BUTTINGTON QUARRY ENERGY RECOVERY FACILITY

Response to formal request for further information under Regulation 15(2) of the DNS () Regulations 2016 for further information

ECL Ref: ECL.001.01.02/FIR ISSUE: FINAL August 2021

TABLE OF CONTENTS

1. INTRODUCTION 1

2. RESPONSE TO THE OBJECTION OF THE 3

3. RESPONSE TO THE LOCAL IMPACT REPORT 4

4. RESPONSE TO THE OBJECTIONS MADE BY BIIG 5

APPENDICES

Appendix 1: Response Regarding Landscape and Visual Matters Appendix 2: Technical Note on Noise Appendix 3: Technical Note on Geotechnical Appendix 4: Critical review of BIIG responses to dispersion modelling report Appendix 5: Written Statement on Economic Issues Raised Appendix 6: Response Regarding Heritage Matters

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ACRONYMS/TERMS USED IN THE TEXT

BIIG Incinerator Impact Group CCS Compliance Classification Scheme DfT Department for Transport DNS Developments of National Significance EA Environment Agency ERF Energy Recovery Facility ES Environmental Statement HGV Heavy Goods Vehicle HIA Health Impact Assessment HZI Hitachi Zosen Innova ITL Intermodal Transportation Limited LVIA Landscape and Visual Impact Assessment LIR Local Impact Report PIA Personal Injury Accidents PINS The Planning Inspectorate PM2.5 Particulate matter with a diameter less than 2.5µm RHPG Registered Historic Park and Garden TA Transport Assessment TAN Technical Advice Note WHIASU Wales Health Impact Assessment Support Unit WHO World Health Organization

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1. INTRODUCTION

1.1. Overview

1.1.1. This report addresses the formal request for further information under Regulation 15(2) of the Developments of National Significance (Wales) (“DNS”) Regulations 2016 (as amended) for further information.

1.1.2. The matters that will be addressed in this report are as follows: • A response to the objection of the National Trust (REP003) regarding the impact of the proposal on the Registered Historic Park and Garden (“RHPG”); • Any response that the applicant wishes to make to the Local Impact Report (“LIR”) from CC. The following areas have been included in this response: • the Landscape and Visual Impact (“LVIA”) of the proposal and the assessment of significance [LIR Paragraphs 5.39-5.51], • impacts on nearby properties as a result of noise [LIR Paragraphs 5.100- 5.109]; and • geotechnical issues including slope stability [LIR Paragraphs 5.110-5.116]; • responses to the objections made by the 2. (“BIIG”) (and other objectors). Issues raised include • the effect of the ERF on air quality especially possible issues with temperature inversion; • impacts on human health; • highway safety issues, • the effect on the local economy, and • the adverse impacts on local cultural heritage.

1.1.3. The information that will be provided in the response to be submitted by the 24th September will be as follows: • The Welsh Government has recently published its Programme for Government 2021- 26 and Well-Being Statement (available on Gov.Wales). The Well-being Statement sets out the Welsh Government’s latest well-being objectives, which are aligned to the well-being goals derived from the Well-Being of Future Generations Act; the Programme for Government sets out a series of actions through which the objectives will be met. The fifth well-being objective is to Embed our response to the climate and nature emergency in everything we do. The associated action commitments indicate a drive to reduce and avoid including legislation to abolish the use of more commonly littered, single use plastics and the introduction of an extended producer responsibility scheme to incentivise waste reduction by businesses. The applicant is invited to comment on the proposal’s consistency with these objectives/commitments and the direction of travel that they indicate. • Broad Energy (Wales) Limited also requested the opportunity to submit further information on the Welsh Government Strategic Assessment. This response is also closely aligned with points made in the LIR for the regional need for an Energy Recovery Facility (“ERF”) (paragraphs 5.1 – 5.11) and BIIGs comments on the waste planning statement. A combined response will therefore be provided; • the points made in the LIR with regard to the potential for the re-use of material within the site and as secondary aggregate [5.10, 5.115, 5.118]; and

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• matters which were raised by BIIG in relation to: • sustainability issues (including Carbon generation as a result of ); and • alternative sites.

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2. RESPONSE TO THE OBJECTION OF THE NATIONAL TRUST

2.1. Introduction

2.1.1. The Planning Inspector requires a response to the objection of the Nation Trust (REP003) regarding the impact of the proposal on the Registered Heritage Park and Garden (“RHPG”) and listed building at Powis (included comments of ).

2.1.2. In addition, it has been requested that the applicant should cross-refer to the analysis of the impact from Viewpoint 24 in the Landscape and Visual Impact Assessment (“LVIA”) and consider if supplementary viewpoints and information should be supplied as suggested by the National Trust.

2.2. Response

2.2.1. Comments raised by the National Trust are addressed in Section 2 of Bright and Associates Report “Response Regarding Landscape and Visual Matters”, August 2021, provided as Appendix 1 of this report.

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3. RESPONSE TO THE LOCAL IMPACT REPORT

3.1. Landscape and Visual Impact

3.1.1. This section specifically considers the Landscape and Visual Impact (“LVIA”) of the proposal and the assessment of significance [LIR Paragraphs 5.39-5.51].

3.1.2. Matters raised in the LIR, and those raised in Appendix 2 of the Landscape Input to the LIR on behalf of Powys County Council (Enplan) (May 2021) may be found within Section 3 of Bright and Associates Report “Response Regarding Landscape and Visual Matters”, August 2021, which may be found as Appendix 1 of this report.

3.2. Noise

3.2.1. This section specifically considers the impacts on nearby properties as a result of noise [LIR Paragraphs 5.1005.109].

3.2.2. A Technical Note has been prepared in response to the comments in the LIR and may be found as Appendix 2.

3.3. Geotechnical

3.3.1. This section specifically considers geotechnical issues including slope stability [LIR Paragraphs 5.110-5.116].

3.3.2. A Technical Note has been prepared in response to the comments in the LIR and may be found as Appendix 3.

3.4. Materials Re-Use

3.4.1. As mentioned in Paragraph 1.1.3., the points made in relation to the re-use of material within the site and as secondary aggregate [LIR Paragraphs 5.10, 5.115, 5.118] will be addressed in the response to be submitted to the Planning Inspectorate on the 24th September 2021.

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4. RESPONSE TO THE OBJECTIONS MADE BY BIIG

4.1. Comments on the Health Impact Assessment in Response to Appendix 2 of BIIG Submission

4.1.1. The BIIG objections to the HIA highlight, and repeat, shortcomings identified within the HIA of both the consultation process and the level of participation. These are key aspects to a meaningful and comprehensive HIA.

4.1.2. Invitations were sent to a range of stakeholders on more than one occasion requesting if they would like to take part. Many of those asked were within public sector organisations, and a number of those organisations have endorsed the ten National Principals for Public Engagement in Wales. It is acknowledged that these principals are aimed at public service organisations within the Public and voluntary sectors in Wales, with no specific remit for engagement with the private sector.

4.1.3. Lack of engagement was raised as a concern at the Stakeholder meeting, along with querying whether it was the appropriate time for starting the HIA and requesting engagement when there were very few technical details that had been confirmed. Members of the Group expressed concern about engaging with and trying to comment on a development proposal lacking full details. However, delivering an HIA after the design has been developed creates scope for unintended consequences and requirement for re- design at further costs and time delays, potentially affecting the viability of a development.

4.1.4. The concerns of HIA timing and lack of engagement were put to a couple of members of WHIASU who confirmed there is no prescribed timings for delivering HIA’s and it was accepted that too early, or late, in a development cycle could lead to problems. It was suggested that lack of engagement from public sector organisations may be due to perceived conflict of interest. These aspects severely limit the delivery of a truly holistic HIA.

4.1.5. In their submission, BIIG repeat paragraphs from the WHIASU and Welsh Government guidance in respect of HIA and the importance of stakeholder engagement and collaboration. Large sections of the submission criticise the lack of meaningful engagement on the part of Broad and ECL. It is understood that at least one member of BIIG attended a drop-in session but did not engage with the HIA team. We would have welcomed the opportunity to engage in further dialogue with BIIG at that time, as this would have better informed the HIA process.

4.1.6. The impartiality of ECL has been questioned, and criticised, with an assumption that if the developer is paying for the HIA then what is produced will only be what the developer wants. The whole point of HIA is to be transparent and holistic. It is important to note that the developer had no opportunity to influence what outcome there would be, negative or positive.

4.1.7. The lengths that members of BIIG have gone to get their points across, supported with detailed research, and raised their concerns in respect of the proposed development, is impressive and commendable. Had a lot of this information, alternative data sources and

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local knowledge been made available through engagement then the HIA could have been more locally informative, and potentially through discussion, concerns and fears could have been addressed.

4.1.8. We would hope that should the development be approved, the members of BIIG would join the community liaison group which would open a channel of dialogue that would be of benefit to the community as a whole.

4.1.9. For the purposes of clarification, both Public Health Wales and Public Health were invited to engage but both declined due to potential conflict of interest.

4.2. Comments on the Public Consultation in Response to Appendix 3 of BIIG Submission

Public Consultation during COVID-19

4.2.1. The original Public Consultation for the Buttington ERF was planned for May 2020. Venues had been booked well in advance, however, due to the COVID-19 pandemic this was cancelled.

4.2.2. Dialogue was held with the Planning Inspectorate (“PINS”) in relation to how best to procced, and an outline consultation strategy was submitted for comment. PINS confirmed that the submitted strategy was positive, end encouraged the applicant to proceed with those aspects of the strategy that went beyond the statutory minimum requirements. Broad Energy therefore proceeded with a virtual consultation using a combination of traditional and digital consultation techniques.

4.2.3. In relation to the comment that ECL emailed BIIG “…….for the first time late on 4th July 2019 with an attachment but no covering message referencing public engagement sessions…..”, the Figure 4-1 below would evidence the contrary. Whilst the cover email does not specify the dates of the consultation, it clearly references the purpose of the email, as does the subject of the email.

Figure 4-1: Email sent to BIIG Re Consultation

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4.2.4. As stated in the Pre-Application Consultation report (SEC Newgate Report, February 2021), Broad Energy sought to go above and beyond in delivering a consultation that they considered to allow all parties to comment on. The following was undertaken as part of the consultation: • Leaflet drop (consultation booked and feedback form with free post envelope) to every property in a 3.02 mile radius of the site (over 3,200 properties); • Two online webinar sessions; • Dedicated email for comment: • Dedicated freephone line number; • Project website with FAQs updated throughout the consultation; • Adverts placed in local newspaper; • Pro-active press releases; • Site notices; and • COVID secure drop in session.

4.3. Response to Comments made on Chapter 3: The Need

4.3.1. The comments made on Chapter 3 will be addressed in the submission to be made to the Planning Inspectorate on the 24th September.

4.4. Response to Comments made on Chapter 6: Air Quality

4.4.1. Eight main concerns were raised by BIIG in relation to Air Quality. There are summarised as follows: 1. advice from 2015 from Powys County Council Planning was that a development would be extremely difficult to justify at this location due to the complex relief of the area; 2. cold air can accumulate to a great depth due to the unique glacial geomorphology of the area which may not have been taken account of in the modelling; 3. pollution will be concentrated in the /Middletown area due to grounding of the plume; 4. recirculation of polluted air, from cold air drainage, may not have been taken into account in the modelling; 5. pollution limits are constantly being revised downwards, reasonable reanalysis of BE data indicates Cr VI will exceed permitted thresholds by a factor >3 times; 6. based on more recent WHO guidelines, PM2.5 and SO2 concentrations should also be re-assessed; 7. the landscape will amplify the collection and damage caused by pollutants downwind from the plume which cannot freely disperse; and 8. repeated breaches of emission permits are known to take place.

4.4.2. Points 1-4 and Point 7 have been addressed by Cambridge Environmental Research Consultants (“CERC”) in their report Critical review of BIIG responses to dispersion modelling report which can be found in Appendix 4 of this report. Points 5, 6 and 8 are discussed below.

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Points 5 and 6

4.4.3. Point 5 and 6 appear to largely relate to the same concern, namely that emission limits for various pollutants are too high. The pollutant emission limit values (“ELVs”) used in the air dispersion modelling are those that would be set by Natural Resources Wales (“NRW”) in the Environmental Permit that the Installation will be required to operate under. The modelling has been undertaken on the assumption that the Installation will operate discharging the various pollutants at the maximum ELVs 24 hours a day, 7 days a week, which in reality will not be the case. Consequently, the actual ground level concentrations will be lower that those predicted, and in some cases substantially so.

4.4.4. Should the emissions limits prescribed by NRW be reduced in response to any recommendations by the World Health Organisation (“WHO”), then the Installation would have do be able to comply with these emission limits in order to continue to operate.

Point 8

4.4.5. It is acknowledged that some incinerators do have breaches of their emission limits, however, these are the incinerators, such as the Edmonton Incinerator, that are around 40 years old and are coming to end of life. There are other incinerators, of a similar age, that use fluidised bed technology which again have breaches of emission limits.

4.4.6. The technology being proposed for the Buttington ERF is modern moving grate incinerator to be provided by Hitachi Zosen Innova (“HZI”). The Environment Agency (“EA”) (used as an example as there are no HZI plants in Wales) use compliance ratings to assess the risk from a regulated facility. Based on how many breaches an installation has, and the severity of a breach the EA assigns an operator performance rating. This forms part of the Compliance Classification Scheme (“CCS”). CCS scores are as follows: • minor breaches (e.g. no impact on human health, quality of life or the environment) would incur a score of 0.1 points; • less serious breaches (e.g. minor impact on human health, quality of life or the environment) would incur a score of 4 points; • serious breaches (e.g. significant impact on human health, quality of life or the environment) a score of 31 points; and • most serious (e.g. major impact on human health, quality of life or the environment), a score of 60 points.

4.4.7. Operator performance bands are as follows: • Band A – 0 points; • Band B – 0.1-10 points; • Band C – 10.1-30 points; • Band D – 30.1-60 points; • Band E – 60.1-149.9 points; and • Band F – 150+ points.

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4.4.8. Existing HZI moving grate installation in the UK, together with their operator performance rating include1: • Ferrybridge Multifuel Plants No 1 & 2 – Band A; • Greatmoor Waste Facility - Band A; • Severnside EFW - Band B; • Newhaven ERF - Band A; • Riverside - Band A; • EnviRecover - Band B; and • Teesside EFW Plant #3,#4 and #5 (Haverton Hill) – Band B.

4.4.9. It can be seen from the information in Section 5.4.8. that all of HZI’s plants, which will be of similar design to the Buttington ERF, are all either Band A, and therefore have no breaches of permit conditions (and therefore no breaches of emission limits) or are Band B and therefore have had less serious breaches which will have had a minor impact.

4.4.10. Consequently the claim with regard to repeated breaches of emission limits is not true for the type of Installation being proposed at the Buttington ERF. Any plants with serious breaches of environmental permits would be classed in Band D as a minimum.

4.5. Response to Comments made on Chapter 7: Socio-Economic

4.5.1. A written statement, prepared by Filkin & Co EHS has been prepared in response to the concerns of BIIG as is included as Appendix 5 of this report.

4.6. Response to Comments made on Chapter 8: Highways and Transportation

4.6.1. This following response has been produced by Intermodal Transportation Ltd (“ITL”) and considers the comments raised by the BIIG in relation to Chapter 8 of the Environmental Statement (“ES”) for the Buttington Energy Recovery Facility (“ERF”). For ease of reference the same numbering system as adopted by the BIIG has been utilised. 1. The BIIG indicate that they will not comment in detail on the data provided within Chapter 8 of the ES and indicate that is for the statutory consultees to do. ITL would highlight that neither Powys County Council in their role as Local Highway Authority or The Government Office in their role as trunk road authority have raised an objection in relation to the proposal.

2. ITL would reaffirm that it is their experience that highway policy looks to focus HGV movements to higher category roads and that trunk roads sit towards the upper end of the highway route hierarchy. The fact that HGV movements are focussed towards higher category roads is borne out by the Department for Transport (“DfT”) publication: Road Traffic Estimates: Great Britain 2019, which indicates that 46% and 45% of traffic carried by motorways and A roads respectively is HGV traffic whereas only 9% of traffic carried by minor roads is HGV traffic. It is acknowledged that the

1 https://environment.data.gov.uk/portalstg/home/item.html?id=bc28b2b53d0e49eb8bd4188875955650

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latest version of the publication was produced in 2020 but ITL would confirm that it does not appear to include a similar summary.

3. The distribution of traffic quoted by BIIG relates to non-HGV traffic during the operational phase of the development and the distribution used within the assessment for HGV traffic during the operational phase was 40% from the north and 60% from the south as referenced in the pre-app document.

4. Chapter 8 of the ES confirms that during the operational phase of the development there would be 100 two way HGV movements per day attracted to the site. Therefore, on the basis that the A483 carries in excess of 900 HGVs per day, as quoted by the BIIG, ITL calculate that if half of the operational phase HGVs used the road, which is considered unlikely, that would represent a 5.6% uplift in HGV levels and not 6% as suggested by the BIIG. Notwithstanding the latter, it is considered that in context the expected average hourly traffic flows associated with the proposal during the operational phase should be regarded as modest only and would be unlikely to materially affect the operation of the local road network.

5. As noted above at item 4, chapter 8 of the ES confirms that during the operational phase of the development there would be 100 two way HGV movements per day attracted to the site. Furthermore, those movements would be split 40% to/from the north and 60% to/from the south as such as a worst case there is likely to be 40 HGV movements per day using the stretch of the A458 referenced by the BIIG and not 100 as they have suggested.

6. Table 8-9 of the ES confirms that on average during the operational phase the ERF would only attract 4 HGV arrivals and 4 HGV departures per hour. In the context of a development site with direct access to a trunk road, ITL maintains that traffic increases of that nature should be regarded as modest.

7. ITL would confirm that the development site is approximately 1.5km by road from the residential properties at Parc Caradog and the adjacent school and therefore is not located within a congested inner area or residential neighbourhood. Furthermore, the proposal would have direct access to one of the road types suggested to be appropriate by Technical Advice Note (“TAN”) 18 for developments of this nature, i.e. a trunk road. As such, ITL maintain that the proposal would not be contrary to the quotation from TAN18 contained at paragraph 8.2.9 of the ES.

8. As confirmed above at item 7, TAN18 indicates that developments of this nature should be served by a number of higher category roads including trunk roads. As such it is considered that the proposal is accessed by a suitable highway and therefore complies with the section of Policy W2 quoted at paragraph 8.2.12 of the ES.

9. ITL does not dispute that Personal Injury Accidents (“PIAs”) were recorded to occur within the agreed study area during the period assessed and would highlight that chapter 8 of the submitted Transport Assessment (“TA”) sets out a summary of the PIAs recorded to occur in the study area. ITL would clarify that, as stated in the TA, during the period analysed out of a total of 21 recorded PIAs there were 6 PIAs within

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the study area that involved HGVs and 5 PIAs were recorded on Cefn bridge of which 3 involved HGVs. As noted within the TA, it is considered that the modest additional traffic levels associated with the development proposal would be unlikely to materially affect the safety record of the local road network.

10. The accidents listed by the BIIG at point 10 did not occur within the agreed study area for the proposal and therefore were not analysed within the TA report. The Highway Authorities for this area will be aware of the road safety record of the local road network and if they felt that the proposed development would have an adverse effect on the sections of road in question, at the scoping stage of the project, they would have requested that they be included within the study. That did not, however, occur and as such they were not assessed within the TA.

11. The three accidents discussed at point 11 by the BIIG to occur at the Cefn bridge are considered within the TA report and their occurrence does not, therefore, change the conclusions of the TA report.

12. The accidents listed by the BIIG at point 12 occurred after completion of the TA and hence were not assessed within the study.

13. The factors referred to by the BIIG at point 13, particularly items 1 and 3, are abnormal occurrences and as such it would not be appropriate to base the assessment of the proposal on scenarios that include for them. In terms of item 2, i.e. that flows on the A458 can be seasonally affected, ITL would highlight that as demonstrated within Chapter 8 of the ES the development proposal would be likely to attract only modest traffic flows, which would be unlikely to materially affect the operation of the local road network. Furthermore, it is considered that peak hours associated with holiday traffic are unlikely to coincide with the peak traffic hours of the proposal, which are likely to be at shift changeover times.

14. As noted above at point 1, neither of the parties that published ‘The Marches and Mid-Wales Freight Strategy’, which is referenced by the BIIG, has raised an objection to the proposal. As such, ITL would assume that they have concluded that, notwithstanding any perceived deficiencies on the local road network, the modest level of development traffic would be unlikely to materially affect the operation of the local road network.

15. ITL would conclude that contrary to the comments of the BIIG: - • The submitted TA and Chapter 8 of the ES do not understate the vehicle movements associated with the development proposal; • The submitted TA and Chapter 8 of the ES do not fail to respect the perceived weakness of the local road network and that having undertaken a balanced and considered review they concluded that the modest level of development traffic would be unlikely to materially affect the operation of the local road network. The latter appears to have been accepted by Powys County Council in their role as Local Highway Authority and The Government Office in their role as trunk road authority, neither of which have raised an objection in relation to the proposal; and

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• The proposal would not be contrary to the quotation from TAN18 contained at paragraph 8.2.9 of the ES.

4.7. Response to Comments made on Chapter 9: Landscape and Visual Impact

4.7.1. Matters raised in relation to comments made by BIIG may be found within Section 4 of Bright and Associates Report “Response Regarding Landscape and Visual Matters”, August 2021, which may be found as Appendix 1 of this report. 4.7.2. It should also be noted that comments in relation to Chapter 9 were also made by Cadw, Town Council, Trewern Community Council and the Campaign for the Protection of Rural Wales – . These are addressed in Section 5 of Bright and Associates Report “Response Regarding Landscape and Visual Matters”, August 2021, which may be found as Appendix 1 of this report.

4.8. Response to Comments made on Chapter 12: Archaeology and Heritage

4.8.1. Matters raised in relation to comments made by BIIG may be found within Orion Heritage Report’s Response Regarding Heritage Matters, August 2021, which may be found as Appendix 6 of this report.

4.9. Response to Comments made on Chapter 15: Health Impact Assessment

4.9.1. The comments made by BIIG in their response titled “Comments by BIIG on Chapter 15: Health Impact Assessment (“HIA”), are largely the same as those made in BIIG’s Appendix 2, Submission by BIIG as part of the Pre-App consultation. Consequently these have been addressed in Section 5.1 above.

4.10. Response to Comments made on Waste Planning Statement

4.10.1. As stated in Paragraph 1.1.3. of this report, Broad Energy (Wales) Limited requested the opportunity to submit further information on the Welsh Government Strategic Assessment. As this response is also closely aligned with points made in the LIR for the regional need for an Energy Recovery Facility (“ERF”) (paragraphs 5.1 – 5.11) and BIIGs comments on the waste planning statement. A combined response will therefore be provided to the Planning Inspectorate by the 24th September 2021.

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APPENDIX 1 Response Regarding Landscape and Visual Matters

ECL Ref: ECL.001.01.02/RFI August 2021 Issue: Final BROAD ENERGY (WALES) LTD.

Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys

Formal request for further information under Regulation 15(2) of the Developments of National Significance (Wales) Regulations 2016 (as amended) for further information (Reference DNS/3214813)

Response Regarding Landscape and Visual Matters

August 2021

bright & associates landscape and environmental consultants

CONTENTS

1. INTRODUCTION ...... 1 1.1. PREFACE ...... 1 1.2. STRUCTURE OF THE REPORT ...... 1 2. RESPONSE TO NATIONAL TRUST COMMENTS ...... 3 2.1. INTRODUCTION ...... 3 2.2. VIEWPOINT LOCATION 24 FROM IN THE LVIA ...... 3 2.3. COUNTRY LIFE MAGAZINE ARTICLE (1901) ...... 8 2.4. NATIONAL TRUST ADDITIONAL/ALTERNATIVE VIEWPOINTS ...... 8 2.5. MAGNITUDE OF IMPACT DURING CONSTRUCTION PERIOD ...... 12 2.6. MAGNITUDE OF IMPACT DURING OPERATION ...... 12 2.7. STACK HEIGHT AND PLUME ASSESSMENT ...... 13 2.8. NATIONAL TRUST SUMMARY ...... 13 3. RESPONSE TO THE LOCAL IMPACT REPORT ...... 15 3.1. INTRODUCTION ...... 15 3.2. SCOPE OF THE LVIA ...... 15 3.3. LVIA METHODOLOGY ...... 17 3.4. LANDMAP AND EVALUATION OF LANDSCAPE SENSITIVITY ...... 26 3.5. SELECTED CLADDING COLOURS ...... 31 3.6. LANDSCAPE MITIGATION PROPOSALS ...... 32 3.7. APPLICATION SITE - ASSESSMENT OF IMPACT/EFFECT ...... 32 3.8. APPLICATION SITE - VISUAL AND SENSORY ASPECT AREA ...... 34 3.9. LOCAL VISUAL AND SENSORY ASPECT AREAS ...... 35 3.10. VISUAL EFFECTS...... 35 3.11. ASSESSMENT OF CONSTRUCTION AND DECOMMISSIONING PHASES IN THE LVIA ...... 35 3.12. ASSESSMENT OF CUMULATIVE EFFECTS ...... 36 3.13. LOCAL IMPACT REPORT CONCLUSIONS - HIGHER-LEVEL SIGNIFICANT LANDSCAPE AND VISUAL EFFECTS...... 37 3.14. PLANNING POLICY ...... 63 4. RESPONSE TO BIIG COMMENTS ...... 67 4.1. INTRODUCTION ...... 67 4.2. THE DESIGN COMMISSION FOR WALES (DCW) ...... 67

4.3. RELATIONSHIP TO PUBLISHED POLICIES AND ADVICE ...... 67 4.4. ADVERSE IMPACT ON MENTAL HEALTH ...... 72 4.5. ADVERSE IMPACT ON TOURISM ...... 73 5. OTHER OBJECTOR COMMENTS ...... 78 5.1. INTRODUCTION ...... 78 5.2. CADW (LETTER DATED 2 JULY 2021) ...... 78 5.3. WELSHPOOL TOWN COUNCIL ...... 78 5.4. TREWERN COMMUNITY COUNCIL ...... 79 5.5. THE CAMPAIGN FOR THE PROTECTION OF RURAL WALES (CPRW) MONTGOMERYSHIRE (DATED RECEIVED 19 MAY 2021) ...... 80

FIGURES Figure L1 (July 21) Photograph PC1 From Castle East Front Porch, Existing View (Panoramic view) (BT1180-D18v1) Figure L2 (July 21) Photograph PC1 From Castle East Front Porch, Existing View (Single photograph) (BT1180-D18v1) Figure L3 (July 21) Photograph PC2 From the End of the East Terrace, Existing View (Panoramic view) (BT1180-D19v1) Figure L4 (July 21) Photograph PC2 From the End of the East Terrace, Existing View (Single photograph) (BT1180-D19v1) Figure L5 (July 21) Photograph PC3 From the Bowling Green Terrace, Existing View (Panoramic view) (BT1180-D20v1) Figure L6 (July 21) Photograph PC3 From the Bowling Green Terrace, Existing View (Single photograph) (BT1180-D20v1) Figure L7 (July 21) Photograph PC3 From the Bowling Green Terrace, Photomontage view (Single photograph) (BT1180-D20v1) Figure L8 (July 21) Photograph PC4 From East Facing Windows within the Castle, Existing View (Single photograph) (BT1180-D21v1) Figure L9 (July 21) Photograph PC5 From East Facing Windows within the Castle, Existing View (Single photograph) (BT1180-D21v1) Figure L10 (July 21) Photograph PC5 From East Facing Windows within the Castle, Photomontage view (Single photograph) (BT1180-D21v1)

APPENDICES Appendix 14 Sheet 2: Viewpoint 24, View of proposed ERF building together with illustrated likely maximum visible plume length

Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

1. INTRODUCTION

1.1. PREFACE 1.1.1. Bright & Associates (B&A) carried out the Landscape and Visual Impact Assessment (LVIA) which assessed the proposed Buttington Quarry Energy Recovery Facility near Welshpool, Powys. The LVIA formed Chapter 9 and Technical Appendix 9-1 of the Environmental Statement (ES). B&A also provided information for the Design and Access Statement (February 2021). 1.1.2. B&A were appointed by ECL (the Agent) on behalf of Broad Energy (Wales) Limited (the Applicant) to undertake the LVIA. 1.1.3. The Planning Inspectorate issued a formal request for further information under Regulation 15(2) of the Developments of National Significance (Wales) Regulations 2016 (as amended) for further information (Reference DNS/3214813) to the Applicant on the 12 July 2021.

1.2. STRUCTURE OF THE REPORT 1.2.1. This report contains the B&A Response to the following matters raised in the formal request. 1.2.2. 1. ‘A response to the objection of the National Trust (REP003) regarding the impact of the proposal on the RHPG and listed buildings at Powis Castle (see also the comments of Cadw). The applicant should cross-refer to the analysis of the impact from Viewpoint 24 in the LVIA and consider if supplementary viewpoints and information should be supplied as suggested by the National Trust’. Comments raised by the National Trust Consultation Response (May 2021) are addressed in Section 2. 1.2.3. 3. ‘Any response that the applicant wishes to make to the Local Impact Report (LIR) from Powys CC. for information, the Inspector wishes to discuss the following issues in the Hearing sessions: … the Landscape and Visual Impact (LVIA) of the proposal and the assessment of significance [5.39-5.51]…These matters may be addressed in the Hearing Statements’. Matters raised in the Local Impact Report (May 2021) and Appendix 2 Landscape Input to the Local Impact Report on behalf of Powys County Council (Enplan) (May 2021) are addressed in Section 3. 1.2.4. 4. ‘Any response that the applicant wishes to make to the objections made by BIIG (and other objectors). Issues raised include matters to be addressed in the Hearings …’ Comments By BIIG regarding Chapter 9: Landscape and Visual Impact are addressed in Section 4. Comments from cadw, Welshpool Town Council, Trewern Community Council and the Campaign For The Protection Of Rural Wales – Montgomeryshire are addressed in Section 5.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

1.2.5. This response includes Appendix 14 Sheet 2: Viewpoint 24, View of proposed ERF building together with illustrated likely maximum visible plume length. 1.2.6. Additional photographs have been taken from four Viewpoint Locations at Powis Castle as follows:  Figure L1 (July 21) Photograph PC1 From Castle East Front Porch, Existing View (Panoramic view) (BT1180-D18v1);  Figure L2 (July 21) Photograph PC1 From Castle East Front Porch, Existing View (Single photograph) (BT1180-D18v1);  Figure L3 (July 21) Photograph PC2 From the End of the East Terrace, Existing View (Panoramic view) (BT1180-D19v1);  Figure L4 (July 21) Photograph PC2 From the End of the East Terrace, Existing View (Single photograph) (BT1180-D19v1);  Figure L5 (July 21) Photograph PC3 From the Bowling Green Terrace, Existing View (Panoramic view) (BT1180-D20v1);  Figure L6 (July 21) Photograph PC3 From the Bowling Green Terrace, Existing View (Single photograph) (BT1180-D20v1);  Figure L7 (July 21) Photograph PC3 From the Bowling Green Terrace, Photomontage view (Single photograph) (BT1180- D20v1);  Figure L8 (July 21) Photograph PC4 From East Facing Windows within the Castle, Existing View (Single photograph) (BT1180- D21v1);  Figure L9 (July 21) Photograph PC5 From East Facing Windows within the Castle, Existing View (Single photograph) (BT1180- D21v1); and  Figure L10 (July 21) Photograph PC5 From East Facing Windows within the Castle, Photomontage view (Single photograph) (BT1180-D21v1) 1.2.7. Reference is made to Technical Appendix 9-1 Landscape and Visual Impact Assessment including paragraphs, Appendices and Figures. This is referred to as the LVIA in this report. 1.2.8. Distance is given from the proposed stack as per the LVIA (LVIA, paragraph 2.2.4). 1.2.9. Footnotes provide reference sources.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2. RESPONSE TO NATIONAL TRUST COMMENTS

2.1. INTRODUCTION 2.1.1. This Section addresses the comments raised by the National Trust relating to Powis Castle (May 2021) concerning landscape and visual matters. The relevant paragraph has been extracted (National Trust Comment) with a response by B&A addressing issues raised (B&A Response).

2.2. VIEWPOINT LOCATION 24 FROM POWIS CASTLE IN THE LVIA Choice of Viewpoint Location at Powis Castle 2.2.1. National Trust Comment: ‘National Trust consider that the submitted scheme underestimates the level of landscape, visual and heritage harm at Powis Castle’. 2.2.2. ‘Section 6.9.1. of the Landscape and Visual Impact Assessment (LVIA) provides one viewpoint (Location 24) from Powis Castle …This is a wholly inadequate assessment of the role of long-distance views in the setting of the Grade 1 listed building and Grade 1 Registered Park and Garden…’. 2.2.3. B&A Response: The GLVIA Third Edition1 is the primary source for landscape professionals when undertaking LVIAs. It states that ‘The viewpoints to be used in an assessment of visual effects should be selected initially through discussions with the competent authority and other interested parties at the scoping stage. But selection should also be informed by the ZTV analysis, by fieldwork, and by desk research on access and recreation, including footpaths, bridleways and public access land, tourism including popular vantage points, and distribution of population’. (GLVIA Third Edition, paragraph 6.18) 2.2.4. The choice of Viewpoint Locations assessed in the LVIA went through a rigorous process over a number of years in line with the GLVIA Third Edition including during the Scoping process in 2018 and pre-application stage in 2020. In total, 35 Viewpoint Locations were assessed. 2.2.5. The LVIA explains the selection of Viewpoint Locations. Consideration was given to views from Powis Castle following the pre-application consultation process. LVIA, paragraph 6.4.2 is provided below.

1 Guidelines for Landscape and Visual Impact Assessment (Third Edition), Landscape Institute and Institute of Environmental Management and Assessment, 2013

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.2.6. ‘The selection of Viewpoint Locations has taken into account comments in the Scoping Direction and following the recent pre-application consultation process. Viewpoint Location 24 is from Powis Castle and the photograph is taken from the upper garden terrace on the north-eastern side of Powis Castle. B&A has been informed by Powys County Council that a planning application has been submitted to open up the east garden of Powis Castle to the public. On the basis of information received, B&A consider that the Viewpoint Location included in this LVIA and assessment to be a rigorous choice’. (LVIA, paragraph 6.4.2) 2.2.7. It should be noted that no request was received from other third parties apart from Powys County Council regarding further views. Nevertheless, additional Viewpoint Locations have been assessed as part of this response and are assessed later in this Section. 2.2.8. Mitigation measures are described in detail in Section 4 of the LVIA. With regards to architectural design, ‘Careful consideration has been given to known sensitive receptors including views from cultural heritage sites such as Powis Castle and Garden together with views along key tourist routes into Wales. Such factors have influenced the siting of proposed built form and landscape proposals incorporated into the Landscape Masterplan’. (LVIA, paragraph 4.2.10) 2.2.9. As part of this response, a review has been undertaken of the description and findings of the LVIA regarding Viewpoint Location 24 From Powis Castle. 2.2.10. This particular Viewpoint Location is south-west of the Site within long range (6.4km). The photograph is taken from a terraced area (c.138mAOD). Receptors include visitors to Powis Castle (National Trust) which is also categorised as a Grade I Registered Park and Garden of Special Historic Interest in Wales. Receptor sensitivity is classified by B&A as Very High. 2.2.11. Figures L78 to L80 of the LVIA are relevant and present a panoramic and single photograph which show the existing view. LVIA Figure L80 includes the photomontage view (single photograph). 2.2.12. The current situation is described and the LVIA highlights that ‘The architectural and scenic merits of Powis Castle and its gardens hold the viewer to scrutinise close range views rather than the available distant backdrop. Thus, the property itself is the key feature’. (LVIA, paragraph 6.9.1) The same paragraph draws attention to the main aspect being eastwards across the Severn Valley, whilst the Site is to the north-east. 2.2.13. Outwith the environs of Powis Castle are views of Welshpool comprising residential areas and industrial buildings. The latter are evident adjacent to the A483 north of Welshpool.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.2.14. Both the proximity of Welshpool and the reduced influence of other aspects at a further distance can be appreciated through the photograph. Reference to the LANDMAP Survey Details for the MNTGMVS762 Welshpool Visual and Sensory Aspect Area refers to the close association between Welshpool and Powis Castle to the south-west. As demonstrated by the photograph, it is also evident vice-versa. 2.2.15. Elsewhere, the photograph shows the pattern of agricultural fields and small woodland tracts at a lower level with a glimpsed view of the Site against a backdrop of rising landform. LVIA paragraph 6.9.2 concludes ‘The Powis Castle estate is sufficiently distanced from the Site to offer no direct visual link or association and it is also seen in a wider context. with its large areas of coniferous woodland is a notable feature and provides part of the backdrop’. 2.2.16. The assessment of Viewpoint Location 24 recorded the following:  During Construction: There will be likely views of crane movements and other aspects (e.g. building construction, scaffolding and ground works) associated with the building of the ERF and ground modelling within the Site. The assessment took into account potential views of crane movements which could increase magnitude of impact from a Small to a Medium level. Generally, a Moderate (neutral) significance of effect will apply albeit, with some Major (neutral) significance of effects. (LVIA, paragraph 6.9.4);  During Operation: There will be likely views of the upper elevations of the ERF building and stack against a backdrop of higher ground seen at an acute angle. In terms of mitigation measures, the choice of natural cladding colours would assist in assimilating the proposed built form into a mainly rural visual setting. The Development would introduce new elements but this would represent a minor component of the wider setting and would not affect the general quality of the visual amenity. A Small magnitude of impact and a Moderate (neutral) significance of effect was recorded. (LVIA, paragraph 6.9.5); and  During Decommissioning: Effects mainly resulted from the intermittent views of crane movements. Whereas, the distance and angle of view would restrict views of Site activities associated with ground restoration. A Small magnitude of impact and a Moderate (neutral) significance of effect was noted. (LVIA, paragraph 6.9.6) 2.2.17. Appendix 1 of the LVIA provides the full methodology used to assess impacts and effects. To assist in understanding the above:

 A Small magnitude of impact would equate to ‘Where the development would introduce new or additional elements but would constitute only a minor component of the wider view which the casual observer could miss or where awareness does not affect the overall quality of the scene’. This would apply to During Operation and Decommissioning. (LVIA, Appendix 1, Table 1E: Visual (Magnitude of Impact);

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

 A worst case scenario was considered During Construction with a Medium magnitude of impact which applies ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E: Visual (Magnitude of Impact); and  A Moderate significance of effect applies ‘Where the development will be clearly visible and results in some changes to the view, but the main elements of the baseline visual context remain’. This would generally apply to all Phases apart from During Construction for crane movements. As a worst case scenario, a Major significance of effect may result. This would equate to ‘The development results in changes that largely affect the view, or where the baseline visual context alters, such that the development is one of the principal visual elements unmistakably or easily seen’. (LVIA, Appendix 1, Table 1F: Significance of Effect). 2.2.18. The assessment considered that a neutral rather than adverse nature of effect would apply to all Phases, in part, due to the distance and magnitude of change involved. Furthermore, the built elements of Development are not visually overbearing or intrusive and will be viewed against rising ground as opposed to the skyline. (LVIA, Appendix 1, paragraphs 1.10.1 to 1.10.10) 2.2.19. Having reviewed the above as part of this response, the conclusions of the LVIA reached by B&A are robust. Appeal (Extension to Existing Dairy at Lower Leighton Farm) (APP/T6850/V/12/2169855P) 2.2.20. National Trust Comment: ‘The importance of the landscape and heritage setting of the terraces at Powis Castle was recognised in the deliberations of the application and Appeal (Extension to Existing Dairy at Lower Leighton Farm) (APP/T6850/V/12/2169855P). Para 208 of the Inspectors decision relates to the setting of Powis Castle “Over 100,000 people would potentially experience this view each year and the fact that this would be a key part of most people’s visits to Powis Castle gardens makes this a highly sensitive location. The assessment of sensitivity made by the applicant’s landscape and heritage witness seems unable to give any weight to the huge numbers of people affected from this viewpoint”. 2.2.21. B&A Response: The National Trust (May 2021) refers to the above Public Inquiry held in 2013 regarding an extension to an existing diary unit at Lower Leighton Farm near Welshpool and the comments made in the Inspectors Report. 2.2.22. B&A accepts that views from Powis Castle are highly sensitive which is reflected in the Very High sensitivity level applied to visitors to Powis Castle in the LVIA.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.2.23. The comparison that the National Trust (May 2021) makes to the Public Inquiry is not helpful in this context when taking into account the very different locations, scale and type of development. The effects of one cannot demonstrate parallel conclusions to another. It is important to note the following disparities:  The Site currently operates in accordance with a Review of Mineral Permissions (ROMP) under the Environment Act 1995 (Reference P/2010/0165). Most of the Site including the existing quarry void being allocated for B1, B2 and B8 employment development under Policy E1 Employment Proposals on Allocated Employment Sites in the Adopted Powys Local Development Plan 2011 – 2026 (April 2018). (LVIA, paragraph 3.2.5) It is understood that the National Trust did not object to the allocation of the Site as employment land;  The Development restricts permitted quarrying and incorporates a restoration proposal which is better than presently exists;  In contrast to the Site, the extension at Lower Leighton Farm involves the removal of a ‘natural green area’ (Inspector Report, paragraph 209);  It is important to note the geographical differences between the Development and that of the diary unit at Lower Leighton Farm. The latter is closer to Powis Castle (c.2895 metres) whilst the Site is c.6366 metres away from Powis Castle; and  Lower Leighton Farm is to the east of Powis Castle and is viewed across the Severn Valley. Whereas, the Site is to the north-east and as noted previously, is viewed at a long range against a backdrop of landform. The environs of Welshpool including residential and industrial development are viewed at a closer range for receptors. This is evident through LVIA Figures L78 to L80. Landscape and Heritage Setting 2.2.24. B&A Response: B&A wish to clarify the differences between the assessment of heritage and landscape setting. 2.2.25. The purpose of the LVIA is to consider landscape and visual impacts whereas, addresses heritage matters are dealt with in Chapter 12 Archaeology and Heritage of the ES. The GLVIA Third Edition notes that although cultural heritage and LVIAs may refer to similar baseline sources (e.g. historic landscape characterisation), there is ‘a danger of both double handling and inappropriate judgements by non-experts. It is particularly important that responsibilities are clear in considering any effects on the settings and views for historic buildings, Conservation Areas and other heritage assets’. (GLVIA Third Edition, paragraph 5.11) 2.2.26. Cadw letter (dated 21 May 2021) to The Planning Inspectorate states that the methodologies used in the ES for both Chapter 9 and 12 were suitable. This is provided in full below.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.2.27. ‘The application is accompanied by an environmental impact assessment, which includes chapters on the landscape and visual impacts of the scheme and also the impact of the proposed development on archaeology and heritage including an assessment of the impact on the settings of the designated historic assets. 2.2.28. The methodologies used to determine these impact are appropriate and the additional visual impact caused by emissions from the working plant, which we raised in our pre-consultation response, has been considered. The environmental impact assessment concludes that the proposed development will have no impact on the settings of the majority of the designated historic assets. However, where an impact will occur this will not have more than a minor but not significant, adverse effect. We concur with this conclusion’. 2.2.29. B&A is satisfied that the approach adopted in the LVIA is correct and appropriate to assess the landscape setting.

2.3. COUNTRY LIFE MAGAZINE ARTICLE (1901)

2.3.1. National Trust Comment: ‘An article in Country Life magazine from January 5th, 1901 states that the terraces ‘... command surpassingly beautiful views, the most delightful of all being through a long vista of trees to the distant peaks of Moel-y-golfa and the Breidden Hills.’ 2.3.2. B&A Response: The comments in the Country Life magazine were made at the beginning of the 20th century and can only reflect the landscape at the time. They do not account for changes which may have occurred since such as development in and around Welshpool. 2.3.3. As stated previously, at Viewpoint 24 From Powis Castle, the LVIA determined that the stack will be viewed below the skyline. Additional photographic evidence included with this response also illustrates this point which is addressed next. In all cases, long distance views of Moel-y-Golfa and the Breidden Hills range will not be affected.

2.4. NATIONAL TRUST ADDITIONAL/ALTERNATIVE VIEWPOINTS

2.4.1. National Trust Comment: ‘The Conservation Management Plan for Powis Castle and Garden identifies key views from the property including the view from East front towards the development site’. 2.4.2. ‘We would suggest that several additional/alternative viewpoints are required including: the end of the East Terrace adjoining the sculpture, the easterly view from the Bowling Green terrace on the east front and from the lower bowls lawn terrace. Views of the scheme will also be possible from the Castle East Front porch at higher level and also from all floors and roof of the Castle on the East Front’. 2.4.3. B&A Response: Viewpoint Location 24 From Powis Castle which is assessed in the LVIA shows the view from the end of the East Terrace.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.4.4. Four additional Viewpoint Locations have been assessed as part of this response. The photographs presented were taken in July 2021. A panoramic view and single photograph is included for external views. Whilst a single photograph is included for the internal view. A photomontage view has been prepared for two Viewpoint Locations, namely, the Bowling Green Terrace and the East Facing Windows within the Castle. 2.4.5. Each Viewpoint Location has been taken in turn and assessed using the methodology adopted for the LVIA. (LVIA, Appendix 1) In all cases, receptor sensitivity is Very High for visitors to Powis Castle. Photograph PC1: From Castle East Front Porch

Refer to Figure L1 (July 21) and Figure L2 (July 21)

2.4.6. The photograph is taken from the steps at the East Front Porch of Powis Castle (c.6.4km south-west). 2.4.7. Views are possible further north but are greatly restricted by the East Terrace itself and a mature tree which is a prominent feature. Long Mountain can be seen to the right of Photograph PC1, with more restricted views of the Breidden Hills to the north. 2.4.8. The Site is hidden by the foreground tree as indicated. In winter, with a reduction in leafcover, a glimpsed view of the Site may be possible. However, this will not weaken the broader scene encompassing a backdrop of hills noted above and the setting of the Severn Valley. 2.4.9. In the mid-distance, the residential and industrial environs of Welshpool has developed without significantly affecting the setting of Powis Castle from this particular location. When considering the Development, the increased distance, the scale of the proposals and incorporated architectural mitigation measures, it is not unreasonable to expect the Development to have a lesser degree of effect in comparison. 2.4.10. The Development has an expected lifespan of 30 years. It has been assumed that the mature tree at the end of the East Terrace is likely to remain for the duration of the Development. However, as stated, the LVIA does not rely on the screening properties and should the tree be removed, this will be not constitute a significant effect. There will be No Impact during all Phases during summer months. Effects during winter would not be notable. Photograph PC2: From End of East Terrace

Refer to Figure L3 (July 21) and Figure L4 (July 21)

2.4.11. The photograph is taken from the end of the East Terrace from the path in front of the sundial at Powis Castle (c.6.4km south-west).

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.4.12. In comparison to the previous location, Photograph PC2 is closer to the foreground tree which restricts broader views further north and is a prominent feature. Long Mountain can be seen to the right of the photograph with limited views of the Breidden Hills to the north. 2.4.13. The Site is hidden by the foreground tree as indicated. In winter, with a reduction in leafcover, a glimpsed view of the Site may be possible. However, this will not weaken the broader scene encompassing a backdrop of hills as mentioned previously and the setting of the Severn Valley. 2.4.14. In the mid-distance, the residential and industrial environs of Welshpool has developed without significantly affecting the setting of Powis Castle from this particular location. When considering the Development, the increased distance, the scale of the proposals and incorporated architectural mitigation measures, it is not unreasonable to expect the Development to have a lesser degree of effect in comparison. 2.4.15. The Development has an expected lifespan of 30 years. It has been assumed that the mature tree at the end of the East Terrace is likely to remain for the duration of the Development. However, as stated, the LVIA does not rely on the screening properties and should the tree be removed, the will be not constitute a significant effect. There will be No Impact during all Phases. Photograph PC3: From the Bowling Green Terrace

Refer to Figures L5 to L7 (July 21)

2.4.16. The photograph is taken from the Bowling Green Terrace which is north of the steps leading to the East Front Porch at Powis Castle (c.6.4km south- west). 2.4.17. Northerly views are framed by the mature vegetation in the grounds of Powis Castle (Photograph PC3). The Site can be seen in the distance as part of a broader area of land with a backdrop of the Breidden Hills. 2.4.18. Figure L7 (July 2021) shows the photomontage view and illustrates the Development, namely the proposed ERF building and stack. A maximum plume length is shown. 2.4.19. In the mid-distance, the residential and industrial environs of Welshpool has developed without significantly affecting the setting of Powis Castle from this particular location. When considering the Development, the increased distance, the scale of the proposals and incorporated architectural mitigation measures, it is not unreasonable to expect the Development to have a lesser degree of effect in comparison. 2.4.20. The results replicate those of the LVIA as set out earlier, namely During Construction, generally there will be a Small magnitude of impact which may rise to a Medium level due to potential views of crane movements. This will result in a Moderate (neutral) significance of effect albeit, with some Major (neutral) significance of effects.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.4.21. During Operation and Decommissioning, a Small magnitude of impact and Moderate (neutral) significance of effect will apply. Photograph PC4 and PC5: From East Facing Windows within the Castle

Refer to Figures L8 to L10

2.4.22. The photograph presents an internal view from windows at Powis Castle (c.6.4km south-west). 2.4.23. Most views from internal rooms are not available to the public given the window shading in operation. However, the principle of the view and the potential amenity is accepted. 2.4.24. Photographs PC4 and PC5 show the view north across the gardens at Powis Castle. The raised elevation increases the broader panoramic view, notably of the industrial environs of Welshpool in the mid-distance, the Severn Valley together with Long Mountain and the Breidden Hills further away. However, this does not allow clearer views of the Site. 2.4.25. When compared to Photograph PC3 and also Viewpoint Location 24 (in the LVIA), this will have a similar magnitude of impact. 2.4.26. In summary, having reviewed the results of both the LVIA and the additional Viewpoint Locations considered in this response:  The additional assessed Viewpoint Locations have not recorded an increased magnitude of impact when compared to Viewpoint Location 24 From Powis Castle in the LVIA. In several cases, the mature ornamental planting within the gardens at Powis Castle can reduce northerly views towards the Site, notably in summer months;  B&A considered different Viewpoint Locations during the preparation of the LVIA and is satisfied that Viewpoint Location 24 is a good representation of the typical view from Powis Castle;  The additional Viewpoint Locations assessed demonstrate a similar or lower magnitude of impact;  A maximum plume length is illustrated on the photomontage views for Photographs PC3 and PC5. When considering the angle of view, it is not very different from the average visible plume shown on Viewpoint Location 24 (LVIA, Figure L80);  The selected colour cladding scheme complements the landscape setting and reduces visual recognition of the Development. The proposed stack is viewed below the skyline as shown by Photograph PC3 From the Bowling Green Terrace and Photograph PC5 From East Facing Windows within the Castle;  Photographs PC1 to PC5 show comparable views and context of the visual amenity to Viewpoint Location 24. Therefore, B&A reject the view that there would be a higher magnitude of impact from Powis Castle. The narrative provided in the LVIA and summarised earlier in this response is appropriate; and

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

 Viewpoint Location 24 is comparable to other additional viewpoints considered as part of this response and therefore, validates the robustness of the LVIA. It provides an elevated view and is set back from the mature tree at the end of the East Terrace, thereby, offering a view across the grounds of Powis Castle. It encompasses an expansive view of the Severn Valley to the east, environs of Welshpool and also the Site, Longmountain and the Breidden Hills to the north. The Site is c.6.4km north-east of Powis Castle.

2.5. MAGNITUDE OF IMPACT DURING CONSTRUCTION PERIOD

2.5.1. National Trust Comment: ‘The magnitude of impact in the LVIA states that during construction the impact would be ‘Small (generally) Medium (worst case scenario). National Trust challenge this conclusion in the absence of any consideration of cranage and lighting. We consider these will bring forward Medium to Large effect considering the open views obtained from the East Front and also considering that Powis Castle is a Very High Receptor’. 2.5.2. B&A Response: As per the additional assessments undertaken, the magnitude of impact During Construction will be higher and this is accepted in the LVIA as discussed earlier. 2.5.3. Taking account of the visual assessment, we are confident of the LVIA’s robustness and consistency. This should not be confused with a consideration and review of the cultural heritage setting which is not the purpose of the LVIA. It should be noted that the construction period will be temporary (c.3 years) and the crane movements will be intermittent during that period given that cranes will be required for specific uses rather than on a continual basis. This will also apply During Decommissioning.

2.6. MAGNITUDE OF IMPACT DURING OPERATION

2.6.1. National Trust Comment: ‘During Operation, the LVIA states that the Impact would be ‘Small’. Although the building structure may be partially obscured and ‘Small’, the visibility of the Plume from the stack would be visible during operation and could be Medium to Large, again considering the open views to the wider landscape of the Powis site and also the higher ground that it sits on’. 2.6.2. B&A Response: As part of this response, a new photomontage view has been prepared for Viewpoint Location 24 From Powis Castle which was assessed in the LVIA. Previously an average visible plume was shown for the visual Figure (LVIA, Figure L80). 2.6.3. As stated in Chapter 6 Air Quality of the ES ‘The prevailing wind direction is from the south/south-west, with the majority of wind measurements falling between southerly and westerly directions. A very small percentage of wind comes from the remaining wind directions…’. (Chapter 6 Air Quality, paragraph 5.1.12)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.6.4. A comparison between the two photomontage views shows that there is little difference. This is due to fact that the direction of travel is broadly in line with the line of sight from Powis Castle and effectively shortens the visible length. It should be noted that although a summer view is shown due to the time of year when photographs were taken, winter weather criteria is used when calculating the length of the plume. 2.6.5. B&A maintains that a Small magnitude of impact applies for the reasons set out earlier in this Section.

2.7. STACK HEIGHT AND PLUME ASSESSMENT

2.7.1. National Trust Comment: ‘National Trust consider that the stack height and plume visibility will have important implications for concluding the level of harm from long distance views to and from Powis Castle’. 2.7.2. B&A Response: A maximum plume length is illustrated on the photomontage views prepared as part of this response for Photograph PC3 and PC5. When considering the angle of view, it is not very different from the average visible plume shown on Viewpoint Location 24 (LVIA, Figure L80). Consequently, there will be no greater effect in visual or landscape terms.

2.8. NATIONAL TRUST SUMMARY 2.8.1. The National Trust raised a number of issues relevant to landscape and visual matters in their summary. 2.8.2. National Trust Comment: ‘The scheme underestimates the level of landscape, visual and heritage harm from Powis Castle, additional work should be completed to that provided in the submission relating to Viewpoint 24 including the content of the Conservation Management Plan Key Views’. 2.8.3. B&A Response: See Sections 2.4 to 2.7 in this response. 2.8.4. National Trust Comment: ‘Additional viewpoints should be taken from Powis Castle East Front to inform the submitted LVIA and Heritage Assessment and consider winter and summer seasonality for long distance views. 2.8.5. B&A Response: See Section 2.4 of this response. 2.8.6. National Trust Comment: ‘Assessments and CGIs regarding impacts at the construction phase and operational phase for night-time, together with the consideration of issues at dawn and dusk’. 2.8.7. B&A Response: In so far as it concerns landscape and visual matters. A night-time view has not been prepared for Viewpoint Location 24. Given the distance from Powis Castle, it is not expected that the proposed lighting scheme at dawn, dusk or during the night will lead to significant effects.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

2.8.8. The LVIA included an assessment of night-time views from six Viewpoint Locations (4, 6, 7, 11, 21 and 22). The assessment concluded that the proposed lighting scheme will not have a significant adverse effect. (LVIA, paragraph 6.16.23), The full assessment is provided in Section 6.16 of the LVIA and relevant visuals can be found in LVIA Appendix 11 (Sheets 1 to 6). 2.8.9. National Trust Comment: ‘Assessment of lighting levels, fittings, quantity, area of illumination, assessment of viewpoint sensitivity. Further information is required within the submission to establish the principle of an acceptable scheme on long distance landscape and visual harm…’ 2.8.10. B&A Response: See response above.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

3. RESPONSE TO THE LOCAL IMPACT REPORT

3.1. INTRODUCTION 3.1.1. This Section addresses issues raised in the Local Impact Report and Appendix 2 Landscape Input to the Local Impact Report on behalf of Powys County Council (Enplan). The latter is referred henceforth as LIR Appendix 2. 3.1.2. The Local Impact Report does not always include exact quotations from Appendix 2 and it is not made clear whether Enplan or Powys County Council as the Local Planning Authority prepared the Local Impact Report itself. 3.1.3. The relevant paragraph has been extracted (Local Impact Report Comment) with a response by B&A addressing issues raised (B&A Response).

3.2. SCOPE OF THE LVIA

3.2.1. Local Impact Report Comment: ‘The LPA finds the scope of the LVIA to be appropriate. The LVIA includes, in addition to a landscape and visual impact assessment, a night time effects assessment, a limited cumulative assessment and landscape capacity. Furthermore, it is understood that B&A’s assessment work has informed the design development of the appearance of built form as well as the preparation of landscape mitigation proposals’. (paragraph 5.39) 3.2.2. B&A Response: Regarding the scope of the LVIA, we would like to draw attention to its contents and the preparation process involved. 3.2.3. It is noted that the Local Impact Report concludes that the scope of the LVIA is appropriate (LIR, paragraph 5.39). Further to the above, the LVIA considered winter views regarding cladding colours and the plume visibility emanating from the stack. The LVIA also assessed the proposed access road during the construction phase. We disagree with the opinion that the cumulative assessment was limited and this matter is addressed separately later in this Section. 3.2.4. At this stage it is useful to summarise the planning process involved in the preparation of the LVIA which has been undertaken over a number of years. This has involved detailed discussions with PCC and consultees, the Design Commission for Wales (DCW) and a review of a draft version of the LVIA by Enplan. These are important matters when considering the assessment of landscape and visual effects which is commented on later:

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

 August 2018: Chapter 9 of the Request for Scoping Direction2 set out the approach of the LVIA including best practice and guidance along with the assessment of landscape and visual effects. Section 9.5 Points of Clarification requested confirmation that no other potentially sensitive landscape or visual receptors were to be considered. With regards to cumulative effects, Section 17.2 Environmental Assessment Boundaries states that consideration will be given to developments in excess of 1 hectare that have been subject to EIA. Developments in the planning system that are not yet permitted will only be taken into account if requested by PINS or PCC (paragraph 17.2.2);  October 2018: Paragraph 7.4 of the EIA Scoping Direction3 set out additional viewpoint locations to consider put forward by Cadw and the Clwyd Powys Archaeological Trust. A request was made that that consultation should take place with neighbouring Council. No reference was made to cumulative effects and to the approach to be adopted in the LVIA specifically. Paragraph 6.5 refers to cumulative effects on a broad basis and finds the approach set out in the Request for Scoping Direction (in paragraph 17.2.2) acceptable. Further consideration should be given dependent on the topic area and using the professional judgement of consultants. Appendix 1: Consultation Responses includes comments from PCC in relation to the cumulative effects concerning transport matters. Mention is made to the planning department providing a list of other planning applications which may require consideration;  July 2020: Design Commission for Wales (DCW) this involved preliminary discussions and comments regarding the design concept and building appearance were received. The presentation to the DCW included Plans showing the Zone of Theoretical Visibility (ZTV) demonstrating the area of potential visibility based on the upper elevations of the energy recovery hall and the stack together with the proposed Viewpoint Locations to be assessed. The Plans were submitted to the DCW in the same month;  October 2020: Review of the LVIA by Enplan: The review requested the inclusion of further presentational material in the LVIA including wireframes and cross sections. A request was made for additional narrative text to be included for the Visual Impact Assessment. Enplan concluded ‘In any case the real landscape and visual effects of the proposals are, in the round, quite modest, especially for similar EfW schemes with which I’m familiar, principally due to the quarry location and valley location which together restrict the magnitude and extent of the effects, as well as the well-considered design. I’m likely to conclude something along the same lines of the LVIA’4; and

2 Request for Scoping Direction, ECL Ref: ECL.001.01.02/RFS, Issue 1, ECL, August 2018 3 DNS: EIA Scoping Direction 3201953: Buttington Quarry, Proposed Energy Recovery Facility, The Planning Inspectorate, 3 October 2018 4 Correspondence by email, Phillip Russell-Vick (Enplan) to Robin Wynne Williams, 15 October 2020

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

 September 2020: Pre-Application Process. A draft version of the LVIA was issued as part of the pre-application consultation process (14 September to 26 October 2020). Table 1: Pre- Application Consultation Summary (Landscape and Visual Matters) of the LVIA lists issues raised by PCC regarding the technical data used for the illustrated plume, the inclusion of wireframes and cross sections. All of the requests were complied with in the final version of the LVIA in the opinion of B&A. (LVIA, Table 1: Pre-Application Consultation Summary (Landscape and Visual Matters)). No reference was made to the approach adopted for assessment of cumulative effects. 3.2.5. Enplan has undertaken a review of the LVIA on behalf of Powys County Council (May 2021) (LIR Appendix 2). Paragraph 1.2 refers to the wireframes which are provided in the LVIA (Appendix 13). 3.2.6. For their assessment in LIR Appendix 2, Enplan have used the same categories of sensitivity, magnitude and level of significance set out in the tables in the LVIA. (LIR Appendix 2, paragraph 1.5)

3.3. LVIA METHODOLOGY

3.3.1. Local Impact Report Comment: ‘The LPA has several observations on the methodology employed in the Impact Assessment Methodology for the LVIA and, as a consequence the reliability of the findings. Including issues of landscape value and susceptibility, and some issues with the precise use of criteria and definitions for aspects of the visual impact assessment, which mean some caution when considering these aspects should be applied’. (paragraph 5.40) 3.3.2. B&A Response: The LIR comments made above are supported by the review by Enplan (LIR Appendix 2). We will address each issue raised. The relevant paragraph of Appendix 2 is identified. Higher Levels of Significant Effects 3.3.3. LIR Appendix 2 finds that the higher level significant effects are likely up to around 5km. (LIR Appendix 2, paragraph 2.1) 3.3.4. B&A Response: Based on the results of the LVIA, B&A agree that in visual terms, During Operation, the likely higher level significant effects will occur up to c.5km. However, we do not agree that this will apply to landscape character effects (both direct and indirect). B&A maintain that given the current context of the Site and the extensive mitigation measures incorporated into the Development, that it can be successfully accommodated into the current landscape setting. This will result in neutral rather than an adverse nature of effect in terms of landscape character in all Phases. Use of Zone of Theoretical Visibility (ZTV) 3.3.5. LIR Appendix 2 refers to the limitations of computer generated Zone of Theoretical Visibility (ZTV). (LIR Appendix 2, paragraph 2.2)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

3.3.6. B&A Response: It is important to note that ZTV is a recognised technique used by many landscape professionals. The GLVIA Third Edition recommends ZTV to be used rather than a Zone of Visual Influence (ZVI) as ZTV can be a valuable tool to indicate where ‘the proposal may theoretically be visible’. (GLVIA Third Edition, paragraph 6.8) Mitigation Measures During Operation (Proposed Native Woodland Planting) 3.3.7. LIR Appendix 2 addresses the photomontage views and the illustrative proposed native woodland planting as part of the assessment process. (LIR Appendix 2, paragraph 2.3) 3.3.8. B&A Response: As stated in the LVIA, the photomontage images show the planting in summer months after c.10 years. In order to carry out a robust assessment, the additional screening benefits provided by the planting is not taken into account During Operation. Therefore, screen bunds only are considered in this Phase (LVIA, paragraph 2.10.5) Aspects of the Methodology Employed by B&A 3.3.9. LIR Appendix 2 raises a number of different issues concerning the LVIA in bullet 1 to 11 of paragraph 2.4. Each is addressed in turn to provide clarification. 3.3.10. For thoroughness, B&A has reviewed the methodology adopted for the LVIA. Appendix 1 presents the full methodology with a summary in Section 1.

LVIA Best Practice Guidance 3.3.11. LIR Appendix 2 refers to relevant guidance for undertaking LVIAs. (LIR Appendix 2, paragraph 2.4, bullet 1) 3.3.12. B&A Response: The particular aspects which influenced the approach adopted by B&A is much broader than is suggested in LIR Appendix 2 (paragraph 2.4, bullet 1). 3.3.13. The methodology employed by B&A is tailored to meet the assessment required to assess the Development, namely the Buttington Quarry Energy Recovery Facility. 3.3.14. The main source of guidance for landscape professionals is the GLVIA Third Edition published in 2013. Each LVIA must give detailed consideration to the landscape and visual effects resulting from the Development in question. Landscape effects are defined as ‘effects on landscape as a resource’ and visual effects concern ‘effects on views and visual amenity’. (GLVIA Third Edition, paragraph 3.20).

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

3.3.15. The GLVIA Third Edition is not prescriptive and landscape professionals set out the assessment that best exemplifies and defines the proposals in question. This is emphasised in the preface to the GLVIA Third Edition which states ‘This edition concentrates on principles and process. It does not provide a detailed or formulaic 'recipe' that can be followed in every situation - it remains the responsibility of the professional to ensure that the approach and methodology adopted are appropriate to the task in hand…’. (GLVIA Third Edition, page x) 3.3.16. The GLVIA Third Edition acknowledges that ‘Even with qualified and experienced professionals there can be differences in the judgements made. This may result from using different approaches or different criteria, or from variation in judgements based on the same approach and criteria’. (GLVIA Third Edition, paragraph 2.25) Therefore, differences will occur between landscape professionals regarding the terminology used in reports. 3.3.17. The LVIA provides a fully evidenced methodology with clear definitions of impact terminology. The assessment being based on professional experience and a thorough knowledge of both the Site and the Development in a wider context gained over a length of time as the project evolved. 3.3.18. Also of importance is the Visual Representation of Development Proposals, Technical Guidance Note 06/19 issued by the Landscape Institute in 2019 and other publications by Natural England and NatureScot (previously known as Scottish Natural Heritage) which are detailed in the LVIA. 3.3.19. B&A paid particular attention to the comments made in the EIA Scoping Direction (October 2018) by DCW and during the pre-application consultation process. Also of importance to landscape and visual matters is LANDMAP including methodologies and guidance notes published by Natural Resources Wales , as well as Policy DM4 Landscape of the Adopted Powys Local Development Plan 2011 – 2026 (April 2018) and the Landscape SPG (Adopted April 2019) issued by PCC.

Sequence of Steps Used for the LVIA 3.3.20. LIR Appendix 2 refers to the steps used for the LVIA. (LIR Appendix 2, paragraph 2.4, bullet 2). 3.3.21. B&A Response: B&A does not agree that the steps employed in the LVIA are not transparent in the methodology. The starting premise being the three steps which echoes the approach from GLVIA Third Edition:

 ‘Determining the sensitivity of the landscape or viewer group (i.e. the receptor) to the type of change envisaged;  Predicting the magnitude of change that would take place in the landscape or view’; and  ‘Evaluating the significance of that change, taking into account the sensitivity of the affected receptor and the magnitude of change’. (LVIA, Appendix 1, paragraph 1.1.10)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

3.3.22. The GLVIA Third Edition recommends that when making judgements about the susceptibility of landscape or visual receptors to change, this should be recorded on a verbal scale with a clear explanation linked back to the baseline study carried out for LVIAs. (GLVIA Third Edition, paragraphs 5.43 and 6.35) 3.3.23. This is carried out by B&A through the inclusion of tables and a clear definition and explanation of the process involved. 3.3.24. The GLVIA Third Edition notes that tables and matrices should be used to support descriptive text rather than replacing it. (GLVIA Third Edition, paragraph 3.36) B&A concurred with this throughout the LVIA. In the methodology, a series of tables is included with an explanation of each stage, clearly defining receptor sensitivity (5-point scale, Very Low to Very High), magnitude of impact (8-point scale, No Impact to Very Large) and significance of effect (5-point scale, Negligible to Substantial). A summary table is provided for consistency which demonstrates the combination of the receptor sensitivity and magnitude of impact. (LVIA, Appendix 1)

Assessment of Landscape Effects (LANDMAP) 3.3.25. LIR Appendix 2 refers to the assessment of sensitivity for landscape character in particular with regards to LANDMAP. (LIR Appendix 2, paragraph 2.4, bullet 3) 3.3.26. B&A Response: The LVIA considered all five Aspect layers of LANDMAP and their relevant Methodologies. Guidance has been followed from the Adopted Powys Local Development Plan 2011 – 2026 (April 2018) and Landscape SPG (Adopted April 2019) as mentioned earlier. Due consideration is given to LANDMAP Visual and Sensory Aspect Areas but not at the expense of the other Aspect layers of LANDMAP. 3.3.27. Site analysis plays an important part in understanding landscape sensitivity. This is highlighted in many planning documents including Technical Advice Note 21 Waste (February 2014) and the Adopted Powys Local Development Plan 2011 – 2026 (April 2018). 3.3.28. The LVIA states that an appraisal of the five Site Aspect layers and the Visual and Sensory Aspect Areas in the principal study area are carried out. (LVIA, Appendix 1, paragraph 1.5.9) In the LVIA, Table 5: Site Related LANDMAP Aspect Areas, Site Analysis and Application to the Site/Development and Table 6: Summary of Indirect Effects on Visual and Sensory Aspect Areas Within the Principal Study Area provides an overview of the relevant Aspect Areas. This includes a review of the Aspect Areas within the study area adopted for the LVIA and gives an appraisal of the LANDMAP Evaluation and Overall Evaluation and the defined landscape sensitivity by B&A. 3.3.29. Box 5.1 of the GLVIA Third Edition is referenced in the LVIA to help the reader better understand what traits may apply to valued landscapes (LVIA, Appendix 1, paragraph 1.5.3). 3.3.30. LANDMAP is addressed in more detail later in this Section.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

Landscape Susceptibility 3.3.31. LIR Appendix 2 refers to landscape susceptibility in terms of a standalone assessment. (LIR Appendix 2, paragraph 2.4, bullet 4) 3.3.32. B&A Response: Paragraph 5.42 of the GLVIA Third Edition notes that ‘… Since landscape effects in LVIA are particular to both the specific landscape in question and the specific nature of the proposed development, the assessment of susceptibility must be tailored to the project…’ 3.3.33. In the LVIA, Table 1B: Landscape (Sensitivity) and supporting paragraphs 1.8.1 to 1.8.4 (LVIA, Appendix 1) clearly explain the assessment of landscape effects. Specific reference is made to what constitutes direct (landscape character of the Site) and indirect effects, namely, where the Development is visible in the principal study area (LVIA, Figures L5 and L6). 3.3.34. LIR Appendix 2 does not reference what is judged to constitute direct or indirect effects.

Magnitude of Landscape Effects 3.3.35. LIR Appendix 2 refers to the magnitude of landscape effects and the use of ZTV to assess effects (LIR Appendix 2, paragraph 2.4, bullet 5) 3.3.36. B&A Response: The ZTV is shown on LVIA Figures L1 and L3 (as a hatched area) for reference purposes. It assists in the evaluation of landscape effects but is not the only means used to assess direct and indirect effects on landscape character (LVIA, Appendix 1, paragraph 1.6.2). Section 5 of the LVIA presents the assessment of effects on landscape character and this is undertaken following Site analysis in line with LANDMAP guidance and methodologies.

Landscape Capacity 3.3.37. LIR Appendix 2 refers to the assessment of landscape capacity in the LVIA. (LIR Appendix 2, paragraph 2.4, bullet 6) 3.3.38. B&A Response: The LVIA assesses the landscape capacity of the MNTGMVS370 Crewgreen to Hill and Scarp Visual and Sensory Aspect Area during each phase of the Development. 3.3.39. This is based on a 3-point scale (LVIA, Appendix 1, paragraph 1.11.2) B&A maintains that the findings of the LVIA are correct. An explanation of sensitivity, value and a narrative of the changes are provided in detail in Section 5 of the LVIA (paragraphs 5.6.1 to 5.6.6). For reference, paragraph 5.6.6 concludes ‘There is sufficient capacity within the Aspect Area to enable the Development without significant or overriding adverse effects to both the character and value of the adjoining landscape. In the case of new native woodland planting, such effects are more likely to offer a beneficial contribution notably within close range in the Aspect Area’. Mid to Long Term Landscape and Visual Benefits 3.3.40. LIR Appendix 2 refers to the assessment of mid to long term landscape and visual benefits. (LIR Appendix 2, paragraph 2.4, bullet 7)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

3.3.41. B&A Response: No request was received for a mid to long term assessment during the Scoping process in 2018 and pre-application stage in 2020.

Assessment of Visual Effects 3.3.42. LIR Appendix 2 refers to the assessment of visual effects, specifically the sensitivity ratings applied in the LVIA. (LIR Appendix 2, paragraph 2.4, bullet 8) 3.3.43. B&A Response: In order to establish visual sensitivity, B&A considered guidance set out in the GLVIA Third Edition. 3.3.44. Paragraphs 6.33 and 6.34 which are cited in LIR Appendix 2 address visual receptors which are most likely and least likely to be susceptible to change. However, it is important to refer to the preceding and proceeding paragraphs which are reproduced below:

 ‘The susceptibility of different visual receptors to changes in views and visual amenity is mainly a function of: • the occupation or activity of people experiencing the view at particular locations; and • the extent to which their attention or interest may therefore be focused on the views and the visual amenity they experience at particular locations’. (GLVIA Third Edition, paragraph 6.32); and  ‘This division is not black and white and in reality there will be a gradation in susceptibility to change. Each project needs to consider the nature of the groups of people who will be affected and the extent to which their attention is likely to be focused on views and visual amenity. Judgements about the susceptibility of visual receptors to change should be recorded on a verbal scale (for example high, medium or low) but the basis for this must be clear, and linked back to evidence from the baseline study’. (GLVIA Third Edition, paragraph 6.35) 3.3.45. A residential amenity assessment was not required as part of the LVIA. Instead, it includes an assessment of views for residents from ground floor locations/gardens and from upper floor windows at specific Viewpoint Locations. B&A makes a differentiation between these groups with a High and Medium sensitivity being applied respectively. (LVIA, Appendix 1, Table 1D) 3.3.46. The GLVIA Third Edition notes that ‘…it will be important to recognise that residents may be particularly susceptible to changes in their visual amenity - residents at home, especially using rooms normally occupied in waking or daylight hours, are likely to experience views for longer than those briefly passing through an area’. (GLVIA Third Edition, paragraph 6.36) 3.3.47. There is some differentiation between the sensitivity levels applied in the LVIA and LIR Appendix 2. 3.3.48. LIR Appendix 2 does not explain the reasoning behind the changes and reference is also made to National Trails and the general public footpath network as well as other receptors being assigned a higher rating.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

3.3.49. Baseline studies undertaken as part of the LVIA along with professional judgement and the GLVIA Third Edition has guided the assignment of sensitivity ratings. B&A strongly rejects the view that receptor sensitivity has been ‘downgraded’ in the LVIA. By increasing sensitivity levels without fully explaining the reasoning can also result in the opposite effects, namely, that results can then be ‘inflated’: 3.3.50. For reference, Table 1 below shows differences between the LVIA and the LIR Appendix 2 sensitivity ratings. In summary, LIR Appendix 2 assigned a higher sensitivity rating for the following.  Offa’s Dyke Path National Trail users: Very High (LIR Appendix 2). B&A assigned a High receptor sensitivity;  Residential properties, from upper floor windows: High (LIR Appendix 2). B&A assigned a Medium receptor sensitivity which differentiates between views from ground floor locations/gardens. It is noted that LIR Appendix 2 assigns both as High;  Public footpaths/bridleways including the general footpath network: High (LIR Appendix 2). B&A assigned a Medium receptor sensitivity to the general footpath network;  Walkers (general recreation): High (LIR Appendix 2). B&A assigned a Medium receptor sensitivity for walkers using Middletown Hill and Green Hall Hill;  Severn Way long distance footpath users: Very High (LIR Appendix 2). B&A assigned a Medium receptor sensitivity in this instance given the nature of such routes;  Road users along ‘A’ and ‘B’ class roads (e.g. the A458, A483 and B4381): Medium (LIR Appendix 2). B&A assigned a Low receptor sensitivity given the type/character of these routes;  General road network including on Heldre Lane, Garreg Bank (upper and lower), Lane, Castlehill Lane: Medium (LIR Appendix 2). B&A assigned a Low receptor sensitivity to these minor roads given the type/character of these routes;  General road network Lane: High (LIR Appendix 2). B&A assigned a Low receptor sensitivity to this minor road given the type/character of the route; and  Recreation users at Welshpool Golf Club and Golf Club: High (LIR Appendix 2). B&A assigned a Low receptor sensitivity as this involves recreation activity action with less reference to external influences (e.g. views of the landscape).

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

Table 1: Visual Sensitivity – LVIA and Local Impact Report Comparison of Assigned Levels

LVIA LOCAL IMPACT VP NO. VISUAL SENSITIVITY EXPLANATION* CATEGORY REPORT**

‘Visitors to nationally advertised Visitors to Powis Very 24 attractions (e.g. a National Park) Very High Castle where visual amenity is very High important to its enjoyment’. Established viewing 18 point at Rodney's High High Pillar ‘From residential properties (ground floor locations/gardens), an Residential established viewing point, or 1, 4, 7, 10, properties, from recognised public location for which High High 14, 19 ground floor the sensitivity of visual amenity is locations/gardens noted as being of a higher rating. 20, 21, 22, Offa’s Dyke Path Footpath users on National Trails’. High Very High 32 National Trail users 8, 9, 11, Residential 12, 13, 23, properties, from Medium High 28 upper floor windows ‘Footpath users on long distance Public footpaths, on the general footpath 3, 5, 6, 7, footpaths/bridleways network (footpaths, bridleways and 16, 19, 25, including the byways) and walkers (general Medium High 27, 31 general footpath recreation). Residential locations network including from upper floor windows Walkers (general and general views from residential 17, 33 Medium High recreation) properties not associated with a High sensitivity’. Severn Way long 30 distance footpath Medium Very High users Road users along 8, 9, 15, ‘A’ and ‘B’ class 20, 21, 23, roads (e.g. the Medium 26, 28 A458, A483 and B4381)

General road network including on 1, 2, 4, 10, Heldre Lane, Garreg Low 11, 12, 13, Bank (upper and Medium 29 lower), Criggion ‘Road users on the general network Lane, Castlehill including ‘A’ class roads, minor roads Lane and lanes. It also includes a place of work or recreation facilities (e.g. golf course) as the action takes place with less reference to external influences’. General road 14 network Bacheldre High Lane Workers at employment areas 22 Low Low close to the A458 at Buttington Bridge Recreation users at Welshpool Golf Club 25, 31 Low High and Llanymynech Golf Club TABLE NOTES: * LVIA, Appendix 1, Table 1D: Visual (Sensitivity) ** Extracted from LIR Appendix 2, Table 2. NB. receptor sensitivity is stated as Medium for Viewpoint Locations 8 and 9.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

Assessment of Visual Effects 3.3.51. LIR Appendix 2 refers to the assessment of visual effects in terms of Table 1E: Visual (Magnitude of Impact) which is included in the LVIA. (LIR Appendix 2, paragraph 2.4, bullet 9) 3.3.52. B&A Response: The LVIA incorporates an eight-point scale when considering both landscape and visual effects. B&A maintains that both the upper and lower categories are well defined.

Significance of Effects 3.3.53. LIR Appendix 2 refers to Table 1F: Significance of Effect which is included in the LVIA. (LIR Appendix 2, paragraph 2.4, bullet 10) 3.3.54. B&A Response: It should be noted that the supporting paragraph 1.13.2 to Table 1F was specifically drafted for the LVIA where no results were Substantial and given that Moderate (adverse) impacts were reviewed to judge whether they would represent a significant effect.

Nature of Effect (Adverse, Beneficial and Neutral) 3.3.55. LIR Appendix 2 refers to the application of a neutral nature of effect. (LIR Appendix 2, paragraph 2.4, bullet 11) 3.3.56. B&A Response: Whilst LIR Appendix 2 allows that neutral or beneficial effects may occur due to the proposed native woodland planting it does not accept that neutral can be applied to the new built form of the Development. Instead, it is suggested that the effects should be adverse in principle. 3.3.57. Both LIR Appendix 2 and more fully, the LVIA refer to paragraph 5.37 of the GLVIA Third Edition which is provided for reference. 3.3.58. ‘It is also possible for effects to be neutral in their consequences for the landscape. An informed professional judgement should be made about this and the criteria used in reaching the judgement should be clearly stated. They might include, but should not be restricted to:  The degree to which the proposal fits with existing character; and  The contribution to the landscape that the development may make in its own right, usually by virtue of good design, even if it is in contrast to existing character’. (GLVIA Third Edition, paragraph 5.37) 3.3.59. The LVIA gave careful consideration to what constituted an adverse, beneficial or neutral effect. 3.3.60. In terms of built form, B&A maintain that when evaluating the Development that the following applies:

 ‘This Assessment recognises that if part of the Development can be assimilated into the landscape or is not visually overbearing and intrusive, it will not necessarily result in an adverse effect. In addition, a change is not necessarily an adverse effect so long as the land use and appearance are broadly in line with similar uses’. (LVIA, Appendix 1, paragraph 1.10.6); and

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

 ‘Neutral effects may arise when the proposals are unlikely to be identified immediately in terms of adversely affecting the characteristics or where they do not constitute an intrusive element in the overall visual amenity; this may apply when views are partially screened or at distance’. (LVIA, Appendix 1, paragraph 1.10.7)

3.4. LANDMAP AND EVALUATION OF LANDSCAPE SENSITIVITY

3.4.1. Local Impact Report Comment: ‘The LVIA provides a comprehensive record of the features and component parts of the landscape context of the study area and, to a large extent, relies on the findings of the various published landscape character assessments and LANDMAP for descriptions of characteristics, scenic quality, and perceptual characteristics of the landscape. In the LPA’s assessment the landscape value of the host Visual and Sensory Aspect Area (VSAA) is Moderate-High and its overall susceptibility to this form of development is High, due to its predominantly rural, intimate, unspoilt character and its attractive views both in and out. Its overall sensitivity is judged to be High, in contrast to the LVIA’s assessment of Medium’. (paragraph 5.41) 3.4.2. B&A Response: In order to establish the current baseline situation for the LVIA, B&A carried out a review of existing Landscape Character Assessments which are available at a national and local level and are a key tool to understand the landscape in rural areas in accordance with the GLVIA Third Edition (paragraph 5.4). 3.4.3. The Landscape Character Assessments are outlined in Section 3: The Baseline Situation, illustrated by Figure L1: Site Location and Landscape Character Classification (National Level) and Figure L3: LANDMAP Visual and Sensory Aspect Areas (within 10km) and supported by Appendices 4 to 10 in the LVIA. 3.4.4. The preliminary study area adopted for the LVIA extended to c.20km from the Site boundary. Primarily, assessable effects were found to be up to c.15km with key effects within 10km. (LVIA, paragraph 2.2.2) Relevant reference sources are published by Natural England and National Resources Wales. The most recent county level Landscape Character Assessment is the Powys Landscape Character Assessment Study (2008).5 3.4.5. As stated in the LVIA, B&A reviewed each resource and the information provided in line with the GLVIA Third Edition in relation to their relevance to current characteristics, date of publication and needs of the specific assessment of Buttington ERF. (LVIA, Appendix 1, paragraph 1.5.4) This is supported by field work analysis acquired during the LVIA process. 3.4.6. B&A took particular care in their approach to using LANDMAP which offers the most detailed and up-to-date information relevant for landscape character and is provided by Natural Resources Wales.

5 Powys Landscape Character Assessment Study, John Campion Associates Ltd. (Commissioned by Powys County Council), 2008

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

3.4.7. The LANDMAP Methodology Overview (2017) draws attention to the following aspects ‘Evidence is consistent, transparent and Quality Assured’ (bullet 3) and ‘Provides a comprehensive baseline of environmental, cultural and heritage information to assist with sustainable decision making at a range of levels from local to national scale whilst ensuring transparency in decision-making’ (bullet 6) (LANDMAP Methodology Overview, page 5).6 3.4.8. The importance of LANDMAP as a resource is cited in Planning Policy Wales (Edition 10) (2018)7 which was current at the time the LVIA was carried out and Technical Advice Note 12 Design (March 2016).8 As stated previously, direction for the LVIA methodology has been taken from the methodologies and guidance notes relevant to LANDMAP and the LVIA considers all five Aspect layers which complies with the Adopted Powys Local Development Plan 2011 – 2026 (April 2018) including Policy DM4 Landscape and the Landscape SPG (Adopted April 2019). 3.4.9. LANDMAP classifies regional scale Area Statements which were issued in 2018 and the following five Aspect layers at a more detailed scale:  Geological Landscape (Survey Dates 2005);  Visual and Sensory (Survey Dates 2004 and monitoring 2015);  Landscape Habitats (Survey Dates 2005 and monitoring 2016);  Historic Landscape (Survey Dates 2006 and monitoring 2017); and  Cultural Landscape Services (Survey Dates 2019). 3.4.10. The table below summarises where LANDMAP resources have been used in the LVIA in respect to the Site and the principal study area. The latter is defined in the LVIA ‘… as the distance from the Development within which the landscape or visual effects might be deemed as being of potential significance and thus, relevant to the assessment process’. (LVIA, Appendix 1, paragraph 1.2.1)

6 LANDMAP Methodology Overview, Natural Resources Wales, June 2017 7 Planning Policy Wales (Edition 10), The Welsh Government, 2018 8 Technical Advice Note 12 Design, The Welsh Government, March 2016

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

Table 2: LANDMAP Aspect Area Layers and Approach of the LVIA LVIA LANDMAP SITE/PRINCIPAL STUDY SECTION 3 THE BASELINE SECTION 5 EFFECTS ON LANDSCAPE SECTION 7 PLANNING ASSESSMENT APPENDICES FIGURES AREA SITUATION CHARACTER AND DESIGNATIONS

Mid-Wales Area Direct Effects On Landscape Character, paragraph N/A LANDMAP, paragraph 3.4.2 N/A Appendix 6 (extract) N/A Statement 5.3.2 (2018) Direct Effects On Landscape Character, Table 5: Site The Site: MNTGMGL697 The Site Aspect Areas, Table 3: Appendix 7: LANDMAP Site Related LANDMAP Aspect Areas, Site Analysis and N/A N/A Hope Other Site Related Aspect Layers Related Aspect Areas (Extract) Application to the Site/Development Geological Appendix 8: LANDMAP Aspect Landscape Principal Study Area Aspect Areas within the Principal Study Principal Study Area Areas, paragraphs 3.4.17 and N/A N/A Area – Summary Details N/A 3.4.18 (Tables 8A to 8E prepared by B&A) The Site Aspect Areas, Direct Effects On Landscape Character, paragraphs Paragraphs 7.3.3 and 7.3.9 in relation to Strategic Policy The Site: MNTGMVS370 paragraphs 3.4.5 to 3.4.8. Table 5.3.1 to 5.3.7 and Table 5: Site Related LANDMAP SP7 Safeguarding of Strategic Resources and Policy DM4 Appendix 7: LANDMAP Site Crewgreen to Forden Hill and 2: MNTGMVS370 Crewgreen to Aspect Areas, Site Analysis and Application to the Landscape of the Adopted Powys Local Development Plan Related Aspect Areas (Extract) Scarp Forden Hill and Scarp Aspect Site/Development. Landscape Capacity, paragraphs 2011 – 2026 (April 2018). Paragraph 7.4.8 concerning Figure L3: Visual and Area 5.6.1 to 5.6.6. Landscape SPG (Adopted April 2019). LANDMAP Visual Sensory Indirect Effects on Other Visual and Sensory Aspect Appendix 8: LANDMAP Aspect and Sensory Aspect Areas Within the Principal Study Area – paragraphs Areas within the Principal Study Areas (within 10km) Principal Study Area Aspect Principal Study Area 5.4.5 to 5.4.7 and Table 6: Summary of Indirect Effects N/A Area – Summary Details Areas, paragraph 3.4.12. on Visual and Sensory Aspect Areas Within the (Tables 8A to 8E prepared by Principal Study Area B&A) Paragraphs 7.3.3 and 7.3.9 in relation to Strategic Policy Direct Effects On Landscape Character, Table 5: Site SP7 Safeguarding of Strategic Resources and Assets and The Site Aspect Areas, Table 3: Appendix 7: LANDMAP Site The Site: MNTGMLH033 Related LANDMAP Aspect Areas, Site Analysis and Policy DM4 Landscape of the Adopted Powys Local N/A Other Site Related Aspect Layers Related Aspect Areas (Extract) Application to the Site/Development Development Plan 2011 – 2026 (April 2018). Paragraph Landscape 7.4.8 concerning Landscape SPG (Adopted April 2019). Habitats Appendix 8: LANDMAP Aspect Principal Study Area Aspect Areas within the Principal Study Principal Study Area Areas, paragraphs 3.4.16 to N/A N/A Area – Summary Details N/A 3.4.18 (Tables 8A to 8E prepared by B&A) Direct Effects On Landscape Character, Table 5: Site The Site: MNTGMHL310 The Site Aspect Areas, Table 3: Appendix 7: LANDMAP Site Related LANDMAP Aspect Areas, Site Analysis and N/A N/A Buttington/Middletown Other Site Related Aspect Layers Related Aspect Areas (Extract) Application to the Site/Development Historic Appendix 8: LANDMAP Aspect Landscape Principal Study Area Aspect Areas within the Principal Study Principal Study Area Areas, paragraphs 3.4.13 to N/A N/A Area – Summary Details N/A 3.4.15 (Tables 8A to 8E prepared by B&A) The Site: MNTGMCLS044 Direct Effects On Landscape Character, Table 5: Site The Site Aspect Areas, Table 3: Paragraph 7.4.8 in reference to Landscape SPG (Adopted Appendix 7: LANDMAP Site Crewgreen to Forden Hill and Related LANDMAP Aspect Areas, Site Analysis and N/A Other Site Related Aspect Layers April 2019). Related Aspect Areas (Extract) Scarp. Application to the Site/Development Cultural Landscape Appendix 8: LANDMAP Aspect Areas within the Principal Study Services Principal Study Area Aspect Principal Study Area N/A N/A Area – Summary Details N/A Areas, paragraph 3.4.19 (Tables 8A to 8E prepared by B&A)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.4.11. The LANDMAP Visual & Sensory Aspect layer is of importance as it informs landscape character. However, it is not the only consideration, otherwise a judgement about landscape value is then weighted towards this Aspect layer which goes against professional judgement and guidance. 3.4.12. LIR Appendix 2 provides an evaluation of the local landscape character but makes reference only to the Visual and Sensory Aspect Areas up to c.5km (paragraph 3.1 to 3.5). It does not consider other Aspect Area layers either in terms of the Site or wider surroundings as undertaken in the LVIA. The approach adopted in LIR Appendix 2 does not comply with the advice provided in the Adopted Powys Local Development Plan 2011 – 2026 (April 2018) and Landscape SPG (Adopted April 2019). Both refer to the importance of considering all five Aspect Area Layers when considering the characteristics and qualities of the landscape. 3.4.13. In order to define the landscape value of each Visual & Sensory Aspect Area (VSAA), LIR Appendix 2 cites LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017. This document presents the approach for using LANDMAP to identify local landscape designations and Special Landscape Areas (SLAs) (LANDMAP Guidance Note 1, paragraph 2). SLAs often cover an expansive area rather than a single Aspect Area and LANDMAP Guidance Note 1 outlines a detailed, four stage process. Table 2: LANDMAP Evaluation Criteria of the same document identifies the evaluation criteria for each LANDMAP layer and states ‘All five LANDMAP layers are important in the identification of SLAs, the criteria highlighted in bold in Table 2 may be particularly informative in identifying SLAs’. 3.4.14. LIR Appendix 2 refers to the ‘Main Drivers’ in a footnote but this is not the phrase used in LANDMAP Guidance Note 1 at any point. A previous report by Enplan on behalf of Powys County Council has adopted an approach using ‘Main Drivers’.9 This was a detailed report to assess areas suitable for solar farms and paragraph 4.10 refers to the Main Drivers’ when defining landscape value. 3.4.15. ‘Of these twelve NRW have informally indicated through preliminary discussions in preparing this methodology that four of these are the “main drivers” in determining landscape value, these being Visual & Sensory Scenic Quality, Visual & Sensory Character, Historic Landscape Integrity and Historic Landscape Rarity. Furthermore, because of its particular relevance to landscape value and sensitivity some additional weighting has been applied to those landscapes which demonstrate a High or Outstanding Visual & Sensory Scenic Quality’. (Powys Renewable Energy Assessment, 2017, paragraph 4.10) 3.4.16. However, the approach adopted when establishing landscape value is to select only the Visual & Sensory ‘particularly informative’ criteria and then focus on the perceptual and other sensory qualities of the MNTGMVS370 Crewgreen to Forden Hill and Scarp VSAA and Scenic quality (High). This approach is then adopted for the other VSAAs as well.

9 Powys Renewable Energy Assessment: Landscape Sensitivity Study For Solar Farm Development, Prepared for Powys County Council by Enplan, May 2017

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.4.17. For reference, perceptual and other sensory qualities are ‘Attractive, Unattractive (Criggion Quarry workings), Safe, Settled’. The individual categories are Integrity (Moderate), Character (Moderate) and Rarity (Low) applies with the Justification of overall evaluation (Moderate) described as a ‘Typical example of farming practices and fields patterns displaying hedgerow boundaries and woodland blocks in lower lying areas that could benefit from enhancement through additional planting along boundaries’. 3.4.18. The landscape value is then combined with an assessment of landscape susceptibility in LIR Appendix 2 to set the landscape character baseline. (LIR Appendix 2, Table 1: Landscape Character Baseline) 3.4.19. B&A have the following concerns about LIR Appendix 2 and their methodology used to define landscape sensitivity:  Applying a methodology from LANDMAP Guidance Note 1 to assess landscape value which is not meant for such a purpose (given scale and reference to the other Aspect Area layers);  By identifying ‘Main Drivers’, i.e. the ‘particularly informative’ criteria this has the potential to skew the landscape value and sensitivity levels of all the VSAAs assessed and then influences the results going forward;  It mixes landscape character and visual sensitivity and this is unhelpful and indeed confusing. It also wholly undermines the conclusions later made in LIR Appendix 2; and  Using ‘particularly informative’ categories of the MNTGMVS370 Crewgreen to Forden Hill and Scarp VSAA, LIR Appendix 2 selectively focuses on Scenic quality (High) which is then given as the reason to increase the evaluation towards the upper end of a Moderate category. LANDMAP assesses it as Moderate. Following Site analysis work in the LVIA, B&A categorised the Aspect Area as a Low-Medium sensitivity within the Site and a Medium sensitivity outwith. Whereas, LIR Appendix 2 assessed the Site as Very Low and a High sensitivity outwith. 3.4.20. In the LVIA, B&A adopted an approach based on current LANDMAP and planning guidance as previously set out. 3.4.21. The Crewgreen to Forden Hill and Scarp VSAA (MNTGMVS370) is directly relevant to the Site. In the LVIA, Table 2: MNTGMVS370 Crewgreen to Forden Hill and Scarp Aspect Area sets out relevant data in a table format. LANDMAP categorises Scenic Quality as High and Character as Moderate. Although the overall evaluation is Medium, the assessment in the LVIA was erring on the side of caution by referencing the Scenic quality and attractive views. 3.4.22. B&A is careful to present the information available from LANDMAP both with direct reference to the Site and study area (where it applies) in adherence with LANDMAP methodologies. Section 5 of the LVIA sets out the LANDMAP information and B&A Site Analysis in Table 5 noting the extent of the Crewgreen to Forden Hill and Scarp VSAA and matters relevant to the Site.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.4.23. The Crewgreen to Forden Hill and Scarp VSAA is particularly extensive to the north-east, east and south-west. In terms of the principal study area adopted for the LVIA, it extends to the north-east (c.6km), east (c.2.7km) and south-west (c.10km). 3.4.24. Reference to Figure L3: LANDMAP Visual and Sensory Aspect Areas (within 10km) in the LVIA demonstrates the extent of the Crewgreen to Forden Hill and Scarp VSAA (MNTGMVS370) and also the hatched areas showing the ZTV of the stack and roof level of the turbine building. 3.4.25. The LVIA defines the landscape sensitivity of the Crewgreen to Forden Hill and Scarp VSAA as Low-Medium within the Site and Medium outwith following Site Analysis as noted. It is content that this is a fully evaluated and evidenced conclusion and for which B&A stands by this assessment.

3.5. SELECTED CLADDING COLOURS

3.5.1. Local Impact Report Comment: ‘In principle, the LPA supports the approach to the design of the building’s cladding (i.e. Option 2 as defined in the DAS) and agrees that the building would, in most instances, be seen against a landscape backdrop, as opposed to the skyline, in respect of the area of views rather than the number of viewers that would experience these views. The current selection shown on the photomontages work relatively well in summer conditions but less so in winter, the LPA would suggest consideration should be given to a range that may work best throughout the year rather than those suitable for high summer. To this end a selection of ‘murkier’ greens and shades of brown may be a better compromise than the brighter lighter greens used for the images. It is recommended that this be covered by an appropriate planning condition should the decision-maker be minded to grant consent’. (paragraph 5.42) 3.5.2. B&A Response: In order to assess winter views, the LVIA presented a series of photomontage winter views (Sheets 1 to 16) (see Appendix 12). Eight winter views were considered in detail to assess the construction, operation and decommissioning phases. Aspects assessed included colour cladding and whether a reduction in vegetation in the wider vicinity increased views of the Development (Section 6.14). 3.5.3. The LVIA concluded ‘… the visual impact assessment found that in summer months, the selection of natural cladding colours will assist in assimilating the proposed built form into a mainly rural visual setting. This also applies to the winter views assessed. The cladding colour scheme merges with the wider landscape setting and forms part of the scene rather than being a focus’. (LVIA, paragraph 6.14.34) 3.5.4. Thus, none of the assessment conclusions are undermined. However, should a grant of consent be made, a further review of the exact cladding colours will be reasonable. 3.5.5. The design process outlined in the Design & Access Statement (February 2021) considered winter views.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.6. LANDSCAPE MITIGATION PROPOSALS

3.6.1. Local Impact Report Comment: ‘The landscape mitigation proposals for screen bunding and large-scale mass planting of native woodland on the bunds, as identified on the Landscape Masterplan, is considered appropriate and the LPA supports the approach’. (paragraph 5.43) 3.6.2. B&A Response: It is noted elsewhere in the Local Impact Report (Ecology and Biodiversity) that the impact of development is judged to be Positive. (paragraph 5.72) 3.6.3. With regards to the landscape mitigation proposals from a landscape and visual perspective. Further to the habitats identified in paragraph 5.43 of the Local Impact Report, Sustainable Drainage System (SuDS) measures, areas of open mosaic habitat and species-rich neutral grassland are included in the Landscape Masterplan. (LVIA, Appendix 2, Drawing BT1180-D2) 3.6.4. It is worth noting that the arrangement of built form (i.e. within a quarry void) and the size of the Site in comparison to that allocated for proposed built form allows the landscape mitigation proposals which are an integral part of the design to be accommodated. It should be noted that the eastern sector of the screen bund adjacent to Sale Lane is approved and partly constructed.

3.7. APPLICATION SITE - ASSESSMENT OF IMPACT/EFFECT

3.7.1. Local Impact Report Comment: ‘For the assessment of the magnitude of landscape effects, for the application site, the LPA considers this to be Large, during operation, and, consequently when combined with its Very Low sensitivity, of only Minor-Moderate adverse significance, well below the level regarded as being a key material factor in the decision-making process’. (paragraph 5.44) 3.7.2. B&A Response: Please refer to Section 3.4 Landmap and Evaluation of Landscape Sensitivity regarding the methodology used to define landscape sensitivity in LIR Appendix 2. 3.7.3. As stated previously, the LVIA and LIR Appendix 2 have notable differences in terms of defining landscape sensitivity, magnitude of impact and significance of effect. The results of each have been reviewed as part out our response. This concerns effects During Operation. LIR Appendix 2 does not address other Phases.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Direct Effects Crewgreen to Forden Hill and Scarp VSAA (MNTGMVS370) – Site Level

LVIA During Operation 3.7.4. In the LVIA, B&A assigned a Low-Medium sensitivity to the Site due to mineral related activities which have resulted in a much changed landscape with typical features such as tracks, exposed mineral and a partially complete screen bund within the Site. This reflects the important local variations within the Site. Whilst it features few distinctive attributes of the Crewgreen to Forden Hill and Scarp VSAA, notably the broad band of mature woodland on the southern Site boundary. (LVIA, paragraph 5.3.4) 3.7.5. A Low-Medium sensitivity would fall between two categories. This recognises both the current Site situation and its potential to accommodate certain types of development. B&A maintains that this is an appropriate landscape sensitivity rating for the Site. (LVIA, Appendix 1, Table 1B: Landscape (Sensitivity)

 Medium ‘Where the key characteristics, elements and associated uses of the landscape are susceptible to change but have the ability to absorb development in some situations. Thresholds for significant change are intermediate’. and  Low ‘Where key characteristics, elements and associated uses are resilient to change and can absorb development in many situations without significant character change’. 3.7.6. During Operation, the LVIA recorded a Medium magnitude of impact and subsequent Moderate (neutral) significance of effect with regards to direct effects at a Site level. The narrative provided of the changes acknowledged that the Development would introduce new elements namely, the proposed ERF building and stack. Mitigation measures including the siting of built form within the quarry void and selection of cladding colours would be suitable for the landscape setting. (LVIA, paragraph 5.3.5) 3.7.7. For reference:

 A Medium magnitude of impact occurs ‘Where the development will cause changes to several landscape characteristics’ (LVIA, Appendix 1, Table 1C); and  A Moderate significance of effect applies to ‘Larger scale changes affecting the landscape to a noticeable degree without a significant resultant change in the character’. (LVIA, Appendix 1, Table 1F). 3.7.8. B&A considered whether an adverse or neutral nature of effect would be appropriate. Relevant in this case would be the assimilation of the Development into the landscape and that it is unlikely to adversely affect landscape characteristics. Both directed to a neutral nature of effect. (LVIA, Appendix 1, paragraphs 1.10.6 and 1.10.7) 3.7.9. B&A has reviewed the above as part of this response and maintains that the same results apply with regards to direct effects on landscape character at a Site level.

LIR Appendix 2 During Operation

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.7.10. LIR Appendix 2 assigned a Very Low landscape sensitivity to the Crewgreen to Forden Hill and Scarp VSAA at a Site level and states ‘The application site itself, in isolation of its surroundings, is essentially a working quarry. Its susceptibility to change from the form of development envisaged is low. Its characteristics, other than being one of a number of local quarries, are not special or positively characteristic of the host VSAA and wider landscape context…’ (LIR Appendix 2 paragraph 3.3) 3.7.11. With regards to landscape value, ‘In Enplan’s assessment the landscape value of the host VSAA is Moderate-High and its overall susceptibility to this form of development is High, due to its predominantly rural, intimate, unspoilt character and its attractive views both in and out. Its overall sensitivity is judged to be High …’ (LIR Appendix 2 paragraph 3.4) 3.7.12. It concludes that ‘For the assessment of the magnitude of landscape effects, for the application site, Enplan considers this to be Large, during operation, and, consequently when combined with its Very Low sensitivity, of only Minor-Moderate adverse significance, well below the level regarded as being a key material factor in the decision-making process’. (LIR Appendix 2 paragraph 5.1)

B&A Conclusions 3.7.13. B&A maintain that the assessment of landscape value and sensitivity used by LIR Appendix 2 misinterprets the landscape character of the Site, particularly by focusing on scenic value of the Crewgreen to Forden Hill and Scarp VSAA. This effectively downgrades the effects on the Site due to the Development.

3.8. APPLICATION SITE - VISUAL AND SENSORY ASPECT AREA

3.8.1. Local Impact Report Comment: ‘For the host VSAA, its predominantly rural character would be significantly changed with the introduction of a prominent, large-scale industrial building with a tall stack and occasional plume, and the sparsely developed, more intimate and relatively unspoilt characteristics would be significantly diminished. The present quarry is not widely visible from within the VSAA and where it is noticeable it is only partially visible, largely screened behind the current screen bunds and partially wooded surrounds. The development would appear to emerge from the quarried landform, be seen against the skyline in some views and dominant, and it would become a new key characteristic of the VSAA. Attractive views from the VSAA to adjoining landscapes, especially those from the high ground across the floodplain to the hills beyond to the west, would be changed adversely. The design and coloured cladding would mitigate some of these effects, as would the bunding to some degree and the native woodland planting would, in time, be a slight benefit to the local character, but together these would not offset the significant harm to the landscape character of the VSAA. During operation, the magnitude of effect on landscape character of the host VSAA is considered to be Large adverse overall, and the significance of this effect would be Major adverse. For areas in close proximity to the development, a greater magnitude of change would be anticipated and, correspondingly, this would fall away slightly with distance. The LVIA considers the magnitude of effect to be Medium (neutral) and Moderate (neutral) significance at close range, and Small or potentially

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Very Small and a Minor (neutral) significance, at medium range’. (paragraph 5.45) 3.8.2. B&A Response: Please refer to Section 3.13: Local Impact Report Conclusions - Higher-Level Significant Landscape and Visual Effects.

3.9. LOCAL VISUAL AND SENSORY ASPECT AREAS

3.9.1. Local Impact Report Comment: ‘The LPA’s assessment of the magnitude of change and the significance of these for the other local VSAAs are set out in Table 2 below and there is marked difference between these findings and those of the LVIA’. (paragraph 5.46) 3.9.2. B&A Response: Please refer to Section 3.13: Local Impact Report Conclusions - Higher-Level Significant Landscape and Visual Effects.

3.10. VISUAL EFFECTS

3.10.1. Local Impact Report Comment: ‘Overall, there is marked difference in the LPA’s assessment and that of the LVIA as reflected in Table 2 below’. (paragraph 5.47) 3.10.2. B&A Response: Please refer to Section 3.13: Local Impact Report Conclusions - Higher-Level Significant Landscape and Visual Effects.

3.11. ASSESSMENT OF CONSTRUCTION AND DECOMMISSIONING PHASES IN THE LVIA

3.11.1. Local Impact Report Comment: ‘In accordance with the EIA Regulations the LVIA appropriately considers the landscape and visual effects of construction and decommissioning. The LPA has reviewed these assessments and agrees with the broad principles of the assessment approach applied. The LPA notes that generally the LVIA considers the magnitude of the construction effects to be slightly greater than the operational effects and the decommissioning effects to be broadly similar to the operational effects. The LPA concurs with this approach as a worst case, noting that these are both essentially transient operations that within each period actual effects may be less or may be greater’. (paragraph 5.48) 3.11.2. B&A Response: We note that the Local Impact Report agrees with the broad approach adopted in the LVIA, namely that the magnitude of impact will be higher During Construction than During Operation. The Local Impact Report and Appendix 2 both concentrate on effects During Operation.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.12. ASSESSMENT OF CUMULATIVE EFFECTS

3.12.1. Local Impact Report Comment: ‘For the assessment of cumulative effects, the LPA notes the other developments that are considered to form part of the cumulative assessment but notes that these are all existing developments and, therefore, part of the existing baseline context. Cumulative effects are normally associated with assessing the proposed development alongside other similar development that is under construction but not yet complete, has planning consent but not yet under construction and, in some cases, development that is in the planning process but not yet consented, such as land allocated in a Local Plan. There is suggestion that this application is an “anchor facility and will open up the development of the wider business park” (laydown area 1-4). Accordingly, the LPA does not consider this to be an adequate cumulative landscape and visual impact assessment, at least not without further information to demonstrate that no other similar development is ‘coming forward’ that should be assessed in this LVIA and as part of this EIA’. (paragraph 5.49) 3.12.2. B&A Response: No developments (in excess of 1 hectare that have been subject to EIA) in accordance with the methodology set out in the Request for Scoping Direction (August 2018) or relevant planning applications in accordance with the EIA Scoping Direction (October 2018) were identified during the preparation of the LVIA. 3.12.3. Consideration was given to large scale industrial buildings located on the main road network and on the edge of settlements. (LVIA, paragraph 8.4.24) The assessment of cumulative effects was carried out in accordance with the GLVIA Third Edition (GLVIA Third Edition, paragraphs 7.26 and 7.38). The LVIA concluded that Development will not result in adverse cumulative landscape and visual effects. 3.12.4. No comments were received by B&A following the Review of the LVIA by Enplan (October 2020) and Pre-Application Process (September 2020) in relation to cumulative effects. This includes the potential future use of the Site as ‘anchor facility’ in future following decommissioning as noted in the Local Impact Report, albeit not in LIR Appendix 2. The assessment concerned the Development rather than future uses of the Site. 3.12.5. In order to understand the approach to cumulative effects adopted for the Development in the ES. Chapter 16 Cumulative Impacts and Mitigation Summary provides a comprehensive account of the other developments which were reviewed. This involved a four Stage process and the following is of note:  A review was undertaken of relevant applications to PINS (Chapter 16, paragraph 16.4.3) and PCC (Chapter 16, Table 16- 2: ‘Other Development’ Evaluated in Terms of Cumulative Effect); and  ‘No residual cumulative effect anticipated’ for the majority of topics assessed in the ES including landscape and visual effects. (Chapter 16, Table 16-3: ‘Other Development’ Cumulative Effects Assessment)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.12.6. No reference is made in the Local Impact Report to the approach adopted in Chapter 16 being unsuitable regarding landscape and visual matters or other topics covered in the ES.

3.13. LOCAL IMPACT REPORT CONCLUSIONS - HIGHER-LEVEL SIGNIFICANT LANDSCAPE AND VISUAL EFFECTS

3.13.1. Local Impact Report Comment: ‘The LPA concludes that there would be the following higher-level significant landscape and visual effects, in summary, arising from the development proposals, up to around 5km from the development and that these are considered to be key material factors for the decision-maker:  A Major adverse significance of landscape effect on the host landscape receptor, the Crewgreen to Forden Hill and Scarp VSAA, which is a Moderate to High value landscape;  A Moderate-Major adverse significance of landscape effect on three neighbouring landscape receptors, Long Mountain VSAA, Breidden Hill VSAA and the Flood Plain VSAA, of which Long Mountain is a High value landscape of regional/county importance and Breidden Hill VSAA is a Moderate to High value landscape;  A Major to Substantial adverse significance of visual effect on residents and walkers on Heldre Lane west of Whitehouse Farm and Major adverse significance to users of vehicles (Viewpoint 1);  A Major adverse significance of visual effect on walkers and users of Offa’s Dyke Path National Trail at the A458 at Buttington Bridge at a distance of 2.4km from the development (Viewpoint 22);  A Major adverse significance of visual effect on residents and walkers on other sections of Heldre Lane, including at Upper Heldre (Viewpoints 2 and 4) and Major to Moderate adverse significance to users of vehicles;  A Major adverse significance of visual effect on walkers the public footpath immediately south of Nelly Andrews' Green (Viewpoint 3);  A Moderate to Major adverse significance of visual effect on residents and pedestrians/walkers at Trewern and nearby (Viewpoints 10 to 13); and  A Moderate to Major adverse significance of visual effect on walkers in the Breidden Hills at the summits of Moel y Golfa, Middletown Hill and Rodney's Pillar up to 5km distant from the development (Viewpoints 16 to 18)’. (paragraph 5.50) 3.13.2. B&A Response: B&A has reviewed the results of the LVIA in terms of the higher-level significant landscape and visual effects identified in the Local Impact Report. Landscape Character Effects 3.13.3. It should be noted that this response reviews effects During Operation only which has been assessed in LIR Appendix 2.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters MNTGMVS370 Crewgreen to Forden Hill and Scarp Visual & Sensory Aspect Area (Indirect Effects)

LVIA During Operation 3.13.4. The Crewgreen to Forden Hill and Scarp VSAA is classified as Moderate (local importance) by LANDMAP. Monitoring of the Aspect Area draws attention to the ‘Transitional landform between Breidden Hill, Long Mountain and the River Severn’. (LVIA, paragraph 5.4.1) 3.13.5. B&A applied a Medium sensitivity to the Aspect Area. This concerns ‘Where the key characteristics, elements and associated uses of the landscape are susceptible to change but have the ability to absorb development in some situations. Thresholds for significant change are intermediate’ (LVIA, Appendix 1, Table 1B) 3.13.6. The Aspect Area expands to the north-east (c.6km), east (c.2.7km) and south-west (c.10km) of the Site. Viewpoint Locations 1 to 4, 7, 9 to 14, 34 and 35 which are assessed in the LVIA fall within this Visual and Sensory Aspect Area. The ZTV extends to the east and south of the Site within close range and to the north-east to medium range and is absent apart from a limited area to the long range (LVIA, paragraph 5.4.3 and Figure L3). 3.13.7. The LVIA concluded that indirect effects will be limited overall due to the current context of the Site, the nature of the Development and incorporated mitigation measures. During Operation, at a close range, a Medium magnitude of impact and a Moderate (neutral) significance of effect was noted. At a medium range, this will reduce to a Small or potentially, Very Small magnitude of impact and a Minor (neutral) significance of effect. 3.13.8. At a maximum level, a Medium magnitude of impact equates to ‘Where the development will cause changes to several landscape characteristics’. (LVIA, Appendix 1, Table 1C) A Moderate significance of effect applies when ‘Larger scale changes affecting the landscape to a noticeable degree without a significant resultant change in the character’ and would be of a neutral nature of effect. (LVIA, Appendix 1, Table 1F)

LIR Appendix 2 During Operation 3.13.9. LIR Appendix 2 assesses the landscape value of the Crewgreen to Forden Hill and Scarp VSAA as Moderate-High. It states that ‘its overall susceptibility to this form of development is High, due to its predominantly rural, intimate, unspoilt character and its attractive views both in and out. Its overall sensitivity is judged to be High…’ (LIR Appendix 2, paragraph 3.4) 3.13.10. During Operation, the LIR Appendix 2 determines a Large magnitude of impact overall and a Major (adverse) significance of effect. This equates to Large ‘Where the development will cause some large-scale changes to several landscape characteristics’. (LVIA, Appendix 1, Table 1C) and Major ‘Landscape character and quality is affected to a large degree, such that the development is a substantive element, creating a character associated with the development’ (LVIA, Appendix 1, Table 1F). Effects would be of an adverse nature. Such effects would decline at a further distance from the Site.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.11. LIR Appendix 2 provides a description of indirect effects (LIR Appendix 2, paragraph 5.2) The main points are addressed below by B&A:

 ‘For the host VSAA, its predominantly rural character would be significantly changed with the introduction of a prominent, large- scale industrial building with a tall stack and occasional plume, and the sparsely developed, more intimate and relatively unspoilt characteristics would be significantly diminished’: B&A Comment: B&A agree that the VSAA is mainly rural in character in places but the description suggests a more remote area. The LANDMAP survey very much describes a working agricultural landscape with hedgerow boundaries and larger tracts of woodland in places. Quarrying is referenced at Criggion Quarry. This is reflected throughout the survey in terms of physical form and elements recorded. The VSAA is also described as Safe and Settled (i.e. ‘Is the area well settled and domestic in character?’). The survey of the VSAA does not use any of the words such as Tranquil, Remote or Wild to describe the VSAA. B&A does not agree that the existing character of the VSAA will be notably changed by the Development;  ‘The present quarry is not widely visible from within the VSAA and where it is noticeable it is only partially visible, largely screened behind the current screen bunds and partially wooded surrounds. The development would appear to emerge from the quarried landform, be seen against the skyline in some views and dominant, and it would become a new key characteristic of the VSAA’: B&A Comment: The Site is visible from areas of the VSAA as demonstrated by the photographs prepared in the LVIA. B&A do not agree that it will be a dominant feature at the skyline nor would it become a new key characteristic of the VSAA; and  ‘Attractive views from the VSAA to adjoining landscapes, especially those from the high ground across the floodplain to the hills beyond to the west, would be changed adversely. The design and coloured cladding would mitigate some of these effects, as would the bunding to some degree and the native woodland planting would, in time, be a slight benefit to the local character, but together these would not offset the significant harm to the landscape character of the VSAA’: B&A Comment: It is accepted that there are attractive views from the Crewgreen to Forden Hill and Scarp VSAA. However, the VSAA is quite sinuous in shape which is an important factor and is not always evident. In some instances, it does not play a key role for elevated views e.g. from the Breidden Hill VSAA where there are clearer views of the River Severn Flood Plain VSAA. The high quality of the design and mitigation measures will not have this predicted adverse effect. Mitigation measures incorporated into the design including the siting of the Development in a quarry void and the Site’s immediate landscape setting are important factors in reducing wider landscape effects. MNTGMVS301 Long Mountain Visual & Sensory Aspect Area (Indirect Effects)

LVIA During Operation 3.13.12. The Long Mountain VSAA is c.950m south. B&A assigned a High landscape sensitivity to this Aspect Area.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.13. This equates to ‘Where the key characteristics, elements and associated uses are vulnerable to change and/or enhancement and where development can only be absorbed in limited situations. The thresholds for significant change are low’ (LVIA, Appendix 1, Table 1B) 3.13.14. Table 6 of the LVIA provides a full assessment and the following is of note:

 Overview of the Aspect Area in the Principal Study Area: ‘The Aspect Area is within close range to the south and the lower slopes (around Heldre Hill and Oak Plantation) are within the principal study area. There is a limited area south at a medium range. However, the majority of the Aspect Area is outwith the principal study area. The presence of Long Mountain is an important visual feature and provides a backdrop for easterly views. Expansive views are available’; and  The ZTV (Figure L3): ’Applies to a small area c.1.6km south-east (close range) and a restricted area c.2.9km south (medium range)’. 3.13.15. During Operation, it was determined that a Small magnitude of impact and a Moderate (neutral) significance of effect would occur. A Small magnitude of impact equates to ‘Where the development will cause small-scale changes to a limited number of landscape characteristics’. (LVIA, Appendix 1, Table 1C) A Moderate significance of effect applies to ‘Larger scale changes affecting the landscape to a noticeable degree without a significant resultant change in the character’. (LVIA, Appendix 1, Table 1F) 3.13.16. B&A maintains that the above is an appropriate assessment of indirect effects on landscape character.

LIR Appendix 2 During Operation 3.13.17. LIR Appendix 2 assesses the both the landscape value and sensitivity of the Long Mountain VSAA as High. The assessment does not refer to specific effects on landscape character but uses ‘broad reasoning’ that they will decrease dependent on distance. (LIR Appendix 2, paragraph 5.3) 3.13.18. During Operation, the LIR Appendix 2 determines a Medium magnitude of impact and a Moderate-Major (adverse) significance of effect. 3.13.19. The above equates to the following:

 Medium magnitude of impact applies ‘Where the development will cause changes to several landscape characteristics’ (LVIA, Appendix 1, Table 1C); and  Significance of effect would fall between two categories: Moderate (Larger scale changes affecting the landscape to a noticeable degree without a significant resultant change in the character) and Major (Landscape character and quality is affected to a large degree, such that the development is a substantive element, creating a character associated with the development) (LVIA, Appendix 1, Table 1F)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters MNTGMVS620 Breidden Hill Visual & Sensory Aspect Area (Indirect Effects)

LVIA During Operation 3.13.20. The Breidden Hill VSAA is c.2.2km north-east of the Site. B&A assigned a High landscape sensitivity to the VSAA. This equates to ‘Where the key characteristics, elements and associated uses are vulnerable to change and/or enhancement and where development can only be absorbed in limited situations. The thresholds for significant change are low’. (LVIA, Appendix 1, Table 1B) 3.13.21. Table 6 of the LVIA provides a full assessment and the following is of note:

 Overview of the Aspect Area in the Principal Study Area: ‘A broad arc (clockwise) south-east to the north-west of Breidden Hill is within the principal study area, whilst the northern part of Breidden Hill is outwith. The presence of quarrying does not greatly influence the Aspect Area in the principal study area and Breidden Hill provides expansive views towards the Site and is an important visual feature as a backdrop for views’; and  ZTV (Figure L3): ‘Applies to a number of isolated areas of Breidden Hill including the summit and on the lower slopes. The majority of Breidden Hill is outwith the ZTV’. 3.13.22. During Operation, it was determined that a Very Small magnitude of impact would occur. This equates to ‘Where the development will cause very small- scale changes to a limited number of landscape characteristics’. (LVIA, Appendix 1, Table 1C) Whilst a Minor (neutral) significance of effect would apply. ‘Some effects on existing landscape for which the development can be readily accommodated without affecting the character’. (LVIA, Appendix 1, Table 1F) 3.13.23. B&A maintains that the above is an appropriate assessment of indirect effects on landscape character.

LIR Appendix 2 During Operation 3.13.24. LIR Appendix 2 assesses the landscape value of the Breidden Hill VSAA as Moderate – High. Whilst landscape sensitivity is denoted as High. 3.13.25. The assessment of effects draws attention to the ‘ … Breidden Hills VSAA, where particularly important characteristics such as the views from the hill summits are affected, that specific characteristic is capable of being harmed even at distance’. (LIR Appendix 1, paragraph 5.3) 3.13.26. During Operation, the LIR Appendix 2 determines a Medium to Large magnitude of impact and a Moderate-Major (adverse) significance of effect. The above equates to the following:

 Medium to Large magnitude of impact: Equates to’ Where the development will cause some notable changes to several landscape characteristics’ (LVIA, Appendix 1, Table 1C); and

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters  Significance of effect would fall between two categories: Moderate (Larger scale changes affecting the landscape to a noticeable degree without a significant resultant change in the character) and Major (Landscape character and quality is affected to a large degree, such that the development is a substantive element, creating a character associated with the development) (LVIA, Appendix 1, Table 1F) MNTGMVS650 River Severn Flood Plain Visual & Sensory Aspect Area (Indirect Effects)

LVIA During Operation 3.13.27. The River Severn Flood Plain VSAA is c.300m north of the Site. B&A assigned a Medium landscape sensitivity to the VSAA. This equates to ‘Where the key characteristics, elements and associated uses of the landscape are susceptible to change but have the ability to absorb development in some situations. Thresholds for significant change are intermediate’ (LVIA, Appendix 1, Table 1B) 3.13.28. Table 6 of the LVIA provides a full assessment and the following is of note:

 Overview of the Aspect Area in the Principal Study Area: ‘The Aspect Area applies to the Severn Valley and broadly extends to the north and south-west of the Site. It comprises agricultural fields at a low elevation and the main transport corridors (road and rail). The Aspect Area is within the immediate vicinity of the Site (north and west) and continues to c.2km north-east (close range), c.9.6km north (long range) and c.15km (long range)’; and  The ZTV (Figure L3): ‘Applies to the majority of the Aspect Area. However, effects will apply to close and medium range, whilst long range effects will be greatly reduced’. 3.13.29. During Operation, it was determined that a close range, there will be a Medium magnitude of impact and a Moderate (neutral) significance of effect. At a medium range, there will be a Very Small magnitude of impact and a Minor (neutral) significance of effect. 3.13.30. In terms of the maximum level of effects, a Medium magnitude of impact equates to ‘Where the development will cause changes to several landscape characteristics’. (LVIA, Appendix 1, Table 1C) A Moderate significance of effect applies when ‘Larger scale changes affecting the landscape to a noticeable degree without a significant resultant change in the character’. (LVIA, Appendix 1, Table 1F) 3.13.31. B&A maintains that the above is an appropriate assessment of indirect effects on landscape character.

LIR Appendix 2 During Operation 3.13.32. LIR Appendix 2 assesses the landscape value of the River Severn Flood Plain VSAA as Moderate. Whilst landscape sensitivity is denoted as Medium. The assessment does not refer to specific effects on landscape character but uses ‘broad reasoning’ that they will decrease dependent on distance. (LIR Appendix 2, paragraph 5.3)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.33. During Operation, the LIR Appendix 2 determines a Large magnitude of impact and a Moderate – Major Moderate-Major (adverse) significance of effect. The above equates to the following:

 A Large magnitude of impact applies ‘Where the development will cause some large-scale changes to several landscape characteristics’. (LVIA, Appendix 1, Table 1C); and  Significance of effect would fall between two categories: Moderate (Larger scale changes affecting the landscape to a noticeable degree without a significant resultant change in the character) and Major (Landscape character and quality is affected to a large degree, such that the development is a substantive element, creating a character associated with the development) (LVIA, Appendix 1, Table 1F) Visual Effects 3.13.34. It should be noted that this response reviews the results for Viewpoint Locations 1 to 4, 10 to 13, 16 to 18 and 22 which are listed in the Local Impact Report (paragraph 5.50) 3.13.35. Effects During Construction and Decommissioning are not assessed in LIR Appendix 2. Therefore, a comparison can only be made with effects During Operation. 3.13.36. LIR Appendix 2 notes that the LVIA photomontage images have been prepared according to current best practice guidance and have been ‘proved’ due to the inclusion of wireframes (LVIA, Appendix 13). Paragraph 2.3 closes by stating ‘Enplan is content that these provide a reasonable basis on which to judge the effects of the proposals in the field’. 3.13.37. LIR Appendix 2 does not include an assessment of individual Viewpoint Locations but rather groups these together based on range and direction. B&A has extracted information citing the relevant paragraph. 3.13.38. Each Viewpoint Location is reviewed in turn and provides the following information:  LVIA During Operation: Summarises the LVIA findings and results;  LIR Appendix 2 During Operation: Identifies notable differences regarding receptor sensitivity, magnitude of impact and significance of effect when compared to the LVIA. Extracts are provided from LIR Appendix 2 including any reference to the Development such as mitigation measures along with the results (LIR Appendix 2, Table 2); and  B&A Conclusions: Presents the review of the results of the LVIA and LIR Appendix 2. It highlights relevant aspects for each Viewpoint Location which were considered in the LVIA namely, the Site context and mitigation measures. It addresses any differences between the assessments.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Viewpoint Location 1 From Heldre Lane immediately west of Whitehouse Farm (Refer to LVIA Figures L9 to L11A) 3.13.39. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 1 is from a gateway on Heldre Lane near to Whitehouse Farm (residential property) and is to the south-west of the Site within the immediate vicinity (c.300m). The LVIA assessed views for residents (both ground and potential first floor locations/gardens) (High sensitivity) and road users (Low sensitivity).

LVIA During Operation 3.13.40. The LVIA accepted that there would be a clear view of the upper elevation and roofline of the ERF building and the stack against the skyline. The ERF building will also reduce distant views of the lower slopes of Moel y Golfa. Existing treecover on the south-western Site boundary will screen views of the access road and other infrastructure in the central part of the Site at Green Farm. With regards to other mitigation measures, the natural cladding colours will assist in assimilating the proposed built form into a mainly rural visual setting. The Development will feature new elements which will be noticeable in the scene and will affect the overall impression of the view. (LVIA, paragraph 6.5.6, Figures L11 and 11a) 3.13.41. A Medium to Large, potentially Large magnitude of impact was recorded. Based on the latter, this equates to ‘Where the development would introduce new or additional elements which would form a significant and immediately apparent aspect of the scene and would affect the overall impression of the view’. (LVIA, Appendix 1, Table 1E) A Major (adverse) significance of effect was noted for residents and a Moderate (adverse) significance of effect for road users (worst case scenario). (LVIA, paragraph 6.5.6)

LIR Appendix 2 During Operation 3.13.42. There are notable differences between the LVIA and LIR Appendix 2 in terms of receptor sensitivity, magnitude of impact and significance of effect. LIR Appendix 2 assigns a High sensitivity to walkers on Heldre Lane and a Medium sensitivity to road users. It should be noted that walkers using Heldre Lane were not assessed at Viewpoint Location 1 in the LVIA. No request was made during the Scoping process in 2018 and pre-application stage in 2020 to consider other receptors and the LVIA concentrates on the main receptor groups relevant to each Viewpoint Location. 3.13.43. Viewpoint Locations 1 to 4 are grouped together by LIR Appendix 2. The assessment notes that the colour design is most effective where the Development is seen against the landform and the screen bund will reduce views of built form. However, such mitigation measures would not be sufficient to prevent significant effects due to their close proximity and ‘the scale and the alien nature of the development in the otherwise rural and largely unspoilt scene’. Specific reference is made to Viewpoint Location 1 noting that the Development would be viewed against the skyline and ‘… would be substantially taller than any other local built form and would dominate the scene’. This would represent the worst case visual effect in terms of Viewpoint Locations assessed. (LIR Appendix 2, paragraphs 6.4 and 6.5)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.44. LIR Appendix 2 records a Very Large magnitude of impact. This equates to ‘Where new or additional elements are introduced and the development is wholly dominant and intrusive within the context of the available view’. (LVIA, Appendix 1, Table 1E) A Major to Substantial (adverse) significance of effect was noted for residents and walkers on Heldre Lane (west of Whitehouse Farm) and a Major (adverse) significance of effect for road users.

B&A Conclusions 3.13.45. B&A has reviewed the findings of the LVIA and the results of LIR Appendix 2. The following is of note:  Viewpoint Location 1 located on Heldre Lane near to Whitehouse Farm (residential property). The photograph is taken from an elevated location near a gateway on the route and was selected to best represent views from residential properties;  The current scene has a wooded appearance, partly due to vegetation along the south-western Site boundary. The higher elevations of the Site including exposed mineral faces and benches can be seen against the skyline and limits wider views. Also evident are Moel y Golfa and Breidden Hill which form part of the background;  LIR Appendix 2 generally refers to mitigation measures citing the natural cladding colours and screen bunds in regards to Viewpoint Locations 1 to 4. However, it states that this will not be sufficient to prevent significant effects; and  In terms of Viewpoint Location 1, LIR Appendix 2 draws attention to the height of the Development against the skyline in comparison to other built form. This does not take into account the existing character of the Site, namely a quarry. Aspects of the architectural design incorporated into the Development further to screen bunds and selection of natural cladding colours includes the siting of built form within the quarry void. Whilst the proposed stack is bicolour to mitigate skyline views. 3.13.46. B&A maintain that when taking into account the mitigation measures outlined above, that the Development will not be wholly dominant within the context of the available view. Viewpoint Location 2 From Heldre Lane (Refer to LVIA Figures L12 to L14) 3.13.47. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 2 is from Heldre Lane and is to the south- east of the Site within the immediate vicinity (480m). The LVIA assessed views for road users (Low sensitivity).

LVIA During Operation 3.13.48. The LVIA accepted that there will be a clear view of the upper elevation and graduated roofline of the ERF building against higher ground. Whilst the upper part of the stack will be seen against the skyline. Mitigation measures notably the natural cladding colours will assist in assimilating the Development into a mainly rural visual setting. Direct views of the lower elevations of the ERF building, stack and vehicle movements will be reduced due to the screen bunds. The Development will feature new

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters elements which will be noticeable in the scene and will affect the overall impression of the view. (LVIA, paragraph 6.5.13 and Figure L14) 3.13.49. A Medium to Large magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate (adverse) significance of effect was recorded for road users. (LVIA, paragraph 6.5.13)

LIR Appendix 2 During Operation 3.13.50. There are notable differences between the LVIA and the LIR Appendix 2 in terms of receptor sensitivity, magnitude of impact and significance of effect. LIR Appendix 2 allocates a Medium sensitivity rating for road users. Effects on residents and walkers on other sections of Heldre Lane are considered in general terms. It should be noted that these receptor groups are not assessed at Viewpoint Location 2 in the LVIA. No request was made during the Scoping process in 2018 and pre-application stage in 2020 to consider other receptors and the LVIA concentrates on the main receptor groups relevant to each Viewpoint Location. 3.13.51. Viewpoint Locations 1 to 4 are grouped together by LIR Appendix 2. The assessment notes that the colour design is most effective where the Development is seen against the landform and the screen bund will reduce views of built form. However, such mitigation measures would not be sufficient to prevent significant effects due to their close proximity and ‘the scale and the alien nature of the development in the otherwise rural and largely unspoilt scene’. (LIR Appendix 2, paragraph 6.4) 3.13.52. LIR Appendix 2 records a Large magnitude of impact. This equates to ‘Where the development would introduce new or additional elements which would form a significant and immediately apparent aspect of the scene and would affect the overall impression of the view’. (LVIA, Appendix 1, Table 1E) A Major (adverse) significance of effect is noted for residents and walkers and a Moderate to Major (adverse) significance of effect for road users.

B&A Conclusions 3.13.53. B&A has reviewed the findings of the LVIA and the results of LIR Appendix 2. The following is of note:  Viewpoint Location 2 is located on Heldre Lane and the Site is most visible when travelling northwards downhill along the route. The photograph is taken from a gap in vegetation but elsewhere it restricts wider views including towards the Site;  The current scene looks across agriculture fields. The incomplete screen bund along the eastern Site boundary adjacent to Sale Lane can be seen. The Severn Valley with its pattern of fields and woodland provides a backdrop to the Site. Whilst higher rolling hills are present at a further distance; and

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters  LIR Appendix 2 generally refers to mitigation measures citing the natural cladding colours and screen bunds in regards to Viewpoint Locations 1 to 4. However, it states that this will not be sufficient to prevent significant effects. No reference is made to other aspects of the architectural design which have been incorporated into the Development and have been shown in the LVIA, when combined with the selection of cladding colours and screen bunds, play a key role in reducing significant effects. At Viewpoint Location 2, this includes the location of built form within a quarry void. Although not viewed at the skyline, the graduated roofline is distinct. Whilst the proposed stack is bicolour to mitigate skyline views. The overall scale and form of the Development is appropriate and in balance with the large scale nature of the landscape. 3.13.54. B&A maintain that when taking into account the mitigation measures outlined above, that the Development will not affect the overall impression of the view. Viewpoint Location 3 From public footpath immediately south of Nelly Andrews' Green (Refer to LVIA Figures L15 to L17) 3.13.55. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 3 is from a public footpath immediately south of Nelly Andrews' Green to the south of the Site within close range (710m). The LVIA assessed views for footpath users (Medium sensitivity).

LVIA During Operation 3.13.56. The LVIA accepted that there will be a clear view of the upper elevation and graduated roofline of the ERF building and stack against higher ground. Mitigation measures notably the natural cladding colours will assist in assimilating the Development into a mainly rural visual setting. Whilst the screen bund will reduce more direct views of vehicle movements. The Development will introduce new elements which will form a recognisable change to the amenity. Albeit, this will not be intrusive within the overall scene. (LVIA, paragraph 6.5.19 and Figure L17) 3.13.57. A Medium magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate (adverse) significance of effect was noted.

LIR Appendix 2 During Operation 3.13.58. There are notable differences between the LVIA and the LIR Appendix 2 in terms of receptor sensitivity, magnitude of impact and significance of effect. LIR Appendix 2 allocates a High sensitivity rating for footpath users.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.59. Viewpoint Locations 1 to 4 are grouped together by LIR Appendix 2. The assessment notes that the colour design is most effective where the Development is seen against the landform and the screen bund will reduce views of built form. However, such mitigation measures would not be sufficient to prevent significant effects due to their close proximity and ‘the scale and the alien nature of the development in the otherwise rural and largely unspoilt scene’. (LIR Appendix 2, paragraph 6.4) 3.13.60. LIR Appendix 2 records a Large magnitude of impact. This equates to ‘Where the development would introduce new or additional elements which would form a significant and immediately apparent aspect of the scene and would affect the overall impression of the view’. (LVIA, Appendix 1, Table 1E) A Major (adverse) significance of effect applies to footpath users.

B&A Conclusions 3.13.61. B&A has reviewed the findings of the LVIA and the results of LIR Appendix 2. The following is of note:  Viewpoint Location 3 is from the general footpath network. The photograph is taken from a point on a section of the route where a clearer view is available northwards to the Site. This is due to an increased elevation and a low hedgerow. Elsewhere on the footpath, woodland, the terrain and footpath alignment combine to prevent a direct visual connectivity with the Site;  The current scene looks across agricultural fields and farm outbuildings. The incomplete screen bund along the eastern Site boundary adjacent to Sale Lane is evident through gaps in the intervening vegetation. Whilst the higher elevations of the Site are seen against the pattern of agricultural fields and woodland in the Severn Valley and higher rolling hills. The wooded hills of Moel y Golfa and Breidden Hill are prominent; and  LIR Appendix 2 generally refers to mitigation measures citing the natural cladding colours and screen bunds in regards to Viewpoint Locations 1 to 4. However, it states that this will not be sufficient to prevent significant effects. No reference is made to other aspects of the architectural design which have been incorporated into the Development and have been shown in the LVIA, when combined with the selection of cladding colours and screen bunds, play a key role in reducing significant effects. At Viewpoint Location 3, this includes the location of built form within a quarry void. Although not viewed at the skyline, the graduated roofline is distinct and the overall scale and form of the Development is appropriate and in balance with the large scale nature of the landscape. 3.13.62. B&A maintain that when taking into account the mitigation measures outlined above, that the Development will not affect the overall impression of the view.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Viewpoint Location 4 From Heldre Lane at Upper Heldre (Refer to LVIA Figures L18 to L20) 3.13.63. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 4 is from Heldre Lane at Upper Heldre and is to the south-east of the Site within close range (990m). The LVIA assessed views for residents (ground floor locations/gardens) (High sensitivity) and road users (Low sensitivity).

LVIA During Operation 3.13.64. The LVIA accepted that there will be a clear view of the upper elevation and graduated roofline of the ERF building and the stack against higher ground. Mitigation measures notably the natural cladding colours will assist in assimilating the Development into a mainly rural visual setting. Direct views of the lower elevations of the ERF building and stack will be reduced by the screen bunds. The Development will introduce new elements which will form a recognisable change to the amenity. However, this is judged not to be intrusive within the overall scene. (LVIA, paragraph 6.5.26 and Figure L20) 3.13.65. A Medium magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate to Major (adverse) significance of effect for residents was noted and a Minor-Moderate (adverse) significance of effect for road users. (LVIA, paragraph 6.5.26)

LIR Appendix 2 During Operation 3.13.66. There are notable differences between the LVIA and the LIR Appendix 2 in terms of receptor sensitivity, magnitude of impact and significance of effect. LIR Appendix 2 allocates a Medium sensitivity rating for road users. 3.13.67. Viewpoint Locations 1 to 4 are grouped together by LIR Appendix 2. The assessment notes that the colour design is most effective where the Development is seen against the landform and the screen bund will reduce views of built form. However, such mitigation measures would not be sufficient to prevent significant effects due to their close proximity and ‘the scale and the alien nature of the development in the otherwise rural and largely unspoilt scene’. (LIR Appendix 2, paragraph 6.4) 3.13.68. LIR Appendix 2 records a Large magnitude of impact. This equates to ‘Where the development would introduce new or additional elements which would form a significant and immediately apparent aspect of the scene and would affect the overall impression of the view’. (LVIA, Appendix 1, Table 1E) A Major (adverse) significance of effect applies to residents (upper floor windows) a Moderate to Major (adverse) significance of effect for road users. The assessment also assigns a Major (adverse) significance of effect for walkers on other sections of Heldre Lane. It should be noted that such views are not separately assessed in the LVIA.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters B&A Conclusions 3.13.69. B&A has reviewed the findings of the LVIA and the results of LIR Appendix 2. The following is of note:  Viewpoint Location 4 is taken from a field gateway on Heldre Lane and is included to show the maximum level of views from the route. Elsewhere, woodland and hedgerows provide a degree of screening including for road users (and walkers);  In terms of the current scene, the elevated location (c.165mAOD) looks down across agricultural fields and woodland. The Site is seen at a further distance and the incomplete screen bund along the eastern Site boundary adjacent to Sale Lane can be seen. There is a backdrop of agricultural fields and woodland in the Severn Valley and the wooded slopes of Crowther’s Coppice and Allt Wood (LVIA, Figure L18);  Although at close range, the Site is viewed in a wider context due to the elevation of the view; and  LIR Appendix 2 generally refers to mitigation measures citing the natural cladding colours and screen bunds in regards to Viewpoint Locations 1 to 4. However, it states that this will not be sufficient to prevent significant effects. No reference is made to other aspects of the architectural design which have been incorporated into the Development and have been shown in the LVIA, when combined with the selection of cladding colours and screen bunds, play a key role in reducing significant effects. At Viewpoint Location 4, this includes the location of built form within a quarry void. Although not viewed at the skyline, the graduated roofline is distinct and the overall scale and form of the Development is appropriate and in balance with the large scale nature of the landscape. 3.13.70. B&A maintain that when taking into account the mitigation measures outlined above, that the Development will not affect the overall impression of the view. Viewpoint Location 10 From Garreg Bank (lower), Trewern (Refer to LVIA Figures L36 to L38) 3.13.71. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 10 is from Garreg Bank (lower) in Trewern and is to the north-east of the Site within close range (1.7km). The LVIA assessed potential views for residents (ground floor locations/gardens) (High sensitivity) and road users (Low sensitivity).

LVIA During Operation 3.13.72. The LVIA accepted that there will be a clear view of the upper elevation of the ERF building and stack which will be seen against the skyline. Intervening vegetation restricts direct views of the lower parts of the proposed built form. Mitigation measures notably the natural cladding colours will assist in assimilating the Development into a mainly rural visual setting. The Development will introduce new elements which will be noticeable in the scene and will affect the overall impression of the view. (LVIA, paragraph 6.6.22 and Figure L38)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.73. A Medium to Large magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate to Major (adverse) significance of effect for residents and a Moderate (adverse) significance of effect for road users. (LVIA, paragraph 6.6.22)

LIR Appendix 2 During Operation 3.13.74. The LIR Appendix 2 concurred with the results of the LVIA regarding residents (ground floor locations/gardens). A differentiation occurred in the assessment of road users. B&A applies a Low sensitivity, whereas LIR Appendix 2 assigns a Medium sensitivity rating for road users. The has been assumed as pedestrians/walkers are not assessed from this Viewpoint Location. 3.13.75. This is one of the Viewpoint Locations which are grouped together by LIR Appendix 2 which are from Trewern, along the A458 and the Severn Valley (Viewpoint Locations 8 to 15).

B&A Conclusions 3.13.76. An assessment of the Development During Operation is not provided in the LIR Appendix 2 to support the results. 3.13.77. In the LVIA, Viewpoint Location 10 (c.1.7km) was judged to be a higher magnitude of impact when compared to others assessed in Trewern, for example, at Viewpoint Location 11. The latter is also at close range but at a further distance (1.9km). A fuller view of the Development is available due to a combination of the acute angle of the viewer, a slightly lower elevation (c.91mAOD) and the layout of proposed built form. Viewpoint Location 11 From Garreg Bank (upper), Trewern (Refer to LVIA Figures L39 to L41) 3.13.78. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 11 is from Garreg Bank (upper) in Trewern and is to the north-east of the Site within close range (1.9km). The LVIA assessed potential views for residents (upper floor windows) (Medium sensitivity) and road users (Low sensitivity

LVIA During Operation 3.13.79. The LVIA accepted that there will be a clear view of the upper elevation and roofline of the ERF building against a backdrop of distant higher ground. Whilst the stack is seen against the skyline. Intervening vegetation restricts direct views of the lower parts of the proposed built form. Mitigation measures notably the natural cladding colours will assist in assimilating the Development into a mainly rural visual setting. The Development will introduce new elements which will form a recognisable change to the amenity but will not be intrusive within the overall scene. (LVIA, paragraph 6.6.29 and Figure L41)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.80. A Medium magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate (adverse) significance of effect for residents was noted and a Minor-Moderate (adverse) significance of effect for road users. (LVIA, paragraph 6.6.29)

LIR Appendix 2 During Operation 3.13.81. There are notable differences between the LVIA and the LIR Appendix 2 in terms of receptor sensitivity, magnitude of impact and significance of effect. LIR Appendix 2 allocates a High sensitivity rating for residents (upper floor windows) and Medium sensitivity rating for road users. 3.13.82. This is one of the Viewpoint Locations which are grouped together by LIR Appendix 2 which are from Trewern, along the A458 and the Severn Valley (Viewpoint Locations 8 to 15). 3.13.83. LIR Appendix 2 records a Medium to Large magnitude of impact. This equates to ‘Where the development would introduce new or additional elements which will be noticeable in the scene and would affect the overall impression of the view’. (LVIA, Appendix 1, Table 1E) A Moderate to Major (adverse) significance of effect applies to residents (upper floor windows) and Moderate (adverse) significance of effect for road users. The latter has been assumed as pedestrians/walkers are not assessed from this Viewpoint Location.

B&A Conclusions 3.13.84. An assessment of the Development During Operation is not provided in the LIR Appendix 2 to support the results. Nor does it provide context to the Site and the immediate environs of the viewer. Of note is the following:  Viewpoint Location 11 (c.110mAOD) is located adjacent to a hedgerow gap on the roadside. It represents a sequential view and is representative of nearby residential properties;  The view looks across agricultural fields and residential areas in Trewern. At a further distance, is the A458. The Site is viewed as part of a higher area of landform which includes the upper extents of woodland abutting the road;  Higher areas of landform include Long Mountain, Crowther’s Coppice and Allt Wood which are prominent features; and  Further to the choice of cladding colour, other relevant mitigation measures include the main ERF building which features a graduated roofline. Whilst the proposed stack is bicolour to mitigate skyline views. 3.13.85. B&A rejects the conclusion of LIR Appendix 2 that the Development will result in a Medium to Large magnitude of impact.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.86. Although the upper part of the ERF building and stack will be clearly in view at the skyline, it will not affect the overall impression of the view. B&A maintains that the Development will introduce new elements which will from recognisable change to the amenity, albeit this will not be intrusive for the viewer. In the LVIA, effects were found to be significant for residents (upper floor windows). It should also be noted that the higher results recorded by LIR Appendix 2 are due in part to the difference in receptor sensitivity ratings. The LVIA assigns a Medium sensitivity to upper floor windows and we maintain that a differentiation should be made between such views and those from ground floor locations/gardens (High sensitivity) in accordance with the GLVIA Third Edition. Viewpoint Location 12 From Criggion Lane, Trewern (Refer to LVIA Figures L42 to L44) 3.13.87. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 12 is from Criggion Lane in Trewern and is to the north-east of the Site within close range (1.7km). The LVIA assessed potential views for residents (upper floor windows) (Medium sensitivity) and road users (Low sensitivity).

LVIA During Operation 3.13.88. The LVIA accepted that there will be a clear view of the ERF building and stack against the skyline seen at an acute angle from this Viewpoint Location. Intervening vegetation restricts direct views of the lower parts of the proposed built form. Mitigation measures notably the natural cladding colours will assist in assimilating the Development into a mainly rural visual setting. The Development will introduce new elements which will form a recognisable change to the amenity, albeit, this will not be intrusive within the overall scene. (LVIA, paragraph 6.6.36 and Figure L44) 3.13.89. A Medium magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate (adverse) significance of effect for residents was noted and a Minor-Moderate (adverse) significance of effect for road users. (LVIA, paragraph 6.6.36)

LIR Appendix 2 During Operation 3.13.90. There are notable differences between the LVIA and the LIR Appendix 2 in terms of receptor sensitivity, magnitude of impact and significance of effect. LIR Appendix 2 allocates a High sensitivity rating for residents (upper floor windows) and Medium sensitivity rating for road users. 3.13.91. This is one of the Viewpoint Locations which are grouped together by LIR Appendix 2 which are from Trewern, along the A458 and the Severn Valley (Viewpoint Locations 8 to 15).

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.92. LIR Appendix 2 records a Medium to Large magnitude of impact. This equates to ‘Where the development would introduce new or additional elements which will be noticeable in the scene and would affect the overall impression of the view’. (LVIA, Appendix 1, Table 1E) A Moderate to Major (adverse) significance of effect applies to residents (upper floor windows) and Moderate (adverse) significance of effect for road users. The latter has been assumed as pedestrians/walkers are not assessed from this Viewpoint Location. No request was made during the Scoping process in 2018 and pre-application stage in 2020 to consider other receptors and the LVIA concentrates on the main receptor groups relevant to each Viewpoint Location.

B&A Conclusions 3.13.93. An assessment of the Development During Operation is not provided in the LIR Appendix 2 to support the results. Nor does it provide context to the Site and the immediate environs of the viewer. Of note is the following:  Viewpoint Location 12 (c.70mAOD) is located on the north- western edge of Trewern and shows a typical open view which is available in the village at a lower level. This represents generally a static rather than a sequential view;  The view looks across agricultural fields (pasture) and the Site forms part of an elevated area of landform including the upper extents of woodland abutting the A458;  A glimpsed view is possible of the northern edge of the existing quarry against the skyline. Albeit, the main Site area is hidden from view. Long Mountain, Crowther’s Coppice and Allt Wood are notable features (Figure L42); and  Further to the choice of cladding colour, other relevant mitigation measures include the main ERF building which features a graduated roofline. Whilst the proposed stack is bicolour to mitigate skyline views. 3.13.94. B&A rejects the conclusion of LIR Appendix 2 that the Development will result in a Medium to Large magnitude of impact. Although the upper part of the ERF building and stack will be clearly in view at the skyline, it will not affect the overall impression of the view. B&A maintains that the Development will introduce new elements which will from recognisable change to the amenity, albeit this will not be intrusive for the viewer. In the LVIA, effects were found to be significant for residents (upper floor windows). 3.13.95. It should also be noted that the higher results recorded by LIR Appendix 2 are due in part to the difference in receptor sensitivity ratings. The LVIA assigns a Medium sensitivity to upper floor windows and we maintain that a differentiation should be made between such views and those from ground floor locations/gardens (High sensitivity) in accordance with the GLVIA Third Edition.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Viewpoint Location 13 From lane at Golfa Bank and adjacent to The Old Shop Cottage (Refer to LVIA Figures L45 to L47) 3.13.96. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 13 is from a lane at Golfa Bank and is to the north-east of the Site within close range (2.3km). The LVIA assessed potential views for residents (upper floor windows) (Medium sensitivity) and road users (Low sensitivity).

LVIA During Operation 3.13.97. The LVIA accepted that there will be a clear view of the ERF building and stack against the skyline seen at an acute angle from this Viewpoint Location. The screen bund and vegetation outwith the Site would restrict views of the lower levels of proposed built form. Mitigation measures notably the natural cladding colours will assist in assimilating the Development into a mainly rural visual setting. The LVIA concluded that it will introduce new elements which will result in a recognisable change to the amenity, albeit this will not be intrusive within the overall scene. (LVIA, paragraph 6.6.43 and Figure L47) 3.13.98. A Medium magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate (adverse) significance of effect was noted for residents (upper floor windows) and a Minor-Moderate (adverse) significance of effect for road users. (LVIA, paragraph 6.6.43)

LIR Appendix 2 During Operation 3.13.99. There are notable differences between the LVIA and the LIR Appendix 2 in terms of receptor sensitivity and significance of effect. LIR Appendix 2 allocates a High sensitivity rating for residents (upper floor windows) and Medium sensitivity rating for road users. 3.13.100. This is one of the Viewpoint Locations which are grouped together by LIR Appendix 2 which are from Trewern, along the A458 and the Severn Valley (Viewpoint Locations 8 to 15). An assessment of the Development During Operation is not provided to support the results. 3.13.101. LIR Appendix 2 records a Medium magnitude of impact which replicates the LVIA. A Moderate to Major (adverse) significance of effect is determined for residents (upper floor windows) and a Moderate (adverse) significance of effect for road users. The latter has been assumed as pedestrians/walkers are not assessed from this Viewpoint Location.

B&A Conclusions 3.13.102. B&A has reviewed the findings of the LVIA and the results of LIR Appendix 2. It is accepted that there will be a clear view of the ERF building and stack against the skyline for receptors. It is accepted that glimpsed views are possible over nearby hedgerows and due to the gateways along the lane to the south-east. Albeit, for the most part this is a static rather than sequential view.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.103. LIR Appendix 2 does not provide a narrative to support its results. However, both the LVIA and Appendix 2 record the same magnitude of impact (i.e. Medium). In this instance, the difference is due to the increased receptor sensitivity by LIR Appendix 2 both in terms of residents and road users. 3.13.104. The LVIA states that most views from residential properties will be from upper floor windows (Medium sensitivity) and maintains that a differentiation should be made between such views and those from ground floor locations/gardens (High sensitivity) in accordance with the GLVIA Third Edition. Viewpoint Location 16 From Moel y Golfa (Refer to LVIA Figures L54 to L56) 3.13.105. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 16 is from a public footpath on Moel y Golfa and is to the north-east of the Site within close range (3km). The LVIA assessed potential views for footpath users (Medium sensitivity).

LVIA During Operation 3.13.106. The LVIA accepted that there will be a clear view of the ERF building and the upper elevation of the stack. This will be against a backdrop of agricultural fields. With regards to mitigation measures, the natural cladding colours will assist in assimilating the proposed built form into a mainly rural visual setting. The Development will feature new elements which will represent a noticeable change to the visual amenity; albeit this will not impose on the wider setting. (LVIA, paragraph 6.6.3 and Figure L56) 3.13.107. A Medium magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate (neutral) significance of effect significance of effect was noted. (LVIA, paragraph 6.6.3)

LIR Appendix 2 During Operation 3.13.108. There are notable differences between the LVIA and the LIR Appendix 2 in terms of receptor sensitivity, magnitude of impact and significance of effect. B&A assigns a Medium sensitivity for footpath users. LIR Appendix 2 assigns a High sensitivity rating. 3.13.109. This is one of the Breidden Hills Viewpoint Locations (16 to 18) that LIR Appendix 2 refers to as a group. It is noted that ‘although at distances of 3km to 5km from the development, that the viewer would be looking down on development and able to see substantially more of the development that from any other set of or single viewpoint, in which the screen bunding mitigation would be evidently much less effective, means that the magnitude of these visual effects is different to other lower level but similarly distanced viewpoints. Although a comparatively small component in the view, it would contrast with other development in terms of its scale and form, especially the stack with its occasional plume, and would by its nature be likely to draw the eye to it’. (LIR Appendix 2, paragraph 6.7)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 3.13.110. LIR Appendix 2 records a Medium to Large magnitude of impact. This equates to ‘Where the development would introduce new or additional elements which will be noticeable in the scene and would affect the overall impression of the view’. (LVIA, Appendix 1, Table 1E) A Moderate to Major (adverse) significance of visual is noted. (LIR Appendix 2, paragraph 6.7)

B&A Conclusions 3.13.111. B&A has reviewed the findings of the LVIA and LIR Appendix 2. It is accepted that there will be a view of the upper elevation and roofline of the ERF building and the higher part of the stack. B&A judge that a neutral nature of effect can result in certain situations when considering the mitigation measures and the built form of the Development. LIR Appendix 2 judge that all new development is categorised as adverse.  The description provided in LIR Appendix 2 groups Viewpoint Locations 16 to 18 and does not provide context to the Site and the immediate environs of the viewer. Viewpoint Location 16 (c.350mAOD) is located in a clearing on the footpath to the summit. The narrative in the LVIA draws attention to existing mature woodland which will restrict views in places. It therefore represents a static view along the footpath rather than a sequential view;  Close to the viewer is the wooded top of Moel y Golfa. The view widens to incorporate Long Mountain and the wooded slopes of Crowther’s Coppice and Allt Wood form part of the backdrop;  The Site is part of a wider area of raised ground which also includes woodland abutting the A458, a main transport route. The incomplete screen bund along the eastern Site boundary adjacent to Sale Lane and the central area of the Site can be seen. At a lower level, is the Severn Valley with its pattern of agricultural fields bounded by hedgerows, woodland blocks and dispersed settlement. (Figure L54);  B&A rejects the conclusion of LIR Appendix 2 that the Development will result in a Medium to Large magnitude of impact. Although the viewer will be looking down towards the Site, it will be in a wider context of the Severn Valley. This includes the main transport routes and features other development including large scale industrial buildings noticeable due to their light colour;  The reasoning that a higher magnitude of impact should apply because it does not apply to others at a similar distance but at a lower level is not a fair judgement as each Viewpoint Location should be judged on its own merits; and  The screen bund is designed to reduce views of activities and built form at a lower elevation which will be achieved. Also notable for this Viewpoint Location is the architectural design incorporating a graduated roofline and choice of cladding colours. The photomontage view illustrates the average visible plume but is not judged to be greatly visible. 3.13.112. B&A maintains that the Development will introduce new elements which will from recognisable change to the amenity, albeit this will not be intrusive for the viewer. The panoramic view from Viewpoint Location 16 shows the large scale nature of the landscape. The Development is also of a suitable size when compared to other built form in view.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Viewpoint Location 17 From Middletown Hill (Refer to LVIA Figures L57 to L59) 3.13.113. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 17 is from the upper part of Middletown Hill and is to the north-east of the Site within medium range (5km). The LVIA potential views for walkers (general recreation) (Medium sensitivity).

LVIA During Operation 3.13.114. The LVIA accepted that there will be a view of the upper elevation and roofline of the ERF building and the higher part of the stack against a backdrop of agricultural fields. 3.13.115. With regards to mitigation measures, the natural cladding colours will assist in assimilating the proposed built form into a mainly rural visual setting. The combination of the screen bund along Sale Lane and existing woodland in the immediate vicinity of the Site will restrict more direct views of the lower elevations of the ERF building. The Development will feature new elements which represents a minor component of the wider view and will not affect the overall quality of the scene. (LVIA, paragraph 6.6.69 and Figure L59) 3.13.116. A Small magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements but would constitute only a minor component of the wider view which the casual observer could miss or where awareness does not affect the overall quality of the scene’. (LVIA, Appendix 1, Table 1E) A Minor-Moderate (neutral) significance of effect was noted. (LVIA, paragraph 6.6.69)

LIR Appendix 2 During Operation 3.13.117. There are notable differences between the LVIA and the LIR Appendix 2 in terms of receptor sensitivity, magnitude of impact and significance of effect. B&A assigns a Medium sensitivity to walkers (general recreation). LIR Appendix 2 assigns a High sensitivity rating. 3.13.118. This is one of the Breidden Hills Viewpoint Locations (16 to 18) that LIR Appendix 2 refers to as a group. It is noted that ‘although at distances of 3km to 5km from the development, that the viewer would be looking down on development and able to see substantially more of the development that from any other set of or single viewpoint, in which the screen bunding mitigation would be evidently much less effective, means that the magnitude of these visual effects is different to other lower level but similarly distanced viewpoints. Although a comparatively small component in the view, it would contrast with other development in terms of its scale and form, especially the stack with its occasional plume, and would by its nature be likely to draw the eye to it’. (LIR Appendix 2, paragraph 6.7) 3.13.119. LIR Appendix 2 records a Medium magnitude of impact. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate to Major (adverse) significance of visual is noted. (LIR Appendix 2, paragraph 6.7)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters B&A Conclusions 3.13.120. B&A has reviewed the findings of the LVIA and LIR Appendix 2. It is accepted that there will be a view of the upper elevation and roofline of the ERF building and the higher part of the stack. B&A judge that a neutral nature of effect can result in certain situations when considering the mitigation measures and the built form of the Development. LIR Appendix 2 judge that all new development is categorised as adverse.  The description provided in LIR Appendix 2 groups Viewpoint Locations 16 to 18 and does not provide context to the Site and the immediate environs of the viewer. Viewpoint Location 17 (c.367mAOD) is from the upper part of Middletown Hill and the photograph demonstrates the view which is also available sequentially from the pathway downhill in a south-westerly direction. The top of Middletown Hill allows an extensive 360 degree panoramic view;  Close to the viewer are the wooded slopes and top of Moel y Golfa whilst Long Mountain is also a prominent feature. The view expands to incorporate the Severn Valley with its pattern of agricultural fields bounded by hedgerows, woodland blocks and dispersed settlement;  The Site is part of a wider area of raised ground which also includes woodland abutting the A458, a main transport route. (LVIA, Figure L57) There is a glimpsed view of the incomplete screen bund along the eastern Site boundary adjacent to Sale Lane and also the central area of the Site (LVIA, paragraph 6.6.69);  B&A rejects the conclusion of LIR Appendix 2 that the Development will result in a Medium magnitude of impact. Although the viewer will be looking down towards the Site, it will be in a wider context of the Severn Valley and Moel y Golfa, the latter which is close to the viewer. The Severn Valley includes the main transport routes and features other development including large scale industrial buildings noticeable due to their light colour. In addition, there is a caravan site in close range which can clearly be seen again notable due to their light colouring;  The reasoning that a higher magnitude of impact should apply because it does not apply to others at a similar distance but at a lower level is not a fair judgement as each Viewpoint Location should be judged on its own merits; and  The screen bund is designed to reduce views of activities and built form at a lower elevation which will be achieved. Also notable for this Viewpoint Location is the architectural design incorporating a graduated roofline and choice of cladding colours. The photomontage view illustrates the average visible plume but is not judged to be greatly visible. 3.13.121. B&A maintains that the Development will constitute a minor component of the wider view. Although in view, it will does not affect the overall quality of the scene. The panoramic view from Viewpoint Location 17 shows the large scale nature of the landscape. The Development is also of a suitable size when compared to other built form in view.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Viewpoint Location 18 From Rodney's Pillar (Refer to LVIA Figures L60 to L62) 3.13.122. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 18 is from the south-western side of Rodney's Pillar on Breidden Hill and is to the north of the Site within medium range (5km). The LVIA assessed potential views for receptors at the established viewing point at Rodney's Pillar (High sensitivity).

LVIA During Operation 3.13.123. The LVIA accepted that there will be a clear view of the upper elevation and roofline of the ERF building and the higher part of the stack. This will occur against a backdrop of agricultural fields. As part of mitigation measures, the natural cladding colours will assist in assimilating the proposed built form into a mainly rural visual setting. Existing woodland in the immediate vicinity of the Site will restrict more direct views of the lower elevations of proposed built form. The Development will feature new elements which represent a minor component of the wider setting and will not affect the general quality of the visual amenity. (LVIA, paragraph 6.6.77 and Figure L62) 3.13.124. A Small magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements but would constitute only a minor component of the wider view which the casual observer could miss or where awareness does not affect the overall quality of the scene’. (LVIA, Appendix 1, Table 1E) A Moderate (neutral) significance of effect was noted. (LVIA, paragraph 6.6.77)

LIR Appendix 2 During Operation 3.13.125. There are notable differences between the LVIA and the LIR Appendix 2 in terms of magnitude of impact and significance of effect. LIR Appendix 2 agrees with the High sensitivity rating for receptors. B&A judge that a neutral nature of effect can result in certain situations when considering the mitigation measures and the built form of the Development. LIR Appendix 2 judge that all new development is categorised as adverse. 3.13.126. This is one of the Breidden Hills Viewpoint Locations (16 to 18) that LIR Appendix 2 refers to as a group. It is noted that ‘although at distances of 3km to 5km from the development, that the viewer would be looking down on development and able to see substantially more of the development that from any other set of or single viewpoint, in which the screen bunding mitigation would be evidently much less effective, means that the magnitude of these visual effects is different to other lower level but similarly distanced viewpoints. Although a comparatively small component in the view, it would contrast with other development in terms of its scale and form, especially the stack with its occasional plume, and would by its nature be likely to draw the eye to it’. (LIR Appendix 2, paragraph 6.7) 3.13.127. LIR Appendix 2 records a Medium magnitude of impact. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate to Major (adverse) significance of visual is noted. (LIR Appendix 2, paragraph 6.7)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters B&A Conclusions 3.13.128. B&A has reviewed the findings of the LVIA and LIR Appendix 2. It is accepted that there will be a clear view of the upper elevation and roofline of the ERF building and the higher part of the stack.  The description provided in LIR Appendix 2 groups Viewpoint Locations 16 to 18 and does not provide context to the Site and the immediate environs of the viewer. Viewpoint Location 18 is a static view from the south-western side of Rodney's Pillar. The immediate area is open and offers a panoramic view from the upper part of Breidden Hill;  The existing view (c.365mAOD) comprises views of Moel y Golfa and Long Mountain. At a lower elevation there is a pattern of agricultural fields bounded by hedgerows, woodland blocks and dispersed settlement. At a further distance is Crowther’s Coppice and Allt Wood. Whilst the Site is part of a wider area of raised ground which also includes woodland abutting the A458 (LVIA, Figure L60). There is a glimpsed view of the incomplete screen bund along the eastern Site boundary adjacent to Sale Lane and also the central area of the Site (LVIA, paragraphs 6.6.72 and 6.6.73);  B&A rejects the conclusion of LIR Appendix 2 that the Development will result in a Medium magnitude of impact. Although the viewer will be looking down towards the Site, it will be in a wider context of the Severn Valley and hills both close to viewer and at a greater distance. The Severn Valley includes the main transport routes and features other development including large scale industrial buildings noticeable due to their light colour. Although the Development will be closer to the viewer in comparison, it will not be located in a wider area of raised land and woodland;  The reasoning that a higher magnitude of impact should apply because it does not apply to others at a similar distance but at a lower level is not a fair judgement as each Viewpoint Location should be judged on its own merits; and  The screen bund is designed to reduce views of activities and built form at a lower elevation which will be achieved. Also notable for this Viewpoint Location is the architectural design incorporating a graduated roofline and choice of cladding colours. The photomontage view illustrates the average visible plume but is not judged to be greatly visible. 3.13.129. B&A maintains that the Development will constitute a minor component of the wider view. Although in view, it will does not affect the overall quality of the scene. The panoramic view from Viewpoint Location 18 shows the large scale nature of the landscape. The Development is also of a suitable size when compared to other built form in view.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Viewpoint Location 22 From A458 at Buttington Bridge (Refer to LVIA Figures L72 to L74) 3.13.130. This response reviews the results During Operation in the LVIA and LIR Appendix 2. Viewpoint Location 22 is from the A458 at Buttington Bridge and is to the south-west of the Site within close range (2.4km). The LVIA assessed potential views for Offa’s Dyke Path National Trail users (High sensitivity) together with workers at nearby employment areas and road users (Low sensitivity).

LVIA During Operation 3.13.131. The LVIA acknowledged that there will be a clear view of the stack and the upper elevations of the ERF building against the skyline, albeit, at an acute angle. As part of mitigation measures, the natural colours of the cladding will assist in assimilating the proposed built form into a mainly rural visual setting. The LVIA concluded that the Development will feature new elements and will represent a noticeable change to the visual amenity; albeit this will not impose on the wider setting. (LVIA, paragraph 6.8.7 and Figure L74) 3.13.132. A Medium magnitude of impact was recorded. This equates to ‘Where the development would introduce new or additional elements and forms a recognisable change to the amenity but is not intrusive within the overall scene’. (LVIA, Appendix 1, Table 1E) A Moderate to Major (adverse) significance of effect for Trail users and a Minor-Moderate (adverse) significance of effect for workers at nearby employment areas and road users was noted. (LVIA, paragraph 6.8.7)

LIR Appendix 2 During Operation 3.13.133. There are notable differences between the LVIA and the LIR Appendix 2 in terms of assessment of receptor sensitivity, magnitude of impact and significance of effect. Although LIR Appendix 2 appears to agree with categorising workers at nearby employment areas and road users as a Low sensitivity. LIR Appendix 2 assigns a Very High sensitivity to Offa’s Dyke Path National Trail users (as opposed to High in the LVIA). 3.13.134. LIR Appendix 2 notes that the Development would be seen against the skyline and states that the colour design would work least well from this direction. Judging that ‘The form of the building and stack against the skyline, would be prominent and be in clear contrast to other features in the scene’. Similar effects would apply to adjoining sections of Offa’s Dyke Path. (LIR Appendix 2, paragraph 6.9) A Medium to Large magnitude of impact is recorded. This equates to ‘Where the development would introduce new or additional elements which will be noticeable in the scene and would affect the overall impression of the view’. (LVIA, Appendix 1, Table 1E) 3.13.135. The assessment concludes that there will be a Major (adverse) significance of effect for Offa’s Dyke Path National Trail users and a Moderate (adverse) significance of effect for road users. Focusing on the former, a Major magnitude of impact equates to when ‘The development results in changes that largely affect the view, or where the baseline visual context alters, such that the development is one of the principal visual elements unmistakably or easily seen’. (LVIA, Appendix 1, Table 1E)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters B&A Conclusions 3.13.136. B&A has reviewed the findings of the LVIA and LIR Appendix 2. It is accepted that there will be views of both the stack and the upper elevations of the ERF building against the skyline. 3.13.137. The assessment in the LIR Appendix 2 does not provide context to the Site and the immediate environs of the viewer. The photograph is taken from an area of existing development (Welshpool Livestock Sales and Buttington Cross Enterprise Park). Current north-easterly views encompasses a foreground of the A458, overhead power lines and agricultural fields. Whilst at a further distance as landform begins to rise is the western part of the Site which is flanked by higher ground of Long Mountain and the summits of Breidden Hill, Middletown Hill and Moel y Golfa. Many of which feature tracts of woodland. (LVIA, Figures L72 and L73) 3.13.138. B&A rejects the conclusion of LIR Appendix 2 that the Development will result in a Major magnitude of impact and the judgement that the choice of cladding colour does not work effectively. B&A maintains that the Development will not largely affect the view to such as degree as suggested in LIR Appendix 2. The principal visual elements will remain to be the hill formations flanking the Development.

3.14. PLANNING POLICY

3.14.1. Local Impact Report Comment: ‘LDP policies DM4, DM13, W2 and RE1 indicates that such a proposal must be able to demonstrate good design, have regard to the qualities and amenity of the surrounding area, there would be no adverse landscape impacts and visual impact is minimised through sensitive location and landscaping. It is considered that the proposal will have a significant and detrimental effect on the valued characteristics and qualities of the Powys landscape and will thus have a Negative impact’. (paragraph 5.51) 3.14.2. B&A Response: The Local Impact Report cites Policy DM4 Landscape, Policy DM13 Design and Resources, Policy W2 Proposals and Policy RE1 Renewable Energy of the Adopted Powys Local Development Plan 2011 – 2026 (April 2018). 3.14.3. It should be noted that Policy W2 Waste Management Proposals states that waste development must be suitable in terms of size and scale with no adverse landscape impacts resulting from proposals. In the case of Policy DM4 Landscape, adverse effects on the valued characteristics and qualities of the Powys landscape and Policy DM13 Design and Resources, in terms of adverse impacts on tourism assets and attractions are preceded by the word ‘unacceptable’. 3.14.4. As part of this response we have reviewed each of the above policies in turn. The LVIA includes a detailed evaluation of planning policy in relation to the Development. (LVIA, Section 7)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Policy DM4 Landscape 3.14.5. The policy states that new development either individually or cumulatively should not have an unacceptable adverse effect on the valued characteristics and qualities of the Powys landscape. Proposals should be appropriate and sensitive to the characteristics and qualities of the landscape, open views and tranquillity (1) and give consideration to LANDMAP, Registered Historic Landscapes and the visual amenity enjoyed by users of both Powys landscapes and adjoining areas (2). 3.14.6. Paragraphs 7.3.5 to 7.3.10 of the LVIA address design aspects relevant to this Site, in summary:  Location of built form within a quarry void, the arrangement of buildings in a tight cluster which allows the incorporation of screen bunds. Ground modelling in the central part of the Site will facilitate a screen bund directly south of the ERF building and the restored northern quarry face. Whilst the layout has taken into account existing topography of the elevated landform and mature mixed woodland adjacent to the north-west of the Site;  The overlay of the Zone of Theoretical Visibility of the stack and roof level of the turbine building on landscape character Figures for reference purposes including Figures L1 and L3 of the LVIA;  The results of the assessment of the access road were found to be a Moderate (neutral) significance of effect for road users due to the existing context of the Site and visual amenity experience;  Attention was drawn to the effective storage of materials in Laydown Areas during the construction phase and the subsequent use of the largest Laydown Area for future employment purposes; and  Mitigation measures of note comprise the choice of cladding colours for built form when considering the landscape setting and landscape proposals incorporated into the Landscape Masterplan (Drawing BT1180-D2). (LVIA, Appendix 2) Also of note is the Site context with regards to its topography, its immediate vicinity and the presence of mature vegetation. All of which combine to create a relatively well contained site. 3.14.7. In terms of (2), reference is made to current guidance, best practice and landscape character resources referred to in the LVIA at a national and county level. With regards to LANDMAP, the LVIA highlights the explanatory text for Policy DM4 Landscape. For Aspect Areas assessed as Moderate or Low, then consideration should be given to enhancement which would apply to the Crewgreen to Forden Hill and Scarp VSAA. The LVIA confirms that all five LANDMAP Aspect layers have been considered with regards to the Site and Site analysis has been caried out. Aspects of the Landscape Masterplan (Drawing BT1180-D2). (LVIA, Appendix 2) relevant to LANDMAP are noted. 3.14.8. With regards to the above and the review undertaken as part of this response, it is maintained that the Development will not have unacceptable adverse effects on the valued characteristics and qualities of the Powys landscape.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Policy DM13 Design and Resources 3.14.9. The policy states that new development should demonstrate good quality design and have regard to the qualities and amenity of the surrounding area, local infrastructure and resources. 3.14.10. Paragraph 7.3.12 of the LVIA addresses the relevant criteria summarised below:  (1) cross references Policy DM4 Landscape;  (2) refers to the five LANDMAP Aspect layers and Site analysis which has been used to establish local distinctiveness. This is reflected in the mitigation measures incorporated into the Development (e.g. choice of cladding colour, use of a quarry void, retained vegetation and screen bunds);  (3) The LVIA concludes that the Development will not adversely affect the setting and/or significant views of the Conservation Areas nor (4) will it have unacceptable adverse impacts on recreational and cultural heritage assets;  (9) The reduction of potential views from public footpaths, open access land and other recreation assets (e.g. National Trails), key mitigation measures include the selection of colour cladding for built form, graduated roofline of the main ERF building and landscape proposals illustrated by the Landscape Masterplan (Drawing BT1180-D2). (LVIA, Appendix 2);  (10) Reference is made to the construction of the access road which is assessed in the LVIA; and  (11) Visual effects were appraised for local residents (e.g. settlement areas, individual farmsteads and residential properties). 3.14.11. With regards to the above and the review undertaken as part of this response, it is maintained that the Development represents good quality design. It has clearly considered the qualities and amenity of the surrounding area, local infrastructure and resources. Policy W2 Waste Management Proposals 3.14.12. The policy states that waste management proposals should meet specific criteria. 3.14.13. Paragraph 7.3.17 of the LVIA addresses the relevant landscape and visual criteria. The assessment of Policy W2 replicates many of the same considerations of Policy DM4 Landscape and Policy DM13 Design and Resources previously reviewed. The LVIA highlighted that there should be no adverse impacts on (3) amenity or the environment and (5) features of built heritage interest. Furthermore, (6) there should be no adverse landscape impacts and visual impacts are minimised through sensitive location and landscaping proposals. 3.14.14. With regards to the above and the review undertaken as part of this response, it is maintained that the Development will not result in adverse landscape impacts whilst visual impacts are reduced given the Site location, its context, the mitigation measures incorporated into the Development and landscape proposals illustrated by the Landscape Masterplan (Drawing BT1180-D2). (LVIA, Appendix 2).

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Policy RE1 Renewable Energy 3.14.15. Policy RE1 includes criteria relevant to landscape and visual matters. 3.14.16. Paragraph 7.3.14 of the LVIA states that (3) no cumulative or in combination effects have been identified regards to the Development and other existing, approved or proposed renewable energy development. (4) Reference is made to the mitigation measures previously highlighted for Policy DM4 Landscape and Policy DM13 Design and Resources. Of importance is the siting of built form within a quarry void, selection of cladding colour and the proposed screen bunds shown on the Landscape Masterplan (Drawing BT1180-D2). (LVIA, Appendix 2). 3.14.17. With regards to the above and the review undertaken as part of this response, it is maintained that the Development satisfies the requirements of Policy RE1. 3.14.18. The purpose of this response is not to review planning policy but it should be noted that the Local Impact Report does not consider or evaluate the wider benefits of the Development in landscape and visual terms. This will facilitate the restoration of a larger area of the Site (as a former quarry) compared to the footprint area of the built form which is limited in comparison. 3.14.19. In the assessment of direct effects on landscape character, the LVIA describes the existing landscape character of the site in comparison to the characteristics of the Crewgreen to Forden Hill and Scarp VSAA defined by LANDMAP. Mineral extraction has resulted in a much changed landscape with typical features such as tracks, exposed mineral and a partially complete screen bund within the Site (LVIA, paragraph 5.3.4). This led to B&A assigning a Low-Medium sensitivity to the landscape character of the Site. The LVIA refers to Policy M5 Restoration and Aftercare and highlights the beneficial re-use and enhancement of the Site. (LVIA, paragraph 7.3.13)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 4. RESPONSE TO BIIG COMMENTS

4.1. INTRODUCTION 4.1.1. This Section addresses the comments raised by the BIIG relating to landscape and visual matters. Relevant paragraphs are referenced (BIIG Comment) with a response by B&A addressing issues (B&A Response).

4.2. THE DESIGN COMMISSION FOR WALES (DCW) 4.2.1. BIIG Comment: Paragraphs 1.1 to 1.4 concern the Design Commission for Wales (DCW) and process involved during the preparation of the ES including the Design Review Report (DCFW Ref: N234) issued in July 2020 by DCW.10 4.2.2. B&A Response: The LVIA states that its contents have been guided by observations from the DCW and refers to the following ‘In July 2020, preliminary discussions were held with the DCW. Comments regarding the design concept and building appearance were received. The presentation to the DCW included Plans showing the Zone of Theoretical Visibility (ZTV) demonstrating the area of potential visibility based on the upper elevations of the energy recovery hall and the stack together with the proposed Viewpoint Locations to be assessed. The Plans were submitted to the DCW in the same month’. (LVIA, paragraph 1.1.8) 4.2.3. Details of the design process and aspects raised by the DCW are addressed in the Design and Access Statement (February 2021). This includes choice of cladding colours and massing of built form etc.

4.3. RELATIONSHIP TO PUBLISHED POLICIES AND ADVICE 4.3.1. BIIG Comment: Paragraphs 2.1 to 2.13 refer to Technical Advice Note (TAN) 21 Waste (February 2014) including Annex C: Detailed Planning Considerations11 and the Adopted Powys Local Development Plan 2011 – 2026 (April 2018). 4.3.2. B&A Response: The comments are addressed in turn below. TAN 21 Waste (February 2014) 4.3.3. Section 15 Visual Impact of the document sets out considerations for the new development of waste facilities. Quotations are provided by BIIG but it is useful to consider the quoted paragraphs 15.1 and 15.3 in full to understand the context:

 ‘The development of any new building may lead to impacts on landscape character and visual amenity. Landscape and visual impacts are material planning considerations. A significant amount of public concern and anxiety can be generated by the proposed visual appearance of such waste management facilities.

10 Design Review Report, Buttington Energy Recovery Facility, Welshpool, Powys, DCFW Ref: N234, Meeting of 31st July 2020 11 Technical Advice Note (TAN) 21, The Welsh Government, February 2014

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters The site should take advantage of existing topography so as to reduce the visual impact and the facilities should not be located where they will have an adverse impact upon statutorily protected landscapes’. (TAN 21 Waste, paragraph 15.1); and  ‘Larger scale plants have the potential to create greater visual intrusion. Enclosed facilities will also require buildings and/or containers for the waste reception processing areas. Smaller, less conspicuous installations may be more appropriate in some circumstances, subject to the economic viability of the operation. Sites may be screened by landscaping works and amenity bunds as well as advance planting of trees, shrubs or hedges around the periphery of a site’. (TAN 21 Waste, paragraph 15.3) 4.3.4. B&A accept that landscape and visual impacts are material planning considerations. However, it is the scale of the changes that is key and whether they are judged to be so significantly adverse to refuse planning permission on such grounds. The LVIA did not find this in relation to landscape or visual matters, although allowing that some adverse impacts will occur in terms of the latter. 4.3.5. The LVIA addressed design considerations in detail at a site level in accordance with TAN 21 Waste (LVIA, paragraph 7.2.21). The design uses the quarry void which is a key mitigation measure further to the colour cladding and landscape proposals such as bunds and tree planting. It is important to note that during the operation phase, no allowance is made for the additional screening benefits provided by the proposed native woodland planting. (LVIA, paragraph 2.10.5) Mitigation measures incorporated into the Development include landscape proposals and architectural design are fully described in Section 4 of the LVIA. 4.3.6. The Site is not located in a statutory or non-statutory landscape designation. Effects on landscape and cultural heritage designations (in terms of LVIA) were all found to be below a Moderate (adverse) significance of effect. 4.3.7. BIIG refer to a planning application for an Energy Recovery Facility (Hoddesdon, Hertfordshire) (ref: 3195373 - 19 July 2019) which was refused by the Secretary of State. BIIG cite a quotation from paragraph 44 which forms part of the planning balance and overall conclusion. 4.3.8. For the LVIA, the beginning of paragraph 44 is relevant which reads ‘The Secretary of State considers that the significant adverse landscape and visual impacts, which as well as being in conflict with the development plan are also in conflict with emerging plan policies, policies of the Epping Forest Local Plan, policies of the Lee Valley Park Plan, and the Framework, carry considerable weight against the proposal…’ As noted previously above, the LVIA did not identify unacceptable adverse effects. 4.3.9. BIIG state in paragraph 2.5 that the Applicant proposes three mitigation measures, namely colour of cladding, tree planting and screen bunds. This does not reflect the mitigation measures incorporated into the Development which are fully described in Section 4 of the LVIA. For reference the elements of the strategy for landscape proposals and architectural design are provided below.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 4.3.10. It should be noted that the purpose of the screen bunds is to provide screening of activities/built form at a lower level. They are intended to screen the higher elevations of the ERF building and stack as suggested by BIIG in their comments (BIIG, Chapter 9, paragraph 2.8). In addition, consideration has been given to mitigation measures for the proposed stack which is bicolour to mitigate potential skyline views. 4.3.11. With regards to landscape proposals:

 ‘The existing Buttington Brickworks geological SSSI will not be affected by the Development;  Retained mature woodland on the southern Site boundary as part of the Development;  Remnant faces in the northern sector of the quarry will be restored;  A comprehensive screen bund design along the south-western and south-eastern boundaries will ensure that a high proportion of the ERF and also Laydown Area 4 remains hidden from view;  Extensive areas of native broadleaved woodland will be established on the screen bunds and restored northern quarry slopes to provide visual and biodiversity enhancement in the long term. Proposed planting will strengthen the existing framework of woodland both within and adjacent to the Site;  Provision for detailed landscape treatment of the new access road by creating areas of native broadleaved woodland together with open mosaic habitat and species-rich neutral grassland to the grass verges; and  SuDS measures include a surface water attenuation pond together with amphibian wetland and peripheral habitat creation’. (LVIA, paragraph 4.2.3) 4.3.12. In terms of architectural design:

 ‘With regards to the landform and landuse of the Site. The ERF is set on a north-east to south-west configuration and situated in the quarry void in the central environs of the Site;  In terms of the wider landscape setting, the ERF is generally seen within a landform background, thus, with predominant land colour and hues. The scale of ERF building is appropriate and in balance with the large scale nature of the landscape;  The proposed stack is bicolour to mitigate skyline views where available;  Particular care has been given to consider potential views of the rooflines at the skyline. The main ERF building features a graduated roofline to avoid a boxy appearance;  The proposed cladding colour scheme is designed to merge and not contrast with the landscape. In addition, it intended to be regressive into views and not form a focus;  The ERF is well hidden from the environs of Trewern. Where it is seen from more elevated locations, it is only the upper part of the ERF building and stack that is visible and is appropriate in scale. The Site is at some distance from other settlement areas such as Welshpool; and

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters  Careful consideration has been given to known sensitive receptors including views from cultural heritage sites such as Powis Castle and Garden together with views along key tourist routes into Wales. Such factors have influenced the siting of proposed built form and landscape proposals incorporated into the Landscape Masterplan’. (LVIA, paragraph 4.2.10) 4.3.13. In terms of winter views, B&A carried out an assessment of specific Viewpoint Locations to evaluate whether additional visibility might occur and if the proposed cladding colour scheme is suitable during winter. The full assessment is provided in Section 6.14 of the LVIA. The assessment concluded that ‘In summary, the visual impact assessment found that in summer months, the selection of natural cladding colours will assist in assimilating the proposed built form into a mainly rural visual setting. This also applies to the winter views assessed. The cladding colour scheme merges with the wider landscape setting and forms part of the scene rather than being a focus’. (LVIA, paragraph 6.14.34) 4.3.14. BIIG provide partial quotes from the Key Environmental Aspects of Chapter 9 rather than the LVIA (i.e. Technical Appendix 9-1). The selected paragraphs are from ‘Consideration of Plume Visibility’ but do not make clear that paragraph 9.4.63 refers to a general comment about photomontage images and the average visible plume for all Viewpoint Locations assessed. Whilst paragraph 9.4.66 refers to the maximum calculated plume length from Viewpoint Location 11: From Garreg Bank (upper), Trewern. This concerned a specific exercise by B&A to assess effects from this particular Viewpoint Location. 4.3.15. Paragraphs 6.15.1 to 6.15.4 of the LVIA provide a fuller explanation of plume visibility and are included for reference below. 4.3.16. ‘Each photomontage illustration presented in the LVIA uses the average calculated visible plume as set out in the Methodology (see Appendix 1). The plume is taken into account as part of the assessment of the overall visibility of the stack. However, for the most part, the average visible plume does not represent a significant detractor’. (LVIA, paragraph 6.15.1) 4.3.17. ‘To explore a worst case scenario, an example photomontage view of the maximum calculated visible plume length is provided in Appendix 14. This has been established using the approach set out in the methodology (Appendix 1). The photomontage view illustrates the maximum calculated plume length from Viewpoint Location 11: From Garreg Bank (upper), Trewern which is within close range (c.1.9km north-east). In such instances, this longer visible plume will accentuate the context of the visibility of the overall ERF building and in particular the stack. However, two factors are of note, firstly, the transient nature of the visible plume and secondly, the wider context of the Site within which the visible plume will disperse, albeit, over a longer range than ordinarily experienced. This is not predicted to increase the overall scale of effect beyond the currently described limits. Thus, the significance of effect is not likely to increase either’. (LVIA, paragraph 6.15.4) 4.3.18. BIIG do not consider LANDMAP with regards to landscape character effects. In addition, there is no mention of LANDMAP in the BIIG comments regarding any Chapters of the ES.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Adopted Powys Local Development Plan 2011 – 2026 (April 2018) 4.3.19. BIIG refer to paragraphs 4.4.1 and 4.4.2 of the Adopted Powys Local Development Plan 2011 – 2026 (April 2018). The paragraphs are taken from the explanatory text relating to economic development and Policy E1 Employment Proposals on Allocated Employment Sites. 4.3.20. It is useful to look at a more fuller version of paragraph 4.4.1 which states ’… The LDP provides opportunity for all scales of employment uses. Employment development proposals on all sites should seek to reflect the character of the towns, villages and countryside settings in which they are located and will be considered against the relevant policies in the LDP’. 4.3.21. Paragraph 4.4.2 in full states ‘Allocated employment sites have been grouped into categories that reflect the nature of the site and the potential future uses. These categories, which reflect best practice and current thinking in adjoining authorities, are: … Local Sites: Sites for B1, B2 and B8 Uses providing a varied industrial and / or employment setting with minimised visual impact (for example, screening) yet located within close proximity to the main road and transport infrastructure as well as centres of population. These sites primarily serve a local market and may include local office developments’. 4.3.22. B&A do not agree with the BIIG conclusion that ‘This proposal is for a massive and very visible industrial facility in a village set in open countryside. It clearly would not comply with the conditions set out above’. (BIIG, Chapter 9, paragraph 2.12) 4.3.23. We would also like to draw attention to paragraph 4.4.4 which notes ‘Policy E1 also enables the provision of complementary ancillary employment uses that fall outside the B use classes where this improves site viability and enables new site development. Ancillary uses that might be complementary include … waste …’. 4.3.24. As stated in the LVIA, this policy allocates Buttington Quarry (Site Allocation Ref. No. P59 EA1) as a Local Site which is suitable for waste uses through Policy W1 Location of Waste Development. It is noted as ‘a brownfield site which is partly in employment use and is reserved for further expansion for General Industrial Uses’ in Appendix 1 – LDP Housing and Employment Sites. (LVIA, paragraph 7.3.2) 4.3.25. BIIG do not refer to the Site as being suitable for waste purposes through Policy W1 Location of Waste Development of the Adopted Powys Local Development Plan 2011 – 2026 (April 2018) in their comments. 4.3.26. With regards to the matters raised in paragraphs 4.4.1 and 4.4.2, the design process has taking into account the landscape setting including with regards to the layout, built form and choice of cladding colours as well as landscape proposals. When considering paragraph 4.4.4, the Development will provide a sustainable future use for an existing quarry. As set out in the Design and Access Statement (February 2021), there is a long term objective for the Development to facilitate wider aspirations for the Development Site to create an eco-business park.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 4.3.27. BIIG state that ‘Furthermore, Trewern is designated in the Powys LDP as a large village suitable for further housing development. Trewern is a residential area with no current industry apart from a haulage company located in Buttington Quarry. The proposed ERF would, in our opinion, and because of its visibility in particular, deter potential housing developers and purchasers from coming into the area. It would, therefore, work against the expressed aims of the Powys LDP’. (BIIG, Chapter 9, paragraph 2.13) 4.3.28. With regards to the Powys' Sustainable Settlement Hierarchy. Trewern is c.1.5km north of the Site and is categorised as a Large Village. The explanatory text states ‘Large Villages will accommodate housing growth (open market and affordable) in proportion to their size and facilities and according to their capacity to accommodate growth due to environmental and infrastructure capacity constraints. Economic development and the provision of local services is supported by policy and in some employment land will be allocated’. (BIIG, Chapter 9, paragraph 3.2.18) 4.3.29. It is important to note that the Site is outwith the settlement boundary of the village (Inset P56). The Development needs to be judged against applicable planning policy set out in the Adopted Powys Local Development Plan 2011 – 2026 (April 2018) including Policy E1 Employment Proposals on Allocated Employment Sites and Policy W1 Location of Waste Development. 4.3.30. The LVIA concluded that ‘With regards to current planning policy relating to landscape and visual matters, the Development will be supportive of policy at a national and local level including Planning Policy Wales (Edition 10) (2018), Technical Advice Notes 5, 12, 21 and 24, the Adopted Powys Local Development Plan 2011 – 2026 (April 2018) (namely Policy E1, SP7, DM2, DM4, DM7, DM13, M5, RE1, T1, W1 and W2) together with Biodiversity and Geodiversity SPG (Adopted October 2018) and Landscape SPG (Adopted April 2019)’. (LVIA, paragraph 8.5.1) 4.4. ADVERSE IMPACT ON MENTAL HEALTH 4.4.1. BIIG Comment: Paragraph 3.1 refers to the Health Impact Assessment and paragraph 3.2, the Wales Strategy for Health 2017-2022. 4.4.2. B&A Response: As stated in the LVIA, ‘The purpose and approach of the LVIA is to establish the main impacts of the Development upon landscape character, landscape designations and identified visual receptors against a defined baseline situation. It then determines the consequences and what the nature of these effects are likely to be…’ (LVIA, paragraph 1.1.5) 4.4.3. The LVIA concluded ‘Of the adverse impacts or effects that have been identified in the Assessment, none are so overriding that it would have a wholly dominant or intrusive visual effect nor will it remove distinctive attributes of landscape character identified through LANDMAP’. (LVIA, paragraph 8.6.5)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 4.4.4. BIIG directly links the results of the LVIA (in terms of visual effects) to the results of the Health Impact Assessment without explaining the different approaches including the use of very different methodologies. The Health Impact Assessment considers the findings of the LVIA and other technical reports submitted as part of the ES and addresses ‘impacts to human health from a wider perspective’ (Chapter 15 Overall Health Impact, paragraph 15.13.2)

4.5. ADVERSE IMPACT ON TOURISM

4.5.1. BIIG Comment: ‘The A458 trunk road which runs past the proposed ERF is the major tourist route to and beyond to parts of Ceredigion and Gwynedd. As the A458 enters Wales, the ERF would quickly become visible and would be a dominant feature of the landscape from Middletown Hill to Buttington, a distance of around 2 miles. This would be the first view that visitors had of Wales. It would conflict with their expectations of a rural non-industrialised landscape and would provide a very negative first impression. The natural landscape has high scenic value. The A458 has the Breidden Hills on one side and Cefn Digoll (Long Mountain) on the other and directly ahead are views of the Severn Valley. The ERF would be in an elevated position and directly in the line of sight for drivers along this road’. (paragraph 4.1) 4.5.2. ‘Planning Policy Wales 2018 focuses on “placemaking”. It defines this as “A holistic approach to the planning and design of developments and spaces focused on positive outcomes. It draws upon an area’s potential to create high quality development and public spaces that promote people’s prosperity, health, happiness and well-being in the widest sense’. (paragraph 4.2) 4.5.3. ‘We strongly contend that the visual impact of the ERF would achieve the exact opposite of these aspirations as well as being inconsistent with the requirements of the planning guidelines, the ‘Wellbeing of Future Generations’ legislation and the Powys Local Development Plan’. (paragraph 4.3) 4.5.4. B&A Response: B&A address matters raised separately below. Views from The A458 4.5.5. Mitigation measures are described in detail in the LVIA. With regards to architectural design, ‘Careful consideration has been given to known sensitive receptors including views from cultural heritage sites such as Powis Castle and Garden together with views along key tourist routes into Wales. Such factors have influenced the siting of proposed built form and landscape proposals incorporated into the Landscape Masterplan’. (LVIA, paragraph 4.2.10) 4.5.6. A summary of the assessment of Viewpoint Location 15 is provided as follows. Reference should be made to LVIA Figures L51 to L53.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Viewpoint Location 15 From A458 west of Wollaston 4.5.7. The LVIA considers views from a gateway alongside the A458. The Viewpoint Location is to the east of the Site within medium range (5.6km). 4.5.8. The selected Viewpoint Location is on the eastern edge of the ZTV (LVIA, Figure L7) and is a sequential view along the A458, rather than from the nearby Orchard School Care Home and residential properties. 4.5.9. Road users are categorised as a Low sensitivity. This applies to ‘Road users on the general network including ‘A’ class roads, minor roads and lanes. It also includes a place of work or recreation facilities (e.g. golf course) as the action takes place with less reference to external influences’. (LVIA, Appendix 1 Table 1D: Visual (Sensitivity) 4.5.10. LVIA Figure L51 shows the current scene. The wooded slopes of Moel y Golfa and rounded shape of Long Mountain are notable. Whilst the wooded slopes of Crowther’s Coppice and Allt Wood form part of the backdrop. The photograph demonstrates that the Site is hidden from view. 4.5.11. The LVIA recorded a Negligible magnitude of impact and Negligible (adverse) significance of effect for road users During Construction and Decommissioning. It was concluded that the Development will not materially alter the existing view. Potential views relate to crane movements and other aspects associated with the building or removal of the ERF against a landform backdrop. (LVIA, paragraphs 6.6.56 and 6.6.58) 4.5.12. During Operation, it was determined that a glimpsed view of the upper section of the stack only would be seen against higher ground (as opposed to skyline). When taking into account the distance and angle of view involved, a Very Small magnitude of impact and a Negligible (neutral) significance of effect was noted. (LVIA, paragraph 6.6.57) 4.5.13. As stated, Viewpoint Location 15 is on the eastern periphery of the ZTV (LVIA, Figure L7) and B&A carried out detailed technical analysis as part of the LVIA process. As outlined in Appendix 1 LVIA Methodology, the Zone of Theoretical Visibility (ZTV) including that shown on Figures L5 and L6 has been identified using computer based analysis established on the potential visibility of the stack (purple shading) and the upper roof section of the ERF combined with the stack (blue shading). This is based on a 70m high stack. Mitigation measures are not factored into the ZTV. (LVIA Appendix 1, paragraph 1.6.1) 4.5.14. The ZTV is founded on landform and key areas of existing woodland beyond the site boundary digitised from Ordnance Survey data. Therefore, it may suggest a wider area than exists in reality. In line with the GLVIA Third Edition, the ZTV is used as a broad assessment tool. It then allows a more detailed level of evaluation for visual and landscape character effects. (Appendix 1, paragraph 1.6.2)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 4.5.15. B&A considered other Viewpoint Locations in the vicinity of the A458 but did not identify additional views and maintains that the view from Viewpoint Location 15 is representative. No request by consultees was received for additional Viewpoint Locations during the Scoping process in 2018 and pre- application stage in 2020. 4.5.16. Viewpoint Locations 8 and 9 are from the A458 at Cefn and Trewern respectively and represent sequential views along the route. Road users are categorised as a Low sensitivity. A summary of the LVIA assessment is included below. The full assessment is provided in the LVIA, for Viewpoint Location 8 From A458 at Cefn (LVIA, paragraphs 6.6.1 to 6.6.7) and Viewpoint Location 9 From A458 at Trewern (LVIA, paragraphs 6.6.8 to 6.6.17).  Viewpoint Location 8 From A458 at Cefn (LVIA, Figures L30 to L32): North-east of the Site within close range (1.1km). The current situation notes that the photograph is from a footpath (pavement) alongside the A458 and illustrates the scene along the route which is generally available between Trewern and Cefn (LVIA, paragraph 6.6.1);  Viewpoint Location 9 From A458 at Trewern (LVIA, Figures L33 to L35): North-east of the Site within close range (1.9km). The current situation highlights that glimpsed views towards the Site from the A458 may be available. Namely, to the east in Middletown and between Wollaston (Viewpoint Location 15) and others explored at Trewern (Viewpoint Location 10 to 13). It also notes that views are restricted along sections of the A458 due to a combination of vegetation, hedgerows and terrain. Of reference is that ‘The ZTV generally indicates greater visual context on higher ground off the A458 and towards Middletown Hill’ (LVIA, paragraph 6.6.10); and  In both cases, the Site forms part of an elevated area of landform which appears as part of the backdrop, including the upper extents of woodland adjacent to the A458. The partially formed screen bund along the eastern Site boundary adjacent to Sale Lane can be identified. Long Mountain is a prominent feature. 4.5.17. In both cases, the LVIA recorded similar results for Viewpoint Locations 8 and 9:  During Construction: There will be views of crane movements and other aspects (e.g. building construction and scaffolding) associated with the building of the ERF at the skyline. The screen bund along Sale Lane will be completed, grass seeded and planted with native broadleaved trees. Whilst ground modelling within the central environs of the Site relating to the restored northern quarry face will be in view at Viewpoint Location 9. The Development will introduce new elements which will constitute a minor component of the wider view and will not affect the overall quality of the scene at both Viewpoint Locations. Small to Medium magnitude of impact (due to crane movements) and a Minor-Moderate (adverse) significance of effect (worst case scenario);

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters  During Operation: It was noted that there would be a clear view of the upper elevation of the ERF building and stack against the skyline, seen at an acute angle. Direct views of the lower parts of the proposed built form are limited by intervening landform and vegetation (both within and outwith the Site). The natural colours of the cladding will assist in assimilating the proposed built form into a mainly rural visual setting. The Development will introduce new elements which will form a recognisable change to the amenity but will not be intrusive within the overall scene. Medium magnitude of impact and a Minor-Moderate (adverse) significance of effect; and  During Decommissioning: In both cases, effects will be similar to that described during construction with views of intermittent crane movements etc. seen at the skyline. Whilst there will be no available views of Site activities relating to ground restoration. Native woodland planting associated with the screen bunds will provide screening benefits as it matures and long term enhancement including with regards to the wider Site setting. Overall, magnitude of impact will be slightly lower than predicted in comparison to construction. Small magnitude of impact with a Minor (adverse) significance of effect for road users. 4.5.18. Effects are judged to be not significant for road users at either Viewpoint Locations 8 or 9. Planning Policy Wales (Edition 10) (2018) 4.5.19. At the time the LVIA was undertaken, Planning Policy Wales (Edition 10) (2018) was current. 4.5.20. The LVIA paid particular attention to Chapter 2 People and Places: Achieving Well-being Through Placemaking, notably that a key planning principle is to achieve the right development in the right place. As stated in the LVIA ‘This involves making the best use of resources, including land which underpins sustainable development and limiting environmental impacts on natural, historic and cultural assets which must be protected. In addition, negative environmental impacts should be avoided in the wider public interest…’. (LVIA, paragraph 7.2.2) 4.5.21. The LVIA considered the Development against the key factors when Assessing the Sustainable Benefits of Development. Of note is the following:

 ‘The proposed ERF building and stack will be located in the quarry void in the central environs of the Site (see Illustrative Cross Sections in Appendix 3). The main ERF building features a graduated roofline to avoid a boxy appearance. The choice of cladding colours is intended to be sympathetic to the landscape setting and uses prevailing natural shades of green and light brown hues. Thus, it achieves a subtle yet high degree of architectural design presence’;  ‘The LVIA has assessed the individual phases of the Development. Landscape effects considers character (local and national), landscape designations and cultural heritage assets. Whilst visual effects appraises a range of receptors including residents, road users, visitors to Powis Castle and footpath users including on the Offa’s Dyke National Trail’;

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters  ‘In terms of landscape proposals, screen bunds will be planted with native broadleaved trees. The Landscape Masterplan also comprises areas of open mosaic habitat, species-rich neutral grassland and SuDS measures’;  ‘During the operation phase, the assessment has made no allowance for the additional screening benefits of proposed native woodland planting. Consideration is given to the screen bunds only. During the decommissioning phase, it will offer long term enhancement both in landscape and visual terms’; and  ‘Of the adverse impacts or effects that have been identified, none appear to be so overriding to the context of the view such that it would have a wholly dominant or intrusive effect’. (LVIA, paragraphs 7.2.3 to 7.2.7)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 5. OTHER OBJECTOR COMMENTS

5.1. INTRODUCTION 5.1.1. This Section addresses other objector comments regarding Chapter 9 of the ES received from cadw (2 July 2021), Welshpool Town Council, Trewern Community Council and CPRW Montgomeryshire. 5.1.2. The objector comment is provided followed by the response by B&A addressing issues (B&A Response).

5.2. CADW (LETTER DATED 2 JULY 2021)

5.2.1. Cadw Comment: ‘Thank you for your letter of 26 May 2021 requesting our comments on an objection raised by the National Trust about the above application. We note that the National Trust advise that the proposed development will be visible from Powis Castle and, if this is the case, we recommend that the applicant’s impact assessment will need to be updated analysing the likely impact of the development on the setting of Powis Castle’. 5.2.2. B&A Response: Cadw has submitted two letters to The Planning Inspectorate regarding the Development. As noted previously in Section 2 of this report, in the first letter (dated 21 May 2021), the LVIA methodology was judged to be acceptable. Furthermore, that ‘After consideration of the information submitted, Cadw have no objections to the proposed development’. 5.2.3. A second letter was submitted dated 2 July 2021 concerning Powis Castle. Following the requests made by the National Trust, B&A has assessed further Viewpoint Locations at Powis Castle in more detail (see Section 2 of this report). Viewpoint Location 24 is comparable to other additional viewpoints taken as part of this response and therefore, validates the robustness of the LVIA. It provides an elevated view and is set back from the mature tree at the end of the East Terrace, thereby, offering a view across the grounds of Powis Castle, It encompasses an expansive view of the Severn Valley to the east, environs of Welshpool and also the Site, Longmountain and the Breidden Hills to the north. The Site is c.6.4km north- east of Powis Castle.

5.3. WELSHPOOL TOWN COUNCIL

5.3.1. Welshpool Town Council Comment: ‘The planning application 21/0733/DNS was considered by Welshpool Town Council. Welshpool Town Council objected to the application for the following reasons…. 3. There would be a major adverse impact on the valued Powys landscape’. 5.3.2. B&A Response: The Welshpool Town Council does not define what aspects of the Powys landscape will be affected by the Development.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 5.3.3. The LVIA considered direct and indirect effects on landscape character basing the evaluation on LANDMAP methodologies and Site analysis in accordance with planning policy set out in the Adopted Powys Local Development Plan 2011 – 2026 (April 2018).

5.3.4. The LVIA concluded ‘Of the adverse impacts or effects that have been identified in the Assessment, none are so overriding that it would have a wholly dominant or intrusive visual effect nor will it remove distinctive attributes of landscape character identified through LANDMAP’. (LVIA, paragraph 8.6.5)

5.4. TREWERN COMMUNITY COUNCIL

5.4.1. Trewern Community Council Comment: ‘As we live close to the Welsh border, our local area is often seen as the ‘Gateway to Wales’, therefore not only will the proposed incinerator have a visual impact on our local landscape and be a constant reminder of the pollution it is causing, it will also have an impact on tourism in Wales. Visitors to the area and local residents alike enjoy the rural setting of the area and do not want to see it industrialised. This will work against our local endeavours for the sustainability of tourism activity in Wales, as our village is strategically positioned. A huge chimney will be a visible blot on the landscape and may easily deter visitors, especially repeat visitors, if their first impression of the local environment is a negative one…’ 5.4.2. B&A Response: B&A has considered views from the A458 as part of the response to BIIG comments (see Section 4 of this report). A review is provided of Viewpoint Location 15 From A458 west of Wollaston as well as Viewpoint Locations 8 and 9 which are from the A458 at Cefn and Trewern respectively. The three Viewpoint Locations were assessed in the LVIA and effects are not judged to be significant for road users. 5.4.3. B&A evaluated other Viewpoint Locations in the vicinity of the A458 during the preparation of the LVIA and did not identify additional views. No request was received from consultees for additional Viewpoint Locations during the Scoping process in 2018 and pre-application stage in 2020. 5.4.4. It should be noted that the ZTV (LVIA, Figures L5 and L6) is founded on landform and key areas of existing woodland beyond the site boundary, digitised from Ordnance Survey data. Therefore, it may suggest a wider area than exists in reality including from the road network and is acknowledged in the LVIA. (LVIA, Appendix 1, paragraph 1.6.2) 5.4.5. With regards to mitigation measures, ‘Careful consideration has been given to known sensitive receptors including views from cultural heritage sites such as Powis Castle and Garden together with views along key tourist routes into Wales. Such factors have influenced the siting of proposed built form and landscape proposals incorporated into the Landscape Masterplan’. (LVIA, paragraph 4.2.10)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 5.5. THE CAMPAIGN FOR THE PROTECTION OF RURAL WALES (CPRW) MONTGOMERYSHIRE (DATED RECEIVED 19 MAY 2021)

5.5.1. CPRW Montgomeryshire Comment: ‘CPRW Montgomeryshire have read the submission by BIIG and would wish to support the highly detailed analysis carried out into all aspects of the project and believe that the conclusions they reach reflect the very real threat that this project poses to this area of Montgomeryshire. We will not repeat the conclusions that we endorse but would wish to add the following comments:  The project is located in a particularly sensitive location as a principal entry point into Mid Wales. As one approaches Wales along the A458, and also along the Cambrian railway line, the Breidden hill scape gives a relatively sudden welcome to a rural Wales topography that gives joy to visitors and returners alike. To then sweep round the corner at Trewern and be confronted by a massive, contorted structure awkwardly positioned on a ridge and emphasised by its chimney and plume will appear dominating and anachronistic but also raise concerns as to the Welsh attitude to its landscape and priorities. Although it may be viewed by some as too emotional to consider the degradation and industrialisation of this distinctive entry into Mid Wales, such cultural landscape issues are important to people. It is fair to say that most people associate a tall chimney, together with its continual plume, as degrading the area to an industrial landscape and now perceive it as signifying a return to a ‘smokestack’ technology’. (Item 1)  ‘Not only is the landscape impact severe in the Trewern area but also highly detrimental to key assets such as Offa’s Dyke Path, the Severn Way and the Montgomeryshire Canal. The Powys LDP recognises all of these assets as Strategic Resources that should not be adversely impacted’. (Item 3)  ‘Offa’s Dyke Path is predominantly walked from south to north and as it descends from Long Mountain the ZTV shows that the incinerator will be very prominent in the walker's view with the visibility for the whole of that time being similar to that shown in Viewpoint 22. As stated in the LVIA, the effect at this viewpoint is Major for sensitive receptors so the total effect over this time will be highly significant. This is followed by virtually a day’s walking with the facility readily visible as one progresses to Four Crosses. Sight of it will not be lost until the walker drops down off Llanymynech Hill. This degradation for such a long period of walking is not what one would expect for a National Trail’. (Item 4)  ‘Similarly the effects upon Powis Castle gardens (with some of the highest visitor figures in Wales) are described as Moderate (and Major during construction) by the developers. There is a presumption that the ‘camouflage’ effect will be effective in reducing the impact of the building. In practice such effects are never that successful and the 'camouflage' is likely to give the impression of a gigantic vertical yard on a ridge. In many views it will be seen against the sky so the 'camouflage' is likely to make it even more visible’. (Item 5) 5.5.2. B&A Response: Items 1, 3, 4 and 5 are addressed in turn in so far as they concern landscape and visual matters.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters Item 1: Impacts on The A458 for Road Users 5.5.3. B&A Response: Please refer to the response to Trewern Community Council above. In addition, the Design & Access Statement (February 2021) describes the design process including choice of cladding colours and massing of built form etc. which influenced the Development. 5.5.4. With regards to mitigation measures incorporated into the architectural design of the Development, the following of note:

 ‘With regards to the landform and landuse of the Site. The ERF is set on a north-east to south-west configuration and situated in the quarry void in the central environs of the Site;  In terms of the wider landscape setting, the ERF is generally seen within a landform background, thus, with predominant land colour and hues. The scale of ERF building is appropriate and in balance with the large scale nature of the landscape;  The proposed stack is bicolour to mitigate skyline views where available;  Particular care has been given to consider potential views of the rooflines at the skyline. The main ERF building features a graduated roofline to avoid a boxy appearance;  The proposed cladding colour scheme is designed to merge and not contrast with the landscape. In addition, it intended to be regressive into views and not form a focus;  The ERF is well hidden from the environs of Trewern. Where it is seen from more elevated locations, it is only the upper part of the ERF building and stack that is visible and is appropriate in scale. The Site is at some distance from other settlement areas such as Welshpool; and  Careful consideration has been given to known sensitive receptors including views from cultural heritage sites such as Powis Castle and Garden together with views along key tourist routes into Wales. Such factors have influenced the siting of proposed built form and landscape proposals incorporated into the Landscape Masterplan’. (LVIA, paragraph 4.2.10) Item 3: Landscape Impacts on Trewern and Key Assets - Offa’s Dyke Path, the Severn Way and the Montgomeryshire Canal

Landscape Impact on Trewern 5.5.5. CPRW Montgomeryshire refer to the landscape impacts on Trewern but do not specify what this is based on. The following is a review of indirect effects on landscape character from the LVIA. 5.5.6. Reference to Figure L3: LANDMAP Visual and Sensory Aspect Areas (within 10km) of the LVIA shows that Trewern is located in the MNTGMVS370 Crewgreen to Forden Hill and Scarp Visual and Sensory Aspect Area.

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 5.5.7. The LVIA concluded that ‘Indirect effects will be limited overall due to the current context of the Site, the nature of the Development and incorporated mitigation measures’. The LVIA recorded a Medium magnitude of impact and a Moderate (neutral) significance of effect in all Phases at close range. Long term beneficial effects may occur due to proposed native woodland planting as it matures resulting in a Minor (beneficial) significance of effect. (LVIA, paragraph 5.4.4)

Key Assets - Offa’s Dyke Path, the Severn Way and the Montgomeryshire Canal 5.5.8. Under Strategic Policy SP7 Safeguarding of Strategic Resources and Assets of the Adopted Powys Local Development Plan 2011 – 2026 (April 2018), National Trails, the Public Rights of Way network and Recreational Trails are recognised as Recreational Assets. 5.5.9. The supporting text states ‘To safeguard strategic resources and assets in the County, development proposals must not have an unacceptable adverse impact on the resource or asset and its operation’. (B&A underline) 5.5.10. The LVIA considered views from the general public footpath network and along the Offa's Dyke Path National Trail and the Severn Way long distance footpath including close to the Montgomery Canal. Consideration was also given to walkers (i.e. general recreation routes). 5.5.11. Viewpoint Location 22 From A458 at Buttington Bridge is explored in more detail separately under Item 4. The LVIA recorded a Moderate to Major (adverse) significance of effect during all Phases. For the other Viewpoint Locations, the same result was noted at Viewpoint Location 20 From A483 at During Construction (worst case scenario). In the case of other Phases for Viewpoint Location 20 and all Phases for Viewpoint Location 21 and 32 (Offa’s Dyke Path National Trail) and Viewpoint Location 30 (Severn Way long distance footpath) the results were below, with magnitude of impact between Negligible to Very Small. This does not suggest an unacceptable adverse impact overall and would comply with Strategic Policy SP7. 5.5.12. The results from the Viewpoint Locations are summarised in the table below.

Table 3: Summary of Results from the Offa’s Dyke Path National Trail and Severn Way Long Distance Footpath

PHASE MAGNITUDE OF IMPACT SIGNIFICANCE OF EFFECT

Offa’s Dyke Path National Trail users (High sensitivity) Viewpoint Location 20 From A483 at Pool Quay, 1.8km north-west (close range) Small (generally) and Medium (worst Moderate to Major (adverse) significance of During Construction case scenario) effect (worst case scenario) During Operation Small Moderate (neutral) During Small Moderate (adverse) Decommissioning Viewpoint Location 21 From A483 near Pool Quay at Abbey, 1.8km north-west (close range)

During Construction Negligible Negligible (adverse)

During Operation Very Small Minor (neutral)

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Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters

PHASE MAGNITUDE OF IMPACT SIGNIFICANCE OF EFFECT

During Negligible Negligible (adverse) Decommissioning Viewpoint Location 22 From A458 at Buttington Bridge, 2.4km south-west (close range)

During Construction Medium to Large Moderate to Major (adverse)

During Operation Medium Moderate to Major (adverse)

During Medium Moderate to Major (adverse) Decommissioning

Viewpoint Location 32 From Quarry Lane and Offa's Dyke Path, Nantmawr, 14.6km north (long range)

Negligible (generally) and Very Minor (neutral) significance of effect (worst During Construction Small (worst case scenario) case scenario)

During Operation Negligible Negligible (neutral)

During Negligible (generally) and Very Minor (neutral) (worst case scenario) Decommissioning Small (worst case scenario)

Severn Way Long Distance Footpath users (Medium sensitivity) Viewpoint Location 30 From the Severn Way, east of Trederwen Severn, 6.3km north-east (long range)

Negligible (generally) and Very During Construction Minor (neutral) (worst case scenario) Small (worst case scenario)

During Operation Negligible Negligible (neutral)

During Negligible (generally) and Very Minor (neutral) (worst case Decommissioning Small (worst case scenario) scenario)

5.5.13. In their letter to The Planning Inspectorate (dated 20 May 2021), The Canal & Rivers Trust in Wales comments on the Montgomery Canal and mitigation measures incorporated into the Development. 5.5.14. ‘The Trust own and manage the Montgomery Canal which is located approximately 1km to the west of the application site. A railway line, River Severn, agricultural fields, woodland and both the A458 and A483 are sited on the intervening land. The submitted viewpoints within the landscape and visual impact assessment demonstrate that notwithstanding the height of the structures the proposed mitigation would assist with reducing the visual harm from the canal corridor. Therefore, based on the submitted details our substantive response as a specialist consultee as required by the article 23 of the Development of National Significance (Procedure) (Wales) Order 2016 is that we have no comment to make’. Item 4: Offa’s Dyke Path 5.5.15. The wider route of the Offa's Dyke Path is examined in Item 3 and this response concentrates on Viewpoint Location 22 From A458 at Buttington Bridge. 5.5.16. CPRW Montgomeryshire refer to the ZTV in the LVIA and the assessment of Viewpoint Location 22 for Offa's Dyke Path National Trail users (High sensitivity) which is c.2.4km south-west (close range).

Bright & Associates Page BT1180, August 2021 83

Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 5.5.17. The LVIA recorded a Medium to Large magnitude of impact During Construction and a Medium magnitude of impact During Operation and Decommissioning. A Moderate to Major (adverse) significance of effect occurred during all Phases. 5.5.18. It is important to note that the ZTV is founded on landform and key areas of existing woodland beyond the site boundary, digitised from Ordnance Survey data and therefore, it may suggest a wider area than exists in reality. In line with the GLVIA Third Edition, the ZTV is used as a broad assessment tool that then allows a more detailed level of evaluation for visual impact assessment and an evaluation of landscape character effects. (LVIA, Appendix 1, paragraph 1.6.2) Therefore, it would be wrong to deduce from the ZTV what definitely would or would not be visible from a section of the route and the time period that this would occur etc. 5.5.19. CPRW Montgomeryshire extrapolate that the assessment at Viewpoint Location 22 also applies elsewhere on the route but mistakenly state that the LVIA assessment is Major as opposed to Moderate to Major (adverse) as explained. This inference is therefore incorrect ‘As stated in the LVIA, the effect at this viewpoint is Major for sensitive receptors so the total effect over this time will be highly significant’. 5.5.20. Having reviewed the route of the Offa's Dyke Path National Trail descending Longmountain to Viewpoint Location 22 near Buttington Bridge, Figure L6: Zone of Theoretical Visibility (ZTV) indicates that views of the Development will not be likely until reaching the vicinity of coniferous woodland at Cwm Dingle. There is an expectation of the stack being in view rather than the upper elevations of the ERF building for the rest of the route until close to the environs of Buttington as the Trail user progresses closer to the Site. Again, this is based on the computer analysis and the information available from LVIA Figure L6. The ZTV does not suggest ‘that the incinerator will be very prominent in the walker's view with the visibility for the whole of that time being similar to that shown in Viewpoint 22’ which is noted by CPRW Montgomeryshire. Item 5: Powis Castle and Gardens 5.5.21. Following the requests made by the National Trust, B&A has assessed further Viewpoint Locations at Powis Castle in more detail (see Section 2 of this report). B&A stand by the choice of Viewpoint Location and assessment in the LVIA which is supported by the results. 5.5.22. With regards to other matters raised by CPRW under Item 5. The word ‘camouflage’ was not used in the ES and seems to originate in the Design Review Report (July 2020) issued by DCW. It was noted in relation to the design approach for the form and appearance of the ERF building at the time (Design Review Report, pages 4 and 6). The design process is fully explained in the Design & Access Statement (February 2021). As noted previously, as part of mitigation measures, ‘The proposed cladding colour scheme is designed to merge and not contrast with the landscape. In addition, it intended to be regressive into views and not form a focus’ (LVIA, paragraph 4.2.10)

Bright & Associates Page BT1180, August 2021 84

Broad Energy (Wales) Limited Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys, Response Regarding Landscape and Visual Matters 5.5.23. Reference to the results of the LVIA demonstrates that the majority of views assessed will be seen against a backdrop of higher ground rather than at the skyline. In part, this is due to the siting of the Development within a quarry void and also the wider landscape setting of the Site which includes rising ground. As part of mitigation measures, the proposed stack is bicolour to mitigate skyline views.

Bright & Associates Page BT1180, August 2021 85

FIGURE LIST

FIGURE NO. TITLE

Photograph PC1 From Castle East Front Porch, Existing View (Panoramic view) Figure L1 (July 21) (BT1180-D18v1) Photograph PC1 From Castle East Front Porch, Existing View (Single photograph) Figure L2 (July 21) (BT1180-D18v1) Photograph PC2 From the End of the East Terrace, Existing View (Panoramic view) Figure L3 (July 21) (BT1180-D19v1) Photograph PC2 From the End of the East Terrace, Existing View (Single Figure L4 (July 21) photograph) (BT1180-D19v1) Photograph PC3 From the Bowling Green Terrace, Existing View (Panoramic view) Figure L5 (July 21) (BT1180-D20v1) Photograph PC3 From the Bowling Green Terrace, Existing View (Single Figure L6 (July 21) photograph) (BT1180-D20v1) Photograph PC3 From the Bowling Green Terrace, Photomontage view (Single Figure L7 (July 21) photograph) (BT1180-D20v1) Photograph PC4 From East Facing Windows within the Castle, Existing View Figure L8 (July 21) (Single photograph) (BT1180-D21v1) Photograph PC5 From East Facing Windows within the Castle, Existing View Figure L9 (July 21) (Single photograph) (BT1180-D21v1) Photograph PC5 From East Facing Windows within the Castle, Photomontage view Figure L10 (July 21) (Single photograph) (BT1180-D21v1)

Site location hidden behind foreground tree

Photograph PC1: From Castle East Front Porch

6.4km to the south west from the ERF. The photograph location is from the steps at the East Front Porch of Powys Castle (National Trust)

Panoramic photographs are presented for illustration and general reference to the accompanying LVIA text. They are not a replacement for observation on site. Detailed single frame photographs accompany the panoramic photographs.

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC1 landscape and environmental consultants Figure L1 Cad Ref: Proposed Energy Recovery Facility (ERF) Existing view on Oswestry Shropshire SY10 8DP (July 2021) ight-associates.co.uk Registered Practice BT1180-D18v1 (Panoramic view) Site location hidden behind foreground tree

Sheet (paper) size: A3 Image size: 390x260 at 100% enlargement in relation to FFS Presented field of view: 39.6 x 27 Camera model: Canon EOS 5D Mark IV with fixed 50mm lens and FFS Date of photograph: 21 July 2021 Location of photograph: 321604,306470 Camera height c.147.0mAOD Tripod use: No

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC1 landscape and environmental consultants Figure L2 Cad Ref: Proposed Energy Recovery Facility (ERF) Existing view Pear Tree House Dovaston Oswestry Shropshire SY10 8DP (July 2021) www.bright-associates.co.uk Registered Practice BT1180-D18v1 (Single photograph) Site location hidden behind foreground tree

Photograph PC2: From End of East Terrace

6.4km to the south west from the ERF. The photograph location is from the end of the East Terrace from the path in front of the sundial at Powys Castle (National Trust)

Panoramic photographs are presented for illustration and general reference to the accompanying LVIA text. They are not a replacement for observation on site. Detailed single frame photographs accompany the panoramic photographs.

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC2 landscape and environmental consultants Figure L3 Cad Ref: Proposed Energy Recovery Facility (ERF) Existing view Pear Tree House Dovaston Oswestry Shropshire SY10 8DP (July 2021) www.bright-associates.co.uk Registered Practice BT1180-D19v1 (Panoramic view) Site location hidden behind foreground tree

Sheet (paper) size: A3 Image size: 390x260 at 100% enlargement in relation to FFS Presented field of view: 39.6 x 27 Camera model: Canon EOS 5D Mark IV with fixed 50mm lens and FFS Date of photograph: 21 July 2021 Location of photograph: 321640,306502 Camera height c.147.0mAOD Tripod use: No

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC2 landscape and environmental consultants Figure L4 Cad Ref: Proposed Energy Recovery Facility (ERF) Existing view Pear Tree House Dovaston Oswestry Shropshire SY10 8DP (July 2021) -associates.co.uk Registered Practice BT1180-D19v1 (Single photograph) Site location

Photograph PC3: From the Bowling Green Terrace

6.4km to the south west from the ERF. The photograph location is from the Bowling Green Terrace which is north of the steps leading to the East Front Porch at Powys Castle (National Trust)

Panoramic photographs are presented for illustration and general reference to the accompanying LVIA text. They are not a replacement for observation on site. Detailed single frame photographs accompany the panoramic photographs.

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC3 Figure L5 Cad Ref: Proposed Energy Recovery Facility (ERF) Existing view BT1180-D20v1 (Panoramic view) (July 2021) Site location

Sheet (paper) size: A3 Image size: 390x260 at 100% enlargement in relation to FFS Presented field of view: 39.6 x 27 Camera model: Canon EOS 5D Mark IV with fixed 50mm lens and FFS Date of photograph: 21 July 2021 Location of photograph: 321614,306506 Camera height c.143.0mAOD Tripod use: No

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC3 landscape and environmental consultants Figure L6 Cad Ref: Proposed Energy Recovery Facility (ERF) Existing view BT1180-D20v1 (Single photograph) (July 2021) Proposed ERF building and stack illustrated with maximum plume length

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC3 landscape and environmental consultants Figure L7 Cad Ref: Proposed Energy Recovery Facility (ERF) Photomontage view try Shropshire SY10 8DP (July 2021) iates.co.uk Registered Practice BT1180-D20v1 (Single photograph) Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC4 landscape and environmental consultants Figure L8 Cad Ref: Proposed Energy Recovery Facility (ERF) Existing view ston Oswestry Shropshire SY10 8DP (July 2021) rig Registered Practice BT1180-D21v1 (Single photograph) Site location

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC5 landscape and environmental consultants Figure L9 Cad Ref: Proposed Energy Recovery Facility (ERF) Existing view vaston Oswestry Shropshire SY10 8DP (July 2021) ww.bright-associates.co.uk Registered Practice BT1180-D21v1 (Single photograph) Proposed ERF building and stack (with maximum plume illustrated)

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Photograph PC5 landscape and environmental consultants Figure L10 Cad Ref: Proposed Energy Recovery Facility (ERF) Photomontage view Dovaston Oswestry Shropshire SY10 8DP (July 2021) www.bright-associates.co.uk Registered Practice BT1180-D21v1 (Single photograph)

APPENDIX 14 SHEET 2

Viewpoint 24, View of proposed ERF building together with illustrated likely maximum visible plume length

Proposed ERF building and stack with maximum plume illustrated

Client: Project: Title: Date: Drawing: bright & associates July 2021 BUTTINGTON QUARRY Viewpoint 24 landscape and environmental consultants Cad Ref: Proposed Energy Recovery Facility (ERF) View of proposed ERF building together Appendix 14 Pear Tree House Dovaston Oswestry Shropshire SY10 8DP with illustrated likely maximum visible .bright-associates.co.uk BT1180-D17v2 Sheet 2 Registered Practice plume length A Registered Practice of the Landscape Institute

APPENDIX 2 Technical Note on Noise

ECL Ref: ECL.001.01.02/RFI August 2021 Issue: Final

56a Leabrooks Road Somercotes Derbyshire Environmental Compliance Ltd DE55 4HB Unit G1 The Willowford Main Avenue Treforest Ind Est Pontypridd Date: 28th July 2021 CF37 5BF

FAO: Sarah Burley Our Ref: R21.0705/DRK

Ref: Technical Note – Application for an Energy Recovery Facility at Buttington Quarry, Welshpool, Powys, SY21 8SZ. PINS Reference: DNS/3214813 Powys County Council Reference: 21/0773/DNS

Response to Local Impact Report for Powys County Council relating to a Development of National Significance (DNS)

We have instructed by ECL acting on behalf of Broad Energy to review the Local Impact Report (LIR) dated 21st May 2021 and provide comment in response in the form of a Technical Note. This has been requested to provide technical support to the DNS application submission to NRW.

Documents Considered

• Powys County Council LIR (21/0773/DNS) dated 21/05/21 • Noise and Vibration Chapter 14 of the Environmental Statement • BS4142:2014 & BS4142:2014+A1:2019 ` • BS8233:2014 • Defra NANR45

Queries Raised & Response

5.100 It is proposed that the construction period working times shall be 0700-1900 hours Monday to Friday, 0700-1200 hours Saturday, with no work on Sundays or Bank Holidays. It is recommended that these times be made a condition of any approval.

R5.100 It is possible that some construction activities would need to be undertaken outside of these hours e.g. delivery of abnormal loads, continuous concrete pours. However, HGV movements would not be permitted outside the hours outlined above without prior agreement from the local planning authority.

Issue: Final

Consideration of these activities should be taken into account in order for the ability of the site to carry out critical construction works, for example, a typical condition may include the following additional wording: “No construction works will take place on Sundays or Public Holidays, with the exception of ‘construction activities using the concrete slip-forming method’; ‘construction activities requiring constant pouring concrete’; and process works within the site boundary relating to mechanical and / or electrical equipment installation. Intrusive work outside of these hours would be subject to prior agreement with the Local Planning Authority, except in the case of any emergency, and delivery of abnormal loads by reasons of instruction / order from local police or the relevant highways authority.”

Additionally, during the internal fit out and commissioning of the ERF, works would be undertaken 24 hours a day, seven days a week. Fit out and commissioning works outside the hours stipulated above would only be undertaken within the main building and when all of the external cladding, roofing and doors are in place, thus mitigating potential amenity effects on nearby residential receptors.”

5.101 The noise assessment in the Environmental Statement predicts that any noise experienced at noise-sensitive receptors (NSRs) as a result of construction activities will not exceed the BS5228 guidance value of LAeq 65 dB. By way of planning condition it is recommend that an agreed noise monitoring programme be conducted at NSRs (Noise Sensitive Receptors) and that where limits are breached work should cease until a plan of corrective measures is put in place. This approach would rely less on complaints being received to prompt reactive or corrective measures.

R5.101 The noise limits, noise monitoring programme and complaints procedure etc would form part of a Construction Noise and Vibration Management Plan (CNVMP) as part of an overall Construction and Environmental Management Plan (CEMP). A suitable condition requiring submission of this would cover this requirement.

5.102 The other proposals for mitigation of construction phase work and traffic noise should be finalised and agreed in the Construction Environmental Management Plan (CEMP). By way of planning condition it is recommended that prior to the commencement of construction, a CEMP shall be submitted in inwriting to the Local Planning Authority for written approval and shall be implemented as approved throughout the construction phases of the project. The approved plan/scheme shall include a monitoring/mitigation and management plan for dust, noise and vibration for the construction phases of the development.

R5.102 As indicate above the CMVMP would form part of a CEMP to comply with the control of noise.

5.103 It is proposed that operational delivery times shall be 0700-1900 hours Monday to Friday, and 0700-1200 on Saturday. It is recommended that these times be made a condition of any approval.

R5.103 Consideration of the scenario of `except in the case of any emergency, and delivery of abnormal loads by reasons of instruction / order from local police or the relevant highways authority’ should form part of any conditional requirement.

Issue: Final

5.104 Due to very quiet background sound levels at night, it was agreed that an absolute limit of LAeq (1hr) 30 dB at NSRs would be appropriate, as this complies with all standards for sleep disturbance. For daytime levels, the agreed limit was LAeq (1hr) 4 dB above background.

R5.104 To clarify, sleep disturbance criteria according to WHO would be 40dB LAeq,8hrs and according to BS8233:2014 internal noise levels should be 30dB LAeq,8hrs and the Standard advises at Annex G.1 that a partially open window attenuation would be approximately 15dB. This would equate to an external window level of 45dB LAeq,8hrs. An external level of 30dB LAeq,1hr would therefore be very robust to protect against sleep disturbance (i.e. 15dB lower than required). In terms of the above limits for daytime, this should be determined by the established representative background sound levels, as provided in the ES baseline study.

5.105 The noise assessment follows the BS4142 methodology insofar as it predicts rating levels for the development, which can be compared to background levels. However, it does not include any penalties for noise characteristics because it claims that these will all be eliminated by design. Predicted noise levels from the development have been assumed based on library data from similar plants around the UK. It is known that certain components of plant, such as turbines, generators, fans among others, have the potential to generate low frequency tonal noise. Given the prevailing very low background sound levels at NSRs overnight, the potential for disturbance from low frequency tonal noise is of particular concern. This is because low frequency tones can be very annoying and have the potential to disturb sleep even at low absolute decibel levels.

R5.105 It is important to refer to Technical Appendix TA14-7. This sets out the consultation comments and response to queries raised by Powys County Council EHO. The detailed design of an ERF is a continuous process of optimisation and refinement, reflecting established and emerging best practice.

The key point of our response, which is provided below for ease of reference, states: e) Consideration of any noise character that would be relevant to the proposed development is covered under the provisions of BS4142:2014+A1:2019. It is the writer’s experience of assessing ERF development that noise character can, and is, controlled by the application of appropriate noise mitigation measures. These can include for example, enclosing specific plant, plant selection by imposition of purchasing specifications, silencers on stack and ventilation openings and vents. The application of a suitably worded planning condition would ensure noise character is included in the assessment of noise and as stated in TA14-7, the use of the word `rating’ level in accordance with BS4142:2014 (or latest version in 2019) includes for the application of character penalties. For example: “Daytime at residential receptors: Rating level not exceeding 4dB(A) above the representative background sound levels (LA90) as a 1-hour LAeq as assessed in accordance with BS4142: 2014. Night-time residential receptors: Not exceeding 30dB LAeq15mins or a rating level not exceeding 4dB(A) above the representative background sound levels (LA90) whichever is higher [rating level as a 15-minute LAeq as assessed in accordance with BS4142: 2014]. [Note: Residential receptors and the representative background sound level at NSRs are as established in the ES Noise & Vibration Chapter 14]”

Issue: Final

In terms of tonal low frequency noise, this is covered by the above proposed condition. In terms of low frequency noise (i.e. one-third octave band centre frequencies between 10Hz to 160Hz), as stated in TA14-7 paragraph 2.3 h): “In terms of dealing with low frequency noise concerns, there is no specific legislative guidance on this aspect of noise. BS4142: 2019 refers to the use of NANR45 at section 1.3, page 2. To cover this, it has already been proposed to the EHO, that the use of a noise condition relating to the DEFRA NANR45 guidelines for low frequency noise could be introduced. This would be presented prior to commencement of operations and agreed in writing with the LPA.”

Note: NANR45 refers to low frequency noise limits when measured within a sensitive room rather than externally. This can be difficult to undertake in practice, where properties are occupied and therefore this may need to be proven by measurement and calculation.

5.106 As the assessment is provisional due to the fact that there is still much uncertainty relating to the details of the development. Further acoustic assessments need to be undertaken to ensure that significant noise sources not yet known, are considered, assessed and attenuated through design. This information has not been provided in support of the application and is a material planning consideration especially given the rural application site and quiet nature of its surroundings. If this application is to be approved, one way of ensuring that agreed noise limits are achieved would be to attach a condition to any approval which requires a post beneficial use noise survey to be completed in order to demonstrate that agreed standards have been achieved. This recognises the findings of the assessment and the vital need for further acoustic verification assessment. Such a condition would allow the developer to work closely with the acoustic consultant to refine the design and mitigation in order to achieve the agreed standards.

R5.106 As stated in TA14-7 and provided for ease of reference: 2.1 The development of an ERF involves the interaction of a significant number of plant equipment, operating independently and in conjunction with different parts of the overall facility. Much of the plant operates within different plant buildings and in some cases within enclosures within the main buildings. Other plant may be located external to buildings or ventilated to outside. This means that there will be several hundred pieces of equipment generating noise, the finer details of which need to be considered, when the plant has permission to be built. 2.2 As is normally the case, reasonable assumptions are made in respect of the expectations of the levels of noise generated within specific building areas and from any external plant. This information is based on many years of experience and empirical data obtained of typical plant from Technology Providers (TP) and the writer’s own experience in dealing with many similar sites that have already been designed in detail and operating in the UK. 2.3 f)..Whilst the site design is provided in detail, following a planning submission approval, the developer would need to finalise a contractual agreement with HZI in order for them to refine the detailed design and comply with the planning noise conditional limits and the Environmental Permit conditions to ensure compliance with BAT. At this point the available Technology would be considered, and the finer details of design established that would ensure compliance with planning and permitting requirements in terms of noise. This is an industry standard and best practice approach.

Issue: Final

It is normal practice, with this type of development that a noise compliance monitoring scheme is submitted to show that the agreed noise limits defined in a specific noise condition have been achieved. The scheme would be submitted and approved in writing by the Local Planning Authority, prior to commissioning of the Development. The scheme would define the maximum permissible levels, the location of measurements and the method of noise measurement.

5.107 Prior to beneficial use a noise assessment shall be submitted to and approved in writing by the Local Planning Authority that demonstrates that the cumulative noise from plant and vehicles achieves a rating noise level of less than 4 db above background (LA90) during the daytime and less than LAeq (1hr) 30 dB at night at the nearest noise sensitive receptors outlined in the Environmental Noise Assessment, when measured and corrected in accordance with BS4142:2014 +A1 2019 (or any British Standard amending or superseding that standard).

R5.107 Refer to R5.105 for proposed noise condition. The reference to a noise assessment is covered in TA14-7 at paragraph 3.14, which is provided below for ease of reference: 3.14 The use of appropriately worded conditions would provide a means of ensuring all noise character is controlled. The following, in conjunction with the noise limits set out in 2.3.h) is suggested: “Prior to any commencement of work on site, an updated Noise Assessment Report including details of proposed mitigation shall be submitted to and approved in writing by this Planning Authority to show compliance with noise limits provided in condition XXX. Thereafter the approved plan and mitigation shall be implemented in full before the site becomes operational and shall be retained for the lifetime of the development. For the avoidance of doubt the report shall also include tonal analysis and low frequency noise assessment, along with any recommended mitigation measures where required.”

5.108 In addition to the above it is also recommended that a condition is also imposed to ensure that no tonal noise element will be emitted from the facility during night time operations (2300-0700 hours) as measured by the methodology set out within BS7445.

R5.108 Any concerns over tonal noise character is covered in the proposed noise condition which includes the word `rating’ level as defined in R5.105.

5.109 Policy W2 – Waste Management Proposals of the LDP states that developments will be permitted where there would be no adverse impact on amenity, human health or the environment by way of noise. Policy DM 13 criterion 11 also notes that the amenities enjoyed by the occupants or users of nearby properties shall not be unacceptably affected by levels of noise. The submission however, fails to adequately prove that there will no adverse impacts associated with Vibration and Noise from the proposal: Negative

R5.109 As detailed in the Noise & Vibration Chapter and additional explanations in TA14-7 combined with the proposed noise conditions and clarifications provided above, the submission clearly shows that no adverse impacts would occur and a negative assumption is completely unwarranted. Through the discharge of conditions and the subsequent Environmental Permit process, this would be proven.

Issue: Final

We hope the above provides sufficient information in respect of the impacts and conclusions of the review of additional vehicles.

Yours sincerely,

D R Kettlewell MSc MIOA MAE I.Eng Managing Director Principal Acoustic Consultant

Issue: Final

APPENDIX 3 Technical Note on Geotechnical

ECL Ref: ECL.001.01.02/RFI August 2021 Issue: Final BMS-CF-025

RH/14880/LIR

Ruth Howells 30 July 2021

ECL

For the attention of Sarah Burley

Dear Sarah

BUTTINGTON QUARRY: LOCAL IMPACT REPORT

I confirm that I have studied the Local Impact Report comments and respond as follows:

5.111 Terra Firma (Wales) Limited previously provided a response to geotechnical concerns raised in Letter GCL/14880/Stability, dated 24th November 2020 (presented as Technical Appendix 13-3 of the EIA. It is not clear if this correspondence has been received and reviewed, or whether there remain outstanding concerns following review. If there are further concerns not raised in the other comments covered in the LIR response then could these please be specified.

5.112 The placement of thick areas of fill in the northern site area and Laydown Area 4 as well as on the scree slopes was not considered in Terra Firma (Wales) Limited slope stability report, as proposals for this area had not be confirmed at the time the investigation was undertaken.

We would advise that in order to clarify whether the intended slopes in the north of the site and Laydown Area 4 will be stable, further intrusive investigative works and assessment will be required, to include number of rotary cored boreholes and geotechnical testing.

For the filling on current scree slopes additional sampling and geotechnical testing of scree material should be carried out and an earthworks methodology and compaction specification determined. In the LIR Powys County Council provide a suggested condition which it is agreed can be undertaken prior to the commencement of development.

Please note that any detailed design and methodologies and drawings relating to the actual earthworks and slope stabilisation will fall under the remit of the EPC contractor.

5.113 The slope stability analysis has informed that a proposed gradient of 60o on the eastern cut slope will maintain long term stability providing the correct stabilisation measures are employed as recommended in the Terra Firma Slope Stability Assessment Report (Report Ref 14880/SS).

Accommodating a 60o slope significantly reduces the area and volume of material that would need to be excavated out, processed and re-used on site as engineered fill. By corollary, by reducing the volume of fill materials created for re-location, this option will minimise the loss of

land allocated for potential further development. It was an important consideration that as the wider quarry area has been zoned for industrial use, and due to the fact that the ERF will be CHP ready, the maximum amount of land was left available for future site uses which would be able to take advantage of the heat off take.

5.114 & 5.115 The disposal, reuse and management of waste materials does not fall within Terra Firma’s remit. However. it should be noted that the management of waste materials is included within the Construction and Environmental Management which is included as Technical Appendix 4-3.

5.116 This is covered in 5.112.

Yours sincerely for: Terra Firma (Wales) Ltd

Ruth Howells

APPENDIX 4 Critical review of BIIG responses to dispersion modelling report

ECL Ref: ECL.001.01.02/RFI August 2021 Issue: Final

Cambridge Environmental Research

Consultants

Critical review of BIIG responses to dispersion modelling report

Final Report

Prepared for Environmental Compliance Limited (ECL)

2nd August 2021

C E R C

Report Information

CERC Job Number: FM1334

Job Title: Critical review of BIIG responses to dispersion modelling report

Prepared for: Environmental Compliance Limited (ECL)

Report Status: Final

Report Reference: FM1334/R2/2021

Issue Date: 2nd August 2021

Author(s): Catheryn Price

Reviewer(s): David Carruthers, Charlotte Aves

Date Comments

1 02/08/2021 Final report

1 Introduction

Cambridge Environmental Research Consultants Ltd (CERC) were instructed by Environmental Compliance Limited (ECL) to carry out a critical review of selected points of concern within chapter 6 of a Buttington Incinerator Impact Group (BIIG) document, produced in response to the Air dispersion modelling assessment of releases from the energy recovery centre at Buttington quarry report produced by ECL and Broad Energy.

In addition, a high level review of the dispersion modelling report by ECL and Broad Energy was also carried out.

This report outlines the findings of this review. CERC’s responses to the BIIG points of concern are given in Section 3, and the findings of the review of the ECL and Broad Energy dispersion modelling report are briefly described in Section 4. Excerpts from an Environment Agency permitting decision document for a similar development are provided in Appendix A.

3

2 Executive Summary

Cambridge Environmental Research Consultants Ltd (CERC) were instructed to carry out a critical review of selected points of concern within chapter 6 of a Buttington Incinerator Impact Group (BIIG) document, produced in response to the Air dispersion modelling assessment of releases from the energy recovery centre at Buttington quarry report produced by ECL and Broad Energy.

The relevant numbered points of concern at the start of chapter 6 of the BIIG report were considered, specifically points 1 to 4, and 7.

The main areas of concern raised in the BIIG chapter were the complex terrain of the area, and the possibility of channelling and impinging of plumes, and cold drainage effects.

A summary of the main responses to the issues raised in chapter 6 of the BIIG report is as follows:

• ADMS includes effects of stratification (i.e. stable layer/inversions), buildings and complex terrain on airflow and turbulence, and hence dispersion and deposition. • The complex terrain has been taken into account in the modelling, mainly through - model runs including the use of local Numerical Weather Prediction (NWP) data as input to the model - the use of the complex terrain module in ADMS • The NWP data includes the effects of terrain features on scales of 1.5km or greater, and the ADMS terrain module models smaller-scale effects • The complex terrain module of ADMS has been extensively validated • The modelled stack is likely to have a high effective stack height due to its height, temperature and exit velocity, so the effects of cold wind drainage effects are not considered to be important in this case • Plume grounding and high plume concentrations tend to be mutually exclusive. If the plume doesn't disperse, it will not ground, and if it does disperse and reach the ground it will be well diluted. • In response to the concern that “AERMOD indicates that the plume will regularly ground on the valley sides”, it is noted that AERMOD treatment of plume impaction in complex terrain is very poor, and the validation and inputs to the ‘Plume Plotter’ tool are unknown; so the material presented for the Plume Plotter tool/AERMOD should be discounted as it is not reliable evidence.

The findings of the high level review of the ECL and Broad Energy dispersion modelling report are that the approach to the general application of ADMS, and the associated assumptions and methodology are considered to be appropriate and robust.

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3 Responses to issues raised in chapter 6 of BIIG report

Here the relevant numbered points of concern at the start of chapter 6 of the BIIG report are considered, specifically points 1 to 4, and 7.

The text from the BIIG report points of concern is given in italics.

3.1 BIIG point of concern 1

3.1.1 Main point in summary

“The advice in 2015 from Powys County Council Planning was that a development would be extremely difficult to justify at this location. The landscape has not changed. The complex relief of this area makes it an unsuitable location for an incinerator.”

The complex terrain of the local area has been taken into account by ECL in the dispersion modelling in ADMS. The effects of complex terrain have been taken into account by the model, most notably through:

• the use of the complex terrain module in ADMS, • model runs including the use of local Numerical Weather Prediction (NWP) data as input to the model

The complex terrain module in ADMS uses CERC's FLOWSTAR, to calculate how the mean airflow and turbulence and hence dispersion and pollutant concentrations are changed over complex terrain.

The model predicts a three-dimensional flow and turbulence field over the region of interest, dependent on input values for the spatial variation of both the terrain height and surface roughness, as well as the local meteorological conditions, including the effect of stable stratification and inversions.

The complex terrain module of ADMS has been extensively validated using standard datasets incorporating terrain effects. The validation documents can be found on the CERC website: http://www.cerc.co.uk/environmental-software/model-validation.html.

The NWP data includes the effects of terrain features on scales of 1.5km or greater; this incudes localised deflection, or ‘channelling’ along the Severn valley. It will also account for larger scale cold drainage flows, should they occur.

Further details of the local terrain and its treatment in the dispersion modelling and input data are discussed in subsequent parts of this document.

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3.1.2 Further detail

“There is potential for local downwash. This has been observed with bonfire smoke on the incline sloping to the north, away from the quarry defile.”

A plume from a high stack has completely different behaviour from a bonfire smoke plume from near ground level so this is not relevant.

“On a larger scale, the Pwll Trewern valley itself channels winds/plumes which, as described, impinge on land surfaces”

This is not the case for this particular plume; the hills would need to be higher for this to occur. This is discussed further below.

3.2 BIIG point of concern 2

“Cold air can accumulate to a great depth due to the unique glacial geomorphology of the area. This compromises dispersal of pollution. This may not have been taken account of in the modelling. We observe the accumulation of cold layer to a depth which will overwhelm the flue.”.

This appears to be essentially the same argument given under point of concern 4. See response under point 4.

3.3 BIIG point of concern 3

3.3.1 Main point in summary

“The flue cannot disperse pollution in the way it is intended. Pollution will be concentrated in the Trewern /Middletown area due to grounding of the plume. This is due to the relief and the associated microclimate.”

As described above, the complex terrain has been taken into account in the dispersion modelling by ECL.

The valley is almost aligned with the prevailing, approximately south-westerly, wind; this can be seen clearly in Figures 15 and 16 of the ECL report. Therefore, the main effect of the valley on the large-scale wind field, for most of the year, will tend to be a slight localised deflection, or ‘channelling’ of the wind. This deflection can be clearly seen in the wind roses in Figure 6 of the ECL report; the most frequent wind direction for the measurements at Shawbury is around 250° (approximately WSW), and the most frequent wind direction for the local NWP data is around 210 ° (approximately SSW/SW).

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This channelling effect would have been taken into account in the ADMS modelling by the use of the NWP data and by the complex terrain module. The FLOWSTAR module in ADMS acts to modify the wind field in accordance with the local topography, and adapt the dispersion of the plume accordingly.

“Incinerator plumes are observed to move sideways and the plume will impact the hillslopes where people live”

Although it is true that plumes will eventually travel in the general direction of the local wind field, for high temperature, high momentum releases such as this there will be some initial vertical motion as soon as the flue gases are emitted, due to plume rise from the inherent momentum and thermal buoyancy of the release itself. The height of the plume after the initial plume rise has been taken into account is commonly known as the effective stack height. The ECL report states that the height of the stack is proposed to be 70 m, with an exit temperature of 135 °C and an exit velocity of 19 m/s, giving the potential for a high effective stack height.

For elevated sources with a high potential effective stack height, such as this one, it tends not to be the most stable conditions (e.g. those occurring at night, during low temperatures) that cause the highest ground-level concentrations. This is because these conditions are not conducive to plume grounding; there is no effective mechanism for the plume to be brought rapidly downwards.

For those conditions that are conducive to plume grounding, such as highly convective conditions (occurring during sunny daytime conditions), and neutral conditions with high winds, there will be high levels of atmospheric turbulence; this acts to mix air in to the plume so that it will be tend to be well-diluted before it reaches the ground.

In summary, plume grounding and high plume concentrations tend to be mutually exclusive. If the plume does not disperse, it will not ground, and if it does disperse and reach the ground it will be well diluted.

In addition, for most weather conditions, the wind is deflected by terrain, and will generally flow over and or/around an obstacle, not impact directly on it. An exception is during particular stable conditions; ADMS includes plume impaction onto hill sides in stable flows should it occur.

“Pollution mapping by AERMOD indicates that the plume will regularly ground on the valley sides. Thus actual pollution values could well be higher than the calculations provided by BE/ECL”

AERMOD treatment of plume impaction in complex terrain is very poor, so the material presented using AERMOD should be discounted as it is not reliable evidence. For more details, see Carruthers et al (2011).1

1 Carruthers, D., Seaton, M., McHugh, C., Sheng, X., Solazzo, E. and Vanvyve, E. (2011) Comparison of the complex terrain algorithms incorporated into two commonly used local-scale air pollution dispersion models (ADMS and AERMOD) using a hybrid model. Journal of the Air and Waste Management Association, 61, 11, 1227-1235

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Research by ul Haq, et al., comparing outputs from AERMOD with tracer measurements in complex terrain, found that “AERMOD overestimated the concentration at receptors which were at the point of direct impaction of plume and ridge”.2

Furthermore, a later section of the BIIG report implies that the pollution mapping referred to above used AERMOD only in the sense that it was used within the ‘Plume plotter’ tool. Comments from the Environment Agency regarding the plume plotter for another application, given in Appendix A below, are also relevant here: “there is no information on the website as to how the model was validated and we have not seen the model input parameters, and so cannot comment on the validity of the predictions.”

3.4 BIIG point of concern 4

3.4.1 Main point in summary

“Polluted air grounding on the hill sides drains back into Pwll Trewern. This recirculation of polluted air, from cold air drainage, may not have been taken into account in the modelling. It is a frequently observed hazard which already causes pollution problems.”

The stability of the atmosphere near the ground plays an important role in hilly terrain. The effects of stable conditions and complex terrain are accounted for in ADMS. The FLOWSTAR model within ADMS has specific algorithms to calculate these effects

Cold air drainage winds are not explicitly represented in ADMS, so their treatment is limited; but this is not important here. The recirculation of polluted air due to cold air drainage effects could possibly occur for low level sources, but not for this case of an elevated stack with a high effective stack height. The plume is too high above ground level for this to be important.

In the UK, the number of instances of these meteorological conditions is low. They are associated with cool temperatures and low wind speed conditions.

Responses from the Environment Agency regarding another application, in Keighley, West Yorkshire are given in Appendix A below, regarding dispersion modelling carried out using ADMS. In response to concerns about low lying cloud in the valley, they state: “We checked the effect of the valley and local weather conditions when we audited the Applicant’s modelling. Our conclusion was that the Applicant’s modelling represented a reasonable worst case”

For context, the terrain local to the Keighley site is similar to the Buttington quarry area, with a slightly narrower, slightly more enclosed valley. The valley floor close to the Buttington site is approximately 2000 m wide; the equivalent distance is approximately 1000 m at Keighley site. The slope of the valley sides at Buttington site is around 10 – 15%; the equivalent slope at the Keighley site is around 10 – 20%.

2 Ul Haq, A., Nadeem, Q., Farooq, A., Irfan, N., Ahmad, M. Ali, M (2019) Assessment of AERMOD modeling system for application in complex terrain in Pakistan. Atmospheric Pollution Research, 10, 1492–1497

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3.4.2 Further detail

“In the study at Cwm Felin Fach [4] the KLAM_21 model (which takes temperature inversions into account in valley regions) showed that emissions came close to the short-term limits under temperature inversions. That landscape was of lower relief and less extreme than our locality.”

The landscape of the Cwmfelinfach site is not in a landscape of lower relief and is more extreme than the Buttington landscape.

The valley floor close to the stack at the Buttington site is approximately 2000 m wide; the equivalent distance is approximately 500 m at the Cwmfelinfach site. The slope of the valley sides at the Buttington site is around 10 – 15%; the equivalent slope at the Cwmfelinfach site is around 35 – 50%.

The Cwmfelinfach is in a more complex location, and a much narrower valley, so that study is of limited (if any) relevance here.

3.5 BIIG point of concern 7

“This complex landscape will amplify the collection and damage caused by these pollutants downwind from the plume which cannot freely disperse.”

This seems to be essentially a repeat of arguments made in previous points of concern (see above for responses).

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4 Review of ECL and Broad Energy report

This section comprises a review of the ECL and Broad Energy report.3

Although it has not been possible to thoroughly check the inputs and details of the assumptions made in the ECL and Broad Energy dispersion modelling report in the time available, a high level review has been carried out of the general approach and methodology taken. Particular focus is on those parameters and assumptions that relate to the BIIG points of concern addressed in Section 3 above.

Meteorological data and parameters

Two different types of meteorological data were used in the modelling: Measured (observed) data from the Shawbury site, and Numerical Weather Prediction (NWP) data with a resolution of 1.5km.

Comprehensive sensitivity tests were carried out using different approaches, including the use of the NWP data with the additional sensible heat flux and boundary layer depth parameters omitted, to allow the ADMS meteorological pre-processor to calculate the boundary layer parameters; other runs were also carried out, in which ADMS uses all of the available NWP parameters, including the additional ones. This allows for a transparent and detailed assessment of the resulting range of model outputs and hence impacts.

The justification of the use of this data is fully explained in the report, including personal communication and references to the NWP User Guide.

The values used for the surface albedo, Priestley-Taylor and minimum Monin-Obukhov length parameters are all appropriate for the area. Of particular importance is that the minimum Monin-Obukhov length parameter is set to the value for a rural area, which enables all stable conditions to be considered by the model.

Complex terrain and surface roughness

The report describes the very comprehensive approach to the use of terrain data, including grid resolution sensitivity tests and an update of the terrain data to reflect the proposed changes to the landscape of the site. The resolution of the terrain data is clearly visible in the figures provided, and the terrain resolution used in ADMS is clearly stated.

The surface roughness length values used for the modelling appears to be appropriate for both the dispersion area (0.3 m) and the Shawbury site (0.2). Tests for a range of alternative surface roughness length values were carried out, which gives useful information on the sensitivity of the modelled impacts to this parameter.

3 ECL and Broad Energy. Air Dispersion Modelling Assessment of Releases from the Energy Recovery Centre at Buttington Quarry. ECL Ref: ECL.001.01.02/ADM. November 2020.

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Buildings

The input building parameters are clearly presented, and the location and layout of modelled buildings with respect to the stack are clearly visible in the figures provided.

The stack height assessment carried out as part of this dispersion modelling assessment effectively acts as an assessment of the influence of the site buildings on the stack emissions.

Source parameters

There is limited scope for reviewing the stack parameters in the absence of underlying information. It is of note, however, that the stack parameters are conducive to substantial initial plume rise and hence a high effective stack height, with a relatively high temperature, exit velocity and proposed stack height (70 m).

Model output grid and receptors

The modelled output grid seems appropriate, both in extent (4 km x 4 km) and resolution (10 m). Specified points were also used for specific sensitive receptors.

Summary

In summary, the approach to the general application of ADMS, and the associated assumptions and methodology are considered to be appropriate and robust.

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Appendix A:

This appendix provides excerpts from the Environment Agency (EA) Determination of an Application for an Environmental Permit document for Endless Energy Limited.4

The document concerns an installation at Airedale Road, Keighley, West Yorkshire. BD21 4LW. The site was treated as a waste incineration plant for the permit application, and lies in an area of relatively complex terrain.

The applicant used ADMS 5 to carry out the dispersion modelling for the permit application. The permit application was accepted and the permit was granted.

The following sections reproduce key relevant text of the decision document.

A.1 EA general points

Page 37 of the Permit decision document states: “During the consultation on the Applicant we received a lot of responses expressing concern over local weather conditions including temperature inversions in the Aire valley and whether this would trap emissions leading to increased impacts.

We carried out checks during our audit of the Applicant’s dispersion modelling that included: • Using our own weather data from Bingley, on site numerical weather prediction data and modelled weather date (MM5) • Considering Defra background maps alongside local data • Using high resolution terrain data • Testing sensitivity to surface roughness • Using multiple dispersion models including the Calpuff model As a result of our audit we were satisfied that the Applicant’s predictions represented a reasonable worst case and could be used for permit determination. We are still satisfied that there will not be a significant impact on air quality or health when taking into account local weather conditions and the location in the valley.”

Page 125 of the of the Permit decision document states “Many responses were submitted showing photographs and video footage of low lying cloud in the valley.

We checked the effect of the valley and local weather conditions when we audited the Applicant’s modelling. Our conclusion was that the Applicant’s modelling represented a reasonable worst case.”

Page 148 of the of the Permit decision document states: “We received many responses to our minded to consultation expressing concern about whether we had adequately considered local weather conditions including temperature inversions in the Aire valley and whether this would trap emissions leading to increased impacts. This is an issue that we have looked at in detail. Our expert modelling team (AQMAU) used several methods of checking this as set out in

4https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/94 2409/Decision_Document_-_ZP3537AT.pdf

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section 5.2.4 of this decision document. In summary our view is that air quality impacts will not be higher than those predicted by the Applicant’s modelling. We considered these comments in detail and we are still satisfied that impacts will not be higher than those predicted by the Applicant.”

A.1 EA responses to specific issues

Page 118 Issue raised: “KLAM_21 should have been used to assess the impact of temperature inversions.”

Response by the EA: “KLAM_21 is a method of assessing cold air drainage that can occur during inversions. We considered temperature inversions in our audit as discussed in section 5.2.4. We are satisfied that no further modelling work is required.”

Page 153 Issue raised: “Bingley is not appropriate weather data. Bingley weather station is set above the valley. This means that temperature inversions and conditions where cloud is trapped in the valley has not been considered.”

Response by the EA : “Bingley weather station is approximately 6 km south of the proposed facility at a greater altitude than the stack. The meteorological conditions observed at Bingley are considered to be reasonably representative. However, due to the topographical differences at both locations there could be localised differences in the meteorology. We conducted modelling checks using our own 5 years of Bingley data, and NWP (numerical weather prediction) and MM5 (fifth generation NCAR/Penn State Mesoscale Model) data extracted for the location of the proposed facility to account for localised differences on predicted concentrations.

Temperature inversions typically occur on clear nights with calm winds. They develop during the night and typically break up a few hours after sunrise. Valley inversions are a certain type of temperature inversion that can form in mountain valleys. They can last for days, but only in certain valleys, under specific meteorological conditions. The Applicant’s ADMS model considered the impact under stable condition type temperature inversions. However, in order to account for valley type inversions and their effect on predicted concentrations, we conducted modelling checks using ADMS and alternative modelling software AERMOD and CALPUFF (non-steady-state model) with several meteorological data sets.

Our audit used meteorological data sets that are likely to be representative of the local area for dispersion modelling purposes, and we used alternative dispersion models that have the capability to model more complex meteorological conditions such as the temperature inversion/low lying cloud that people have reported and sent us photographs of Issue raised by Representations from Community and Other Organisations

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Our audit showed that even when taking valley type inversions into account, impacts would be no higher than those shown in the Applicant’s dispersion modelling.”

Page 126 Issue raised: “Concern over the impacts as shown on the Plume Plotter website."

Response of EA: “Plume Plotter appears to be a tool which uses air quality modelling software to predict the ground level concentrations of nitrogen oxides and other pollutants that may arise from the incinerator based on a number of factors.

The information on the website indicates that the results may be based on expected modelling methods. However, there is no information on the website as to how the model was validated and we have not seen the model input parameters, and so cannot comment on the validity of the predictions. We have audited the dispersion modelling submitted with this Application and we are satisfied that there will not be any significant impacts.”

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APPENDIX 5 Written Statement on Economic Issues Raised

ECL Ref: ECL.001.01.02/RFI August 2021 Issue: Final Written Statement Author: Dr Bryony Turner Date: 28th July 2021 Response to Economic Objection (BIIG)

PROJECT NAME: Proposed Buttington Energy Recovery Facility Written Statement on Economic Issues Raised

An email was issued on the 13th July 2021 stating that progress for the Buttington Application would be via hearings with the Planning Inspectorate (PINS). Dr Bryony Turner completed the socio- economic chapter (chapter 7) during 2020 and an objection has been received from Buttington Incinerator Impact Group (BIIG) that includes objection based on economic concerns.

This Written Statement is a response to the objection by BIIG and has been prepared to provide a reference point for economic matters during the Hearing process should it be required.

Socio-Economic Assessment Chapter Content

We thank BIIG for their concerns raised in their response, we understand the introduction of a waste facility can cause concerns to those that reside and operate businesses in proximity to the proposed location. The socio-economic chapter that was prepared was designed to address the areas where there could be significant socio-economic concerns:

 Employment generation: direct and indirect;  Supply chain impact: on a local and national basis;  Recreation access: residential properties and traffic issues, Public Rights of Way (“PRoW”) and recreation activities;  Landscape and visual effect: the effect of landscape and visual impact from a socio-economic perspective; and  Tourism: visitors to the area that may stay or visit areas within proximity to the proposed ERF.

These were endorsed by the scoping direction issued by PINS. Part of the BIIG objection has been to question the credentials of Dr Bryony Turner and experience in such matters to be able to make professional judgements regarding the assessment work; therefore, included below is a brief summary of Bryony’s relevant experience.

Dr Bryony Turner, Waste and Socio-Economic Credentials

Bryony began work on socio-economic matters in 1999 when undertaking a Doctorate whilst working for Shell UK. This was at a time when the Brent Spar Incident had recently occurred, and Shell were keen to ensure socio-economic issues were captured within business decision making (the subject of Bryony’s thesis). Bryony’s academic qualifications included a Bachelor of Science in Environmental Biology and a Masters in Environmental Impact Assessment and she concluded her Doctorate in 2004. Her experience in Shell included socio-economic and stakeholder engagement processes for major LNG facilities (Sakhalin, Nigeria and the UK). Completion of the Doctorate coincided with a change in employment to become the Minerals, Waste and Contaminated Land Officer for the North West Regional Assembly (NWRA) where she provided secretariat for the Regional Technical Advisory Body on Waste (RTAB). This began her involvement specifically on waste issues that continued through a consultancy-based career that began in 2006.

She has worked for environmental consultancies Parsons Brinckerhoff and Enviros (who underwent various takeovers whilst Bryony was employed) and her main responsibility was socio-economic assessments, carbon footprints and life cycle assessment. Her work included the socio-economic assessment for the Four Ashes energy from waste facility (application by Staffordshire County

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Written Statement Author: Dr Bryony Turner Date: 28th July 2021 Response to Economic Objection (BIIG)

Council), socio-economic assessment of the Llanwern facility (South Wales) applied for by Veolia and site selection and assessment of the North Wales energy from waste plant (now in Deeside). She has also been involved with National Grid socio-economic assessments on the Mid Wales Connection (did not proceed) and North Wales connection. More recently Bryony has completed the socio-economic assessment of the North Shropshire electricity connection (from Oswestry to Wem). Bryony has also provided planning and socio-economic assessment support associated with a number of waste procurement activities in terms of completing assessment and appraising those of waste companies. This includes appraisal of the socio-economic work undertaken for the Shrewsbury Battlefield facility.

Since 2016 Bryony has been Director of a micro-consultancy, Filkin & Co EHS Limited, based in Wem, Shropshire and has completed a number of waste related projects including waste strategy work in Falkland Islands, Kenya, NHS (Birmingham) and environmental support for a range of waste- related business operating in the UK.

Bryony has an extensive range of experience in waste and socio-economic assessment matters and has lived in North Shropshire for the past 15 years.

Response to BIIG Objection

The BIIG objection includes reference to other chapters within the Environmental Statement and we direct you to those chapters / statements for greater consideration of the objections raised:  The Alternatives assessment, Technical Appendix 3-2 of the EIA, Alternative Sites Assessment  Waste need statement, Waste Planning Statement, Carter Jonas Report Ref: J0036928Butt, April 2021, Issue 2 (revised from the original submission – attached for ref).  Landscape / visual statement (I assume there will be no change on potential impact on tourism locations but will need to know asap if there is), Technical Appendix 9-1 of the EIA, Landscape and Visual Impact Assessment.  Reference to transport statement, Technical Appendix 8-1 of the EIA, Transport Impact Assessment.  Air quality statement, Technical Appendix 6-1 of the EIA, Air Quality Assessment, and Technical Appendix 6-2 of the EIA, Air Quality Assessment of Road Emissions.  Health statement. Technical Appendix 15-1 of the EIA, Comprehensive Health Impact Assessment.

More specifically, these references are in answer to:  TAN 23 2.1.5, Alternatives: Any response to the Alternative assessment will need to be referenced in the socio-economic response (Alternative Site Assessment)  Response on Powys LDP 2011-26 and land use requirement with provision of waste need for the region (will need to refer to need text and capacity calculations for proposed facility) (Waste Planning Statement)  Response on tourism: This will need to reflect findings for the landscape / visual assessment (particularly Powis Castle as a viewpoint) (Landscape and Visual Impact Assessment)  “Speed” Welshpool business and affect on their location and movement of delivery vehicles caused by the proposed development (reference to transport chapter) (Transport Impact Assessment)  “Special Merit” reference to need for waste arising (Waste Planning Statement)  Response on TAN21 will need to reference air quality response and landscape responses plus health impact assessment response (Air Quality Assessment and Health Impact Assessment)

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Written Statement Author: Dr Bryony Turner Date: 28th July 2021 Response to Economic Objection (BIIG)

“Speed” Welshpool Location The BIIG objection refers to “Speed” Welshpool, the following marked up map shows the extent of the “Speed” location in relation to the proposed facility.

Figure 1: Speed Location in relation to Proposed ERF

As a delivery company, we would conclude that its operation from a socio-economic perspective would not be affected by the proposed ERF (for example, it is not a tourism business that is reliant on landscape or visual matters). We would suggest the transport chapter / response is referred to for any potential impact on their business area of vehicle movements.

Job Creation A number of jobs will be provided by the construction and operation of the proposed facility; information has been received from HZI (26th July 2021) to confirm that the construction peak on site would be around 600-700 (collectively from HZI, sub-contractors and equipment suppliers) with an average of approximately 309 construction workers (as given in the original socio-economic chapter). HZI confirm that the peak requirement for construction workers would occur taking into account peak holiday season to ensure accommodation is available for use to minimize disruption to providers and maximise local spend during low season periods.

Once operational, the site will employ approximately 35 permanent staff, running the facility on a shift pattern to allow 24 hour operation. At any one time there will be at least 4 operational staff on duty and the majority of staff will work normal day shifts with a maintenance team working irregular shifts to cover planned and unscheduled maintenance. The breakdown of employees (Full Time Equivalent,

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Written Statement Author: Dr Bryony Turner Date: 28th July 2021 Response to Economic Objection (BIIG)

FTE) can be indicated as follows (this breakdown is based on professional experience following establishment of facilities but has been confirmed as representative by HZI):  Facility Manager 1 FTE  Operations Manager 1 FTE  Maintenance Manager 1 FTE  Administration 1 FTE  HSE Manager 1 FTE  Weighbridge Clerk 2 FTE  Shift Leaders/Supervisors 6 FTE  Facility Operatives (shifts) 16 FTE  Maintenance 4 FTE  Bottom Ash 2 FTE

The economic value included in the chapter was based on a more conservative estimate of 30 employees. Based on average earning for Powys of £507.70 per week based on 46 weeks of working (to account for holiday and closures) per year this would equate to approximately £700,600. HZI have confirmed a number closer to 35 FTE that would equate to approximately £817,000. As mentioned in the chapter the need for technical specialists means that this may not be restricted to the LSA (Local Study Area).

TAN 23 2.1.5 “Economic Development” The BIIG objection has highlighted that TAN 23 2.1.5 states: “2.1.5 Where a planning authority is considering a site allocation or planning application that could cause harm to the environment or social cohesion, it should ask three questions in order to help clarity and balance the economic, social and environmental issues. These questions should be used to assist the normal planning decision making processes. In all cases robust evidence should be provided to support these tests: Alternatives Jobs Accommodated and; Special Merit” [text has been summarised]

We understand that waste facilities are a controversial application type but would stress that the planning application is not expected to harm the social cohesion of the area (largely due to the location of the development in an existing quarry). Information on Alternatives were included in Technical Appendix 3-2 of the environmental statement. In terms of jobs accommodated we have provided (thanks to HZI) further explanation of the likely jobs and peak numbers within this Written Statement. In terms of “Special Merit” this is where a development would make any special contribution to policy objectives. This would be dealt with by the Planning Statement and has not been covered in the socio-economic assessment.

Stakeholder Contact Preparation of the socio-economic assessment has been completed by Dr Bryony Turner, she was not involved with the stakeholder process for the application itself. The stakeholder consultation programme has been external to the socio-economic assessment and so adequacy of the stakeholder consultation is not addressed by the author of the socio-economic chapter (this includes the query regarding location of workforce response provided as part of pre-application consultation explained on page 46 and supply chain job creation on page 48 of the objection). Questions regarding the approach and findings associated with the formal stakeholder engagement programme for the

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Written Statement Author: Dr Bryony Turner Date: 28th July 2021 Response to Economic Objection (BIIG) application can be found in the Pre-application consultation report, prepared by secNewgate and submitted with the application.

In terms of stakeholder concern, for the socio-economic chapter as well as checking there were no significant issues raised by the formal stakeholder engagement programme, Bryony did also attempt contact with a number of key organisations / individuals, these were:  Shropshire Rights of Way Officer (contacted by email 22/04/2020); and  Powys Rights of Way Officer (contacted by email 22/04/2020).

What follows is a summary of the information issued:

I am working on a socio-economic assessment as part of an environmental impact assessment for a proposed waste facility in Powys. As part of the socio-economic assessment we will be taking into account potential impact on rights of way. The Shropshire rights of way are not in close proximity but are included within the 5km local study zone for the socio-economic assessment (blue line marks local zone limits on the following image). The site is located at SY21 8SZ we have identified the Shropshire rights of way as included below (screen grab from Google Earth using data from Shropshire Council available at: https://www.shropshire.gov.uk/outdoor-partnerships/countryside- access-and-public-rights-of-way/the-definitive-map/#):

Shropshire Rights of Way Powys and Shropshire Rights of Way

I include the Shropshire and Powys rights of way in case that assists (Powys data taken from Open Government Licence at: https://data.gov.uk/dataset/6b7de0f2-1370-4b52-82b8-97665b936d84/public- rights-of-way).

I was wondering if you would be so kind as to look at the Shropshire rights of way and highlight any access concerns regarding the proposed site. Are you aware of any visitor counts for any of the rights of way?

General email addresses were used for the contact (O k and to try to accommodate for the fact that there could be limited accessibility during the Covid19 pandemic (so emails were not addressed to any one individual). A response was received from Powys (23 April 2020) that stated:

“Thank you for your enquiry which has been passed to Sian Barnes, Acting Professional Lead - Countryside Access & Recreation and Calum Carr, Rights of Way and Access Officer, for attention.

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Written Statement Author: Dr Bryony Turner Date: 28th July 2021 Response to Economic Objection (BIIG)

Please be aware that in view of the current COVID 19 outbreak, Powys County Council has invoked business continuity plans for services to concentrate on social care activities and critical business activities. The action was authorised by the council’s strategic group and means that non-critical activity will be stepped down to support social care and critical frontline services in response to the Coronavirus outbreak.

Because of that, the Countryside Services and Outdoor Recreation team currently has very limited capacity to respond to countryside access enquiries. We will give priority to reports of hazards that pose immediate and high health and safety risks, for example, damaged footbridges, but may not be able to reply to other enquiries at the moment.”

The chapter was finalised and submitted in February 2021 (10 months later) and no more responses had been received by that date.

Local Study Area (LSA) The Local Study Area (LSA) has been defined as the location of the planning application with a buffer of approximately 5km around the boundary. This includes areas of Powys and Shropshire administrative boundaries, but the Shropshire areas were sufficient distance that they did not include any viewpoints or sensitive receptors. The use of Super-Output areas (SOAs) is to allow the collection of baseline data at a level that allows for use of census material. The selection of the SOAs for the socio-economic assessment were identified to include the application location (because any potential sensitive receptors are more likely to be in proximity to the proposed development) and the extent was confirmed with the landscape and noise assessment teams to ensure it included any potential viewpoints where sensitive socio-economic receptors may occur.

We note that BIIG have identified urban areas of Welshpool as being most affected by the development, we maintain that the location of the proposed development would be the area most affected.

Eco-Park We note that the BIIG objection has stated that there has been insufficient information provided on the “Eco-Park”. We have not included reference to this in the socio-economic assessment because we agree with BIIG that any claims would be difficult to justify; we are concentrating on the application itself for the proposed facility. The “Eco-Park” would be subject to separate planning applications, the content of which are unknown at this time and would also be outside the control of the applicant. However, we recognise that this may cause a concern to local residents and an indication of the type of businesses that may be developed in proximity to the facility would be beneficial. However, there are no definite parameters on this, when considering facilities of this nature in a similar locality we can use examples such as Battlefield, Veolia’s plant near Shrewsbury. Once it had been built a range of eating establishments and recreation facilities (Climbing the Walls) were developed in close proximity. However, this location is on the outskirts of a major conurbation, Shrewsbury, so potentially not likely to be applicable to the Buttington example. The Four Ashes development in Staffordshire (which the author also has experience of from planning to development) was also placed in a rural area (but with some industrial buildings in the surrounds) industrial uses have developed around the site since the introduction of the facility with food, automotive and waste related businesses. HZI have been involved with other “Eco-Park” developments associated with proposed waste facilities and the types of businesses that have been located on the sites are within the circular economy arena.

6

Written Statement Author: Dr Bryony Turner Date: 28th July 2021 Response to Economic Objection (BIIG)

Conclusion

The socio-economic chapter for Buttington Energy Recovery Facility explored a number of issues that have been re-visited for the purposes of this Written Statement. The construction and operational job numbers have increased with additional information provided by HZI. Emphasis has been placed on identifying the key socio-economic issues that have the potential for significant impact and the assertion that there will be no significant negative effects that require mitigation is maintained. We note that concerns have been raised by BIIG that are related to economic issues and understand their perspective, the introduction of a waste facility is often of a concern to local residents the assessment has focused on those areas where there could be a potential significant impact but through assessment and information provided by other key chapters (landscape, transport etc), we conclude there to be no likelihood of significant negative socio-economic impact.

7

APPENDIX 6 Response Regarding Heritage Matters

ECL Ref: ECL.001.01.02/RFI August 2021 Issue: Final

Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys

Formal request for further information under Regulation 15(2) of the Developments of National Significance (Wales) Regulations 2016 (as amended) for further information (Reference DNS/3214813)

Response Regarding Heritage Matters

August 2021

Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys

Formal request for further information under Regulation 15(2) of the Developments of National Significance (Wales) Regulations 2016 (as amended) for further information (Reference DNS/3214813)

Response Regarding Heritage Matters

August 2021

© Orion Heritage Ltd 2021

No part of this report is to be copied in any way without prior written consent.

Every effort is made to provide detailed and accurate information, however, Orion Heritage Ltd cannot be held responsible for errors or inaccuracies within 3rd party data supplied to Orion and referred to within this report.

© Ordnance Survey maps reproduced with the sanction of the controller of HM Stationery Office. Licence No: 100056706

1 Report Response Regarding Heritage Matters

Site Proposed Buttington Quarry Energy Recovery Facility, Welshpool, Powys

Clients Broad Energy (Wales) Ltd

Date August 2021

Planning Authority Powys County Council

Site Centred At NGR 326690, 310106

Prepared By Emma Baxter BA MA (Cantab) MSc IHBC

Approved By Dr Rob Smith MCIfA

Report Status FINAL

Orion Ref PN1820

Buttington Quarry, Welshpool August 2021

2 Contents

1.0 Introduction 2.0 Response to National Trust Comments 3.0 Response to BIIG comments

List of Illustrations Figure 1: Designated Heritage Assets within 5km

Buttington Quarry, Welshpool August 2021

3 1.0 Introduction

Preface 1.1 Orion Heritage (Orion) carried out the Heritage Assessment (HA) which assessed the proposed Buttington Quarry Energy Recovery Facility near Welshpool, Powys. The Heritage Assessment formed Chapter 12 and Appendix 12-1 of the Environmental Statement (ES).

1.2 Orion were appointed by ECL (the Agent) on behalf of Broad Energy (Wales) Limited (the Applicant) to undertake the HA.

1.3 The Planning Inspectorate issued a formal request for further information under Regulation 15(2) of the Developments of National Significance (Wales) Regulations 2016 (as amended) for further information (Reference DNS/3214813) to the Applicant on the 12 July 2021.

Structure of the Report

1.4 This report contains the Orion Response to the following matters raised in the formal request:

1.5 1. ‘A response to the objection of the National Trust (REP003) regarding the impact of the proposal on the RHPG and listed buildings at Powis Castle (see also the comments of Cadw). The applicant should cross-refer to the analysis of the impact from Viewpoint 24 in the LVIA and consider if supplementary viewpoints and information should be supplied as suggested by the National Trust’. Comments raised by the National Trust Consultation Response (May 2021) are addressed in Section 2.

1.6 4. ‘Any response that the applicant wishes to make to the objections made by BIIG (and other objectors). Issues raised include matters to be addressed in the Hearings …’ Comments By BIIG regarding Chapter 12: Archaeology and Heritage are addressed in Section 3.

1.7 This response refers to TVIA Appendix 14 Sheet 2: Viewpoint 24, View of proposed ERF building together with illustrated likely maximum visible plume length. This response also refers to the Bright & Associates Response (August 2021) and to the additional viewpoints contained therein, together with further images obtained from Powis Castle on a site visit undertaken by the author of this response on 29th July 2021.

1.8 Reference is made to Technical Appendix 12-1 Heritage Assessment including paragraphs, Appendices and Figures. This is referred to as the HA in this report.

Buttington Quarry, Welshpool August 2021

4 2.0 Response to National Trust Comments

Introduction

2.1 This section addresses the comments raised by the National Trust relating to Powis Castle (May 2021) concerning heritage matters. The relevant paragraph has been extracted (National Trust Comment) with a response by Orion addressing the issues raised.

Long distance views from Powis Castle

Assessment of impact arising from the proposals

2.2 National Trust Comment: Section 12.4.19 of the Environmental Statement (Heritage) states in relation to Powis Castle “the castle and gardens are surrounded by fields and woodland, particularly to the north-east. Far to the north-east lies Welshpool which blocks any intervisibility between the castle and gardens and the Development Site. Consequently, there will be no effect and no further assessment is required”. Photographs taken from the Bowling Green below the East Front terrace, show how the development site is clearly visible to and from Powis Castle.”

2.3 Cadw’s response letter commenting on the point above (dated 2nd July 2021) advised that the heritage impact assessment required updating to reflect the consequence of the visibility of the proposals. As both the HA and ES have been submitted, this response undertakes the impact assessment required by CADW in the paragraphs below.

2.4 In undertaking this assessment, reference is made to Cadw’s Setting of Historic Assets in Wales (2017) which outlines a four stage process to the assessment of impact arising from development within setting of historic assets. It is clearly stated within this document that what matters is to identify how the setting contributes to the significance of the heritage asset concerned, as the significance of the asset is the element which attracts statutory protection.

2.5 Powis Castle is a heritage asset of the highest designation and is valued for its historic and architectural special interest as evidenced in its built fabric through plan form, materials, architectural detailing, decorative schemes, associative links and the historic illustrative importance of the typology.

2.6 The setting of the Castle has a number of elements which contribute to the manner in which it is experienced, and key among these are the ancillary buildings and structures relating to the Castle, many of which are also Grade I listed, and the Grade I Park and Garden within which the assets are located. Reference to the listing detail held by Cadw gives the reasons for designation as follows:

Powis Castle is an outstanding monument which charts a progression from medieval fortress to country house: the extensive survival of the medieval external structure forms the framework for a remarkable series of later interiors, amongst which those of the late C16, and the late C17 are of exceptional importance.

2.7 As detailed within the historical section of the listing, the original fortified structure of the early medieval castle has been remodelled and altered over the centuries, with the emphasis moving away from military might as an expression of power towards the display of wealth and erudition as an alternative manner of displaying power and privilege.

2.8 The Baroque detailing of the house and garden, and the level of intactness of the structures, layout and decorative scheme, form a key element of the significance of the asset, together with the age and evidential potential of the original fortifications.

2.9 Turning to issues of setting and their contribution to significance, the siting and location of the asset was fundamental to the defensive function of the original castle structure, with the availability of wide-ranging views being key to its defence. The proximity of the border to the east and the requirement to have maximum surveillance of this most vulnerable aspect, together with the topography, would have dictated the footprint and orientation of the defensive structure, and this angle of view is of greatest importance to the earliest iteration of the asset.

2.10 With the evolution of the building from fortress to country house, however, views outward to the wider environs became of less import than views toward the assets, through which one

Buttington Quarry, Welshpool August 2021

5 could appreciate their architectural splendour. Such views are manipulated through the variety of approaches to the buildings, and the nature of the planting which controls the character of the views. Given that the reasons for the Castle’s designation relate to the exceptional rarity of the Baroque elements of the assets, both in terms of the house and the garden, then it follows that the designed views associated with this era of the asset’s development should carry more weight.

2.11 Two of the state rooms have views out toward the site, with views in this direction also available from the main terrace and from the southern edge of the bowling green, and associated terrace. In the views from the main terrace, the site is obscured by tree planting, but is visible from the state rooms and the bowling green terrace. In all views the site is experienced in the context of the settlement of Welshpool, and in particular its later expansion in terms of the residential development and industrial buildings to its peripheries. Very little of the historic core of the settlement is experienced in the context of these views, and consequently there is loss of illustrative historic value in terms of historic settlement and the principal contribution made by the wider setting in this area is topographical. This is supported by the National Trust’s comment with reference to the 1901 Country Life article and the comment that the terraces ‘...command surpassingly beautiful views, the most delightful of all being through a long vista of trees to the distant peaks of Moel-y-golfa and the Breidden Hills.’. Reference to historical mapping (online at the National Library of Scotland), however, evidences that Welshpool was considerably less developed at the turn of the twentieth century than it is today, and thus to refer to literature from the earlier date, without reference to intervening changes, is rather misleading in terms of analysing setting contribution.

2.12 In its present state the site is considered to make a neutral contribution to the setting of the asset, with virtually no contribution to the asset’s significance.

2.13 The proposed ERF will be visible within the wider landscape setting but, as demonstrated by the visualisations contained within the LVIA Response at Figures L7 and L10, the form of the development is wholly contained within the surrounding landform massing and does not compete with the topographical character of the hillscape.

2.14 Cadw letter (dated 21 May 2021) to the Planning Inspectorate state that the methodologies for both Chapter 9 and 12 of the EIA were suitable. The LVIA Response gives Cadw’s comments in full at paragraphs 2.2.27 and 2.2.28. The methodology contained within the Orion ES chapter contains the criteria for sensitivity of heritage receptors at table 12-8, the criteria for magnitude of change at table 12-3, and significance of effect and residual effects at tables 12-7 and 12-9. Following the matrices employed in assessment and the conclusions drawn, it is considered that whilst Powis Castle is a receptor of very high sensitivity, the magnitude of change will be negligible and therefore the significance of effect will be minor and not significant in EIA terms. This method of assessment is carried through from the HA, which similarly indicates that a minor effect would be sustained by the asset.

National Trust Additional/Alternative Viewpoints

2.15 National Trust Comment:

2.16 ‘The Conservation Management Plan for Powis Castle and Garden identifies key views from the property including the view from East front towards the development site’

2.17 ‘We would suggest that several additional/alternative viewpoints are required including: the end of the East Terrace adjoining the sculpture, the easterly view from the Bowling Green terrace on the east front and from the lower bowls lawn terrace. Views of the scheme will also be possible from the Castle East Front porch at higher level and also from all floors and roof of the Castle on the East Front’.

2.18 In their response to this comment, B&A undertake a comprehensive analysis of the alternative viewpoints suggested, assessing each in line with the methodology employed for the LVIA, and conclude that the effects arising from the analyses are either the same or of a lower order than those assessed in relation to Viewpoint Location 24 contained within the LVIA, which was considered to be a representative viewpoint, validated by the LPA. Orion concur with the findings of this analysis and consider Viewpoint 24 to be a suitable vehicle to assess the visual and heritage impacts arising from the proposals.

Appeal (Extension to Existing Dairy at Lower Leighton Farm) (APP/T6850/V/12/2168955P)

Buttington Quarry, Welshpool August 2021

6 2.19 National Trust Comment: ‘The importance of the landscape and heritage setting of the terraces at Powis Castle was recognised in the deliberations of the application and Appeal (Extension to Existing Dairy at Lower Leighton Farm) (APP/T6850/V/12/2169855P). Para 208 of the Inspectors decision relates to the setting of Powis Castle “Over 100,000 people would potentially experience this view each year and the fact that this would be a key part of most people’s visits to Powis Castle gardens makes this a highly sensitive location. The assessment of sensitivity made by the applicant’s landscape and heritage witness seems unable to give any weight to the huge numbers of people affected from this viewpoint”.

2.20 As identified in the LVIA response (paragraph 2.2.23) there are a significant number of disparities between the ERF proposal and the Lower Leyton Farm proposal, and that drawing parallels between the two applications is not particularly helpful. It is recognised that Powis Castle is a receptor of very high sensitivity, however the comment by the National Trust appears to suggest that the wider setting of the asset carries as much weight in terms of heritage value as the castle itself or the garden in which it is situated. As demonstrated in the assessment above, the conclusions of which are echoed by the LVIA, the proposals are located on a site which has a lesser contribution to the setting and significance of the Castle than Lower Leyton Farm which, being located to the east, lies within the most sensitive area of the setting in heritage terms.

Buttington Quarry, Welshpool August 2021

7 3.0 Response to the BIIG report

Introduction

3.1 This section addresses the comments raised by the BIIG report concerning heritage matters. The relevant paragraph has been extracted (BIIG Comment) with a response by Orion addressing the issues raised.

Contextual information regarding Trewern 3.2 BIIG comment: We are deeply concerned that Chapter 12 continues to be deficient because of its failure to provide a comprehensive description of the area around the proposed development and misrepresents or omits information about the important role Trewern and the surrounding area has played in Welsh and English history.

3.3 Orion response:

Local Context

3.4 Buttington (Tal-y-Bont) is a village in north Powys. It is around 3km to the northeast of the town of Welshpool. The village of Trewern is around 4 km to the northeast of Buttington. The study site lies between the two villages. Trewern is immediately to the south of the Breidden Hills (Breidden Hill, Moel y Golfa, Cefn y Castell, Kempsters Hill and Bausley Hill), which are sometimes considered the northern extension of Cefn Digoll (‘Long Mountain’). Portions of Offa’s Dyke run close to both villages near the Severn (NPRN 309692).

3.5 Due to its strategic position in the , Buttington has been the site of several notable battles, and has long been a transit hub linking Montgomeryshire to the Midlands.

Fortifications

3.6 The Iron Age Breiddin Hillfort (NPRN 141162) is on the summit of Breidden Hill, to the north of the study site. Surviving stone ramparts enclose around 28 hectares of flat land which likely contained buildings. The site was excavated in 1933-35 and again in 1969-76 (St John O’Neil, 1937; Musson, 1991). Finds indicated that the site was occupied from the 7th century BC to the 4th century AD. The site has been partly destroyed by quarrying and is marked by Rodney’s Pillar (1781) (NPRN 32922). There is also a well and spring known as White Well on Breidden Hill, which appears on Ordnance Survey maps. On the south side of the Breidden Hills is a further enclosed settlement dated to the Roman period, known as New Pieces (NPRN 94037).

3.7 The Breidden Hills are one of the possible sites for the battle fought between the British King Caratacas and the Roman General Ostorius Scapula in AD 50 (RCAHMW 2006). The location of the battle was described by Tacitus as being on steep mountains with a view of the Severn, and Blodwel Rocks at Llanymynech has been suggested as a likely fit (Tacitus, ‘Annals’; Jones & Mattingly, 1990, pp. 66-67). This battle may have been in connection with the Llanymynech Hillfort on the west side of Llanymynech Hill (NPRN 92487). This fort was later incorporated into Offa’s Dyke. It was also mined for copper by the Romans. (Fox & Hemp, 1926).

3.8 There are two further Iron Age fortifications in the vicinity of the Breidden Hills: Beacon Ring Hillfort (or Caer Digoll) on Cefn Digoll (NPRN 306947) and Cefn Y Castell Hillfort above the village of Middletown (NPRN 307135). Beacon Ring is notable for its appearance in the 9th/10th century poetic saga Canu Llywarch Hen (‘The Song of Llywarch the Old’), where it is described as the camp of Prince Cadwallawn. It was reputedly of significance in the Battle of Cefn Digoll in 630, a great conflict between Prince Cadwallawn and King Edwin of Northumbria. The fortification is briefly mentioned several times in the Mabinogion (Williams et al., 1870, p. 97; Powys-Land Club, 1869, Vol II, pp. 356-58). In August 1485, Henry Tudor used Cefn Digoll as a rendezvous point on his march through Wales and the Marches. Here Henry assembled with a large army of supporters from North Wales who contributed to his victory against Richard III at Bosworth Field (Vergil, pp. 216-17; Griffith, 1993). Beacon Ring is currently undergoing a series of excavations by the Clwyd-Powys Archaeological Trust.

3.9 Cefn Y Castell Hillfort consists of an oval enclosure containing the remains of a cairn (NPRN 307136). The site has not been excavated, but according to Cadw, holds strong potential for significant archaeological evidence.

Roman

Buttington Quarry, Welshpool August 2021

8 3.10 The small village of Wroxeter in Shropshire was an important Roman town and fortress from the 1st to the 7th century AD. A Roman road connected Wroxeter with auxiliary forts at Forden Gaer and . Llanymynech Hill is known to have been inhabited and mined for copper by the Romans (Hankinson, 2016). A Roman road passed close to Cefn Digoll and the study site, though its exact path is not known (Margary, 1955, p. 49). Parts of the Roman road certainly followed the valley south-east of Cefn Digoll to Westbury and Forden Gaer, as shown in aerial photography. In 1983, Rigg and Toller argued for the Roman origin of roadways between the Long Mountain and Welshpool, and leading west from Welshpool to Dolgellau (Rigg & Toller, 1983). However, in 1999, Toller recanted this view, as new evidence has shown that these roadways in fact date to the turnpike period - “between the Long Mountain and Welshpool none of the remains described in [the previous article] need be of ancient date” (Toller, 1999, p. 300).

Medieval

3.11 In 894, The Battle of Buttington was fought between a Viking army and a combination of Anglo-Saxons and Welsh. Buttington is the most likely location for this battle, though the specific location of the fortification mentioned in the Anglo-Saxon Chronicle is not known (Ingram, 1937, pp. 72-74). A battle took in the Vale of Severn in 1039, possibly near to Rhyd y Groes and Strata Marcella Abbey (NPRN 403405; Guest, 1888, p. 117-18; Morgan Owen, 1874). Here, Gruffydd ap Llewelyn defeated King Edwin of Mercia.

3.12 Part of a motte-and-bailey castle known as survives in Montgomery (NPRN 306405), around 15km south of the study site. This was the original site of the manor house of Roger of Montgomery, a major Norman landowner who was granted land in Shropshire by William the Conqueror in 1071.

3.13 The Buttington/Trewern area falls into the medieval of Gorddwr within the larger cartref of Ystlyg. Y Gorddwr ostensibly remained part of Powys following the Norman Conquest of England, though it was largely under the control of the Norman Corbet family until the 13th century (Barton, 2002; Spurgeon, 1962).

3.14 In the Domesday Book, Buttington was not mentioned by name. ‘Buttington’ likely derives from the Old English ‘Bota’s settlement’. Trewern was included in the Domesday survey as part of Shropshire: the manor was held by Roger, son of Corbet (Phillimore reference: Shropshire 4,1,8). To the south of Buttington, the small manor of Leighton was held by the same Lord (Phillimore reference: Shropshire 4,4,22).

3.15 On the eastern foothills of Cefn Digoll is Caus Castle, a Norman motte-and-bailey fortification, probably based on an Iron Age hillfort site (NHLE 1020147). The castle was probably built by Roger de Corbet, the lord of the manor of Trewern named in the Domesday Book, in the late 11th century. The Corbets owed fealty to Roger de Montgomery, Earl of Shrewsbury, to defend the Welsh Marches and subdue the Welsh to Norman rule (Sanders, 1960, p. 29). Caus was likely the administrative centre of Corbet’s barony, taking its name from the Pays de Caux area of Normandy, his ancestral home. The castle was demolished in the mid-17th century, and the remaining ruins were appropriated for road-stone in the 18th and early 19th centuries. The present enclosure consists of around 4.7 hectares, containing visible stone ramparts and ditches.

3.16 The ruin of a Norman motte and bailey castle survives at Nantcribba, in Forden, to the south of Welshpool (NPRN 306979). This castle has been identified with Gwyddgrug, the castle mentioned in the Placita Corum Rege in the Michaelmas Term of 1260 (Lloyd, 1873, p. 60; Lloyd, 1876, p. 338). Gwyddrug Castle was built by Thomas Corbet of Caus in 1260 and destroyed just three years later by Gruffydd ap Gwenwynwyn (Calendar of Close Rolls, 1261-64, p. 265). The attribution of Gwyddgrug Castle to the Nantcribba site is likely, but uncertain (Lieberman, 2010, pp. 130-131; Spurgeon, 1962).

3.17 On the western bank of the Severn near the study site is the site of Strata Marcella Abbey, a Cistercian monastery founded in 1170 by Owain Cyfeiliog, Prince of Powys (NPRN 94052). The abbey grew to be the largest Cistercian abbey in Wales. It was partially destroyed during the Owain Glyndwr risings of 1400-5. It ceased to exist at the Dissolution and was fully dismantled. The farmland on the site was excavated in 1890, revealing a plan of the cloister and church.

Early Modern

3.18 Following the fall of Oswestry to Parliamentarian forces in June 1644, a series of offensives across the Marches extended Parliamentarian control towards the Severn valley. An important raid took place at Welshpool in August 1644, contributing to the collapse of the

Buttington Quarry, Welshpool August 2021

9 Royalist hold in Wales (Phillips, 1874, pp. 240-241). Powis Castle (NPRN 29858), to the south of Welshpool, remained an important muster point for Parliamentarian forces for subsequent battles at Newtown and .

3.19 Modern

3.20 Buttington’s position has meant that it has been a key connection on transport links between Montgomeryshire and the Midlands. The road from Welshpool to Shrewsbury was turnpiked in 1758 (Statute, 31 George II, c. 67).

3.21 The Montgomeryshire Turnpike Act was passed in 1768 (Public Act 8 George III, c. 51). Turnpike roads were maintained in the Welshpool region from 1769 (Public Act 9 George III, c. 56). These included the road west from Welshpool to Llanfair and Mallwyd (now the A458), the road south to Montgomery (now the A483) and the main road connecting Buttington with Shrewsbury (now part of the A458). By the 1880s most roads in Montgomeryshire had become ‘disturnpiked’, and their management handed over to local authorities.

3.22 A canal running near the Severn past Welshpool was authorised by a Parliamentary Act in 1794 (Private Act 34 George III, c. 39). The section of the Montgomeryshire Canal passing Welshpool was completed in 1797. It was intended to transport lime for agricultural purposes, serving the Severn Valley. The canal connected Shropshire to the mines at Llanymynech, past Welshpool down to Garthmyl. The final connection to Newtown was completed in 1821 (Priestley, 1831, pp. 455-456).

3.23 The Llandidloes and Newtown railway line opened in 1859. The line was extended to the north the Oswestry, via Welshpool and Buttington, the following year (Baughan, 1980, p. 190). The line from Welshpool to Newtown opened in 1861. Buttington Station was situated at the junction between the Cambrian Rail main line and the Shrewsbury and Welshpool railway, and was therefore an important connection between Montgomeryshire and the Midlands (Wright, 2013, ‘Disused Stations’). The Great Western Railway extended services to Welshpool in 1865, which also ran through Buttington. Welshpool also had 9 miles of Light Railway line connecting it to , which opened in 1903 (Baughan, 1980, p. 185).

Consultation with CADW

3.24 BIIG comment: The Applicant claimed in response to the pre-application consultation to have “consulted with CADW and rigorously followed their guidance, and also the standards and protocols of the Chartered Institute for Archaeologists (CIfA) of which we are a Registered Organisation (RO) when preparing the Heritage Assessment and Heritage ES Chapter. Therefore, an objective assessment of the local area’s archaeological and heritage potential has been undertaken.” The revised Chapter 12 shows no evidence of either rigour or objectivity.

3.25 As previously highlighted in the response to the National Trust, in their letter of 21 May 2021, Cadw confirmed their acceptance of the methodologies employed within Chapter 12 and considered that these were appropriate in terms of assessing heritage matters.

3.26 For heritage assets that do not meet the criteria for statutory designation, but are considered of local importance, Cadw recommend the compilation of a local list of buildings and sites, required to meet agreed and adopted criteria, which then confers non-designated heritage asset status to the building, monument or area and ensures its appropriate consideration within the planning balance. In the absence of such a list for Welshpool, or adopted criteria against which to assess a putative heritage asset, the likelihood of omission of assets of local interest in assessment is increased. The lacunae in the Orion research have been addressed above, but as the BIIG committee note, local knowledge and understanding provide an interpretive layer that is difficult to replicate. This is the reason that the compilation of local lists is recommended in government guidance.

BIIG report section on Planning Policy and Guidance 3.27 It is noted that the BIIG report includes two pieces of legislation within its section on policy and guidance, these being The Well-being of Future Generations (Wales) Act 2015 and Historic Environment (Wales) Act 2016

Buttington Quarry, Welshpool August 2021

10 3.28 Section 35 of the Historic Environment (Wales) Act 2016 relates to duties with regard to Historic Environment Records with subsection 2(e) requiring that details of every conflict site in the authority’s area which the Welsh Ministers consider to be of historic interest are recorded. The HER itself, however, is not a statutory document and, whilst an invaluable tool in understanding the Historic Environment, is, on its own, insufficient in terms of understanding heritage significance.

BIIG report section on Historic Battlefield Sites 3.29 At paragraph 7.2 the statement from Chapter 12 (para 12.3.51) is misinterpreted. Orion’s statement that there are no historic battlefields in the vicinity of the development is made within the context of designated heritage sites, as the second half of the sentence quoted by BIIG illustrates. As previously mentioned, the HER is not a statutory tool and inclusion on it does not confer designation status. The compilation of a local list of heritage sites per Cadw’s guidance is the recommended route for recording the heritage interest of local assets.

Buttington Quarry, Welshpool August 2021

11 Sources

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12 https://www.google.co.uk/books/edition/Collections_Historical_Archaeological_Re/gC8LA AAAYAAJ?hl=en&gbpv=1&dq=rhyd+y+groes+battle&pg=PA163&printsec=frontcover (Accessed 28 July 2021) Musson, C. R; Britnell, W. J; Smith, A. G. (1991). ‘The Breiddin Hillfort: A later prehistoric settlement in the Welsh Marches’. Council for British Archaeology Research Report 76. London: Council for British Archaology, 1991. Archaeology Data Service. Available at: https://archaeologydataservice.ac.uk/archiveDS/archiveDownload?t=arch-281- 1/dissemination/pdf/cba_rr_076.pdf (Accessed 26 July 2021) O’Neil, B. H. St J. (1937). ‘Excavations at Breiddin Hill Camp, Montgomery 1937-39’, Archaeolgica Cambrensis. 92. 1937. Pages 86-128.

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Online Sources Clwyd-Powys Archaeological Trust. Beacon Ring Annual Reports. Available at: https://cpat.org.uk/beacon-ring-annual-reports/#page-content (Accessed 27 July 2021) English Heritage. ‘History of Wroxeter Roman City’. Available at: https://www.english- heritage.org.uk/visit/places/wroxeter-roman-city/history/ (Accessed 27 July 2021) Hankinson, R. (2016). Llanymynech Ogof: Archaeological evaluation 2016. Unpublished report. CPAT Report No. 1407. Coflein. Available at: https://coflein.gov.uk/media/298/69/652254.pdf (Accessed 27 July 2021) Historic England. (2001). Listing for Caus Castle: a small multivallate hillfort, a motte and bailey castle and a medieval borough. Scheduled Monument NHL 1020147. Available at: https://historicengland.org.uk/listing/the-list/list-entry/1020147 (Accessed 27 July 2021) Open Domesday. Entry for Trewern, Hundred of Rewset, Shropshire. Available at: https://opendomesday.org/place/SJ2711/trewern/ (Accessed 27 July 2021) People’s Collection Wales. ‘Welsh Place-names: Tal-y-bont: Buttington’. Available at: https://www.peoplescollection.wales/items/467006 (Accessed 27 July 2021) RCAHMW. Listing for Beacon Ring; Caer Digoll. NPRN 306947. Coflein. Available at: https://coflein.gov.uk/en/site/306947?term=beacon%20ring%20hillfort (Accessed 27 July 2021) RCAHMW. Listing for Cefn-y-castell, Hillfort. NPRN 307135. Coflein. Available at: https://coflein.gov.uk/en/site/307135/ (Accessed 27 July 2021) RCAHMW. Listing for Cefn-y-castell, Cairn. NPRN 307136. Coflein. Available at: https://coflein.gov.uk/en/site/307136/ (Accessed 27 July 2021) RCAHMW. Listing for Nantcribba Castle; caer. NPRN 306979. Coflein. Available at: https://coflein.gov.uk/en/site/306979/ (Accessed 27 July 2021) RCAHMW. Listing for New Pieces Enclosure, Breiddin Hill. NPRN 94037. Coflein. Available at: https://coflein.gov.uk/en/site/94037/ (Accessed 26 July 2021) RCAHMW. Listing for Offa’s Dyke: N of School House at Buttington. NPRN 309689. Coflein. Available at: https://coflein.gov.uk/en/site/309689?term=309689 (Accessed 26 July 2021) RCAHMW. Listing for Breiddin Hillfort. NPRN 141162. Coflein. Available at: https://coflein.gov.uk/en/site/141162/ (Accessed 26 July 2021) RCAHMW. Listing for Strata Marcella Abbey; Ystrad Marchell, Welshpool. NPRN 94052. Coflein. Available at: https://coflein.gov.uk/en/site/94052/ (Accessed 27 July 2021) RCAHMW. Listing for Rhyd-y-groes, Possible Site of Battle, Near Welshpool. NPRN 403405. Coflein. Available at: https://coflein.gov.uk/en/site/403405/ (Accessed 28 July 2021) RCAHMW. Listing for Powis Castle; Powys Castle. NPRN 29858. Coflein. Available at: https://coflein.gov.uk/en/site/29858/ (Accessed 29 July 2021) RCAHMW. Listing for Hen Domen, Montgomery. NPRN 306405. Coflein. Available at: https://coflein.gov.uk/en/site/306405/ (Accessed 29 July 2021)

Buttington Quarry, Welshpool August 2021

15425 15419 $+ 15416 15422 15423 $+ 15412 $+ $+$+$+ 15415 15420 $+ $+$+ 15421 15414 15417 15413 15418 131086

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8701 $+ 7897 7895 $+$+ 7896 $+ 7894 PO39 MG120

7880 15646 $+ $+

PO37

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MG035 LEIGHTON CENTRE MG035

MG286MG286 MG167 MG035 PO34 Leighton Park MG035

MG035 Contains Ordnance Survey data Crown copyright and database right 2014

Legend Site SAM 1:50,000 at A4 $+ Listed Building point Parks and Gardens 0 1,500m Conservation Area

Title: N Fig.1: Designated assets within 5km Address: Buttington Quarry, Welshpool