, a proposed land take from the Peterstone and Rumney SSSI (see S W Argus Article Wednesday August 5th, p. 11 “Business district between cities ‘to create 6,000 jobs’”. “ Measuring 90,000 sqm, the Cardiff Hendre Lakes development – which includes the planned Cardiff Parkway railway station site will bring connectivity, jobs and investment to . As a result of a positive approval of this site the Cardiff ‘built’ environment/boundary will then have moved right up to the border of Newport. This development will take more SSSI land from the Peterstone and Rumney SSSI. Newport will then be alone in its attempt to protect its green wedge and green belt between Newport and Cardiff and this si the land at risk with this solar farm submission. To illustrate: arriving at Shirenewton, just beyond Peterstone on B4329 route to Cardiff, there is one uninterrupted Industrial and Business Park, including Wentlooge Business Park, Aldi’s Distribution Centre, Neals, Cardiff Landfill, Rumney businesses and Tesco at Pengam with all spaces filled, on then into Cardiff. On the A48, Cardiff have also built right up to the border with Newport from Llanrumney to Old , onto Blooms Garden Centre and with new housing right up to to St Mellons Golf Club. In Green Lane, driving from Peterstone, the St Mellons Business Park has taken all the green space. This is close to where the Hendre Lakes Development is being planned, taking the last of the open green space in the Cardiff boundary with Newport. To maintain the Green Wedge and Green Belt between Newport and Cardiff as cited in NCC LDP dates no further land can be lost to development . It is crucial that the Wentlooge SSSI be protected.

10. SUPPORT FOR WELL- BEING AND HEALTH The Gwent Levels lie so near to Cardiff and Newport and because of this the preservation of such a green lug matters even more. The division between town and country for both cities is as sharp as a line across a map. In the Wentlooge Levels lies green space, historic places, bird life and wildlife, places to walk, to cycle and to enjoy in peace and tranquillity with time away from the hustle and bustle of city life. Here there is time to relax from the pressures of busy work and family lives. From my upstairs windows, not far from the proposed site, and on my travels towards Peterstone, Marshfield and Newport I see garden birds, Swans on the reen and gathering in great flocks, Starlings with heir murmurations, “ one of Britain’s great wildlife spectacles”, stretching and twisting before settling for the night in nearby Leyllandi. I see also Collared Doves, Magpies squabbling with each other and with Crows, Jackdaws, Ravens and grey squirrels, Swallows, House Martins and Swifts, Sparrow Hawks, Kestrels and Peregrines, Mallards with their young, Moorhens, Coots, Grey Herons, Little Egrets and bats captured on our security cameras as they swoop and dive in the dusk of evenings. Kingfishers nest in Hawse Lane. The green spaces were recognised in the nineteenth century by the likes of W H Davies, born in 1871 in and a visitor to the Church House Inn in St Brides Wentlooge. All those years ago his famous poem ‘Leisure’ talks about peace, tranquillity and of all things essentially rural, a poor life indeed he says, if there is not time to stand and stare. Stare at what , certainly not 155/162 ha of Solar panels. His message is as pertinent to this solar farm proposal as it was to the M4 Public Inquiry. An ode to the Wentlooge Levels:? Leisure What is this life if, full of care Streams full of stars, like skies at night. We have no time to stand and stare. No time to turn at Beauty’s glance’ No time to stand beneath the boughs And watch her feet, how they can dance. And stare as long as sheep or cows. No time to wait til her mouth can, No time to see, when woods we pass Enrich the smile her eyes began. Where squirrels hide their nuts in grass. A poor life this if, full of care, No time to see, in broad daylight, We have no time to stand and stare

In Building Better Places: The Planning System. Delivering Resilient and Brighter Futures, Place making and the COVID -19 Recovery, July 2020 and in a Forward by Julie James MS, Minister for Housing and Local Government 15: “ a poor environment with no or limited access to local goods, services and green spaces can have a detrimental impact on our mental and physical health and well-being, as well as our ability to protect our livelihoods”. “We need to rebuild a greener, cleaner society with de-carbonisation and social justice at its heart which respects our environment, whilst giving people good places to live in, which are accessible on foot, bike and public transport.

11. AN OPEN INVITATION TO DEVELOPERS TO WHITTLE AWAY THE REST OF THE WENTLOOGE LEVELS. To permit a proposal of such magnitude in such a precious and iconic area will open the flood gates to developers. Approval will tantamount be an open invitation to developers to seek and destroy the rest of the Wentlooge Levels and also to nibble away at the rest of the Gwent Levels. Where will it stop? When all our SSSI’s have been lost? When there is nothing left of the Levels? It will represent the thin edge of the wedge and other developers will jump on the bandwagon. If agreed this proposal will take over 12% of the entire SSSI Levels. The First Minister pledged to protect and preserve the Levels in 2019 and not lower the drawbridge to developers. So much land has already been lost on the Levels and recently to the LG site, to , to St Modwens, to Celtic Business Park, to Europark and to Tesco Distribution Centre. REF: S W Business Argus: 02.05.17

12. INAPPROPRIATE JUSTIFICATION FOR THE SIGHTING OF A SOLAR FARM. WELSH GOVERNMENT PRIORITY SEARCH AREA FOR SOLAR AND WIND ENERGY DOES NOT INCLUDE THE WENTLOOGE LEVELS OR INDEED THE GWENT LEVELS AT ALL “The developer must demonstrate the case for development and why it could not be located on a site of less significance for nature conservation”. This is not demonstrated . The reasons given, by Savills representatives, at the public meeting on 10.02.2020 to justify the location of the solar farm were twofold: firstly - the flatness of the land, thus cheaper for installation and secondly - good access to the national grid provided by Network Rail as a result of the electrification of the Swansea to Paddington GWR rail line. . Savills were quite open with these admissions. Cheapness and convenience is no justification for the desecration and diminution of an SSSI. Savills have boasted that this solar, if approved, will be a Mini Hinckley Point. To suggest an area is suitable for the development of a solar farm, for investor profit, based on the flatness of the terrain and a convenient connection to the National Grid is unacceptable. Wentlooge/St. Brides SSSI is not a brownfield site nor is it identified either by NCC or the Welsh Government as a site suitable for Solar ground installations. Surely compulsory installation of solar panels and PV panels on the roofs of all new buildings and on suitable current building stock with excess sell back to the grid is a more effective model along with installing ground source heat pumps on new builds and air source hear pumps on all other suitable buildings. The proposal will have an unacceptable impact on its surrounding - its wild life, flora, fauna and aquatic life as colleagues will demonstrate.The proposal should therefore be rejected.

13. ASSESSMENT OF ENVIRONMENTAL STATEMENT Could ‘satisfactory’ ‘sufficiently’ and ‘reasonable alternatives’ be improved upon? “The aim of the ES is to provide a systematic and objective account of the significant environmental effects likely to arise from the proposed development including sufficient information to verify the conclusions and identify the source of the information provided”. Schedule 4 of the 2017 Regulations specifies the information to be included in the ES. The Inspector Hywel Wyn Jones states the description of the development in Chapter 2 and Chapter 3 is ‘satisfactory’. What does satisfactory mean? The ES demonstrates in Chapter 6 (11) that ‘reasonable alternatives’ have been properly considered by the applicant. What does ‘reasonable alternatives ‘ mean? Point 14 states that aspects of the environment likely to be significantly affected is described as ‘complete and satisfactory. What does satisfactory mean? Description of the likely significant effects of the development on the environment states that the technical chapters of the ES generally provide adequate descriptions(15). The likely significant effects of the development on the environment have been systematically assessed and are sufficiently described. What does sufficiently described mean? The mitigation measures are described as satisfactory. What again does satisfactory mean? The provision of a Non- Technical Summary was provided(22) and the information contained therein was sufficient. What does ‘sufficient’ mean?

14. THE ROLE OF THE LIVING LEVELS The 'Living Levels', financed through a lottery grant,supported by Newport City Council, recognises that the Wentlooge Levels and the Levels in general is a historic and vibrant place. Living Levels is currently working with farmers and tenants, but interrupted by COVID 19, in order to give the Levels a sustainable future. This future will involve farmers, landowners, renters and tenants maximising their skills, diversifying products, celebrating and sharing successes, increasing production by improving the quality of land, reens, ditches, trialling crops and products, producing high quality farm kite marked products possibly for sale in first class farm shop scenarios. Loss of land to solar farming does not fit in with this vision for the future. A solar farm in St Brides This is a for profit investment opportunity with no spin off or rewards for local people and WITH all electricity going to the grid.

15. SSSI's AND MITIGATION Not my area of expertise and covered by others. I offer the following. No mitigation of any value has been offered. What has taken centuries to develop cannot be compensated for by mitigation. The designation features of SSSI’s cannot be mitigated. An area is worthy of protection because it has been awarded an SSSI. We need therefore to protect it. Fobbing off with fences, extra land, planting of wild flowers, reen clearance, hedge removal etc is unacceptable. You cannot compensate for what should not have been done in the first place!! Ecologist Tom Heath 'Costing the Earth' says

“DON'T PROMISE THAT YOU CAN CREATE WHAT IS LOST”

16. IMPACT OF SOLAR ON THE ENVIRONMENT .

‘The UK has adopted solar powered electricity generation as part of the national energy landscape. Due to the spatial requirements of utility scale solar PV developments the sheer scale of them which is required for profitability, the physical landscape of UK inhabitants will be affected by the implementation of this technology necessitating an understanding of the potential effects that solar PV may have on diversity. The lack of ecological evidence is heavily under representative of the interest and investment in solar PV deployment. There is a dearth of robust scientific and peer reviewed publications. It is urgently needed if the solar farm industry is to progress

17. FINAL STATEMENT How much of what remains of the Levels is handed on to future generations to enjoy, to roam and to marvel at depends on the extent to which we can limit the damage done by major developments like the proposed solar farm. To try and solve a problem that can be met by other means, by taking land that is is protected is unacceptable. Once this land is taken and destroyed it can never be replaced or rejuvenated. It will become a ‘brownfield site.

You can walk for miles in solitude between dense hedges and tall reed beds, along grassy tracks, through our ancient villages on the Wentlooge Levels, passing beautiful churches, farms and buildings and along the coastal path that follows, as closely as possible, the sea wall observing grazing marsh, woodlands, salt-marsh, open mosaic habitats, birds, sea waders, bats, dormice, water voles, otters, great crested newts, protected and notable species, aquatic vegetation, insect and invertebrate species, badgers, the great crested newt and other amphibians,

I ask the Planning Inspectorate to think ahead and into the future, to keep the Levels sacrosanct, so that generations to come will be proud of what we have protected.

Ann Picton 9 Nellive Park St Brides Wentlooge