brechfa forest west Consultation Report

Document Reference BFW/AppDoc12/Consultation

Required document as set out in Section 37(3)(c) of the Planning Act 2008 Produced October 2011- RWE Renewables Ltd Forest West Wind Farm Consultation Report

contents

1. Introduction 1 1.1 Foreword 1 1.2 The Developer 2 1.3 The Proposal 3 1.4 Site location 4 1.5 Role of a Consultation Report 5

2. Section 42 6 2.1 Prescribed persons 6 2.2 Local authorities for the purposes of Section 42(b) 8 2.3 Persons within one or more categories set out in Section 44 9 2.4  Section 44(c) is not relevant to the Brechfa Forest West Wind Farm proposal 10 2.5  Section 42 comments summary table 10 2.6  Summary analysis of Section 42 responses 12 2.7  Detailed responses 13 2.8  Meetings 98 2.9 Section 44 99

3. Section 47 103 3.1 Statement of Consultation 104 3.2 Local Authority’s comments 105 3.3 Community Liaison Group 107 3.4 Visits to local residents 108 3.5 Newsletters 109 3.6 Presentations 110 3.7 Telephone calls 111 3.8 Exhibitions 112 3.9 Documents available for viewing 115 3.10 Feedback forms 116 3.11 Summary of feedback received under Section 47 117 3.12 Feedback forms 123 3.13 RWE NRL response to summary feedback 126 3.14 Letter summaries and responses 140 Brechfa Forest West Wind Farm Consultation Report

contents

4. Section 48 151

5. Section 49 152

6. Conclusions 154

7. Glossary 155

Appendices Appendix A Summary of Section 47 responses 157 Appendix B List of prescribed bodies 186 Appendix C Letter to Section 42 consultees 190 Appendix D Letter to Section 42 consultees 194 Appendix E Reminder letter to Section 42 consultees 196 Appendix F Letter from Hoare Lea Acoustics to County Council 198 Appendix G Meeting minutes– statutory consultees 210 Appendix H Statement of Community Consultation 251 Appendix I Newsletter 1 253 Appendix J Newsletter 2 257 Appendix K Newsletter 3 265 Appendix L Exhibition boards 273 Appendix M Feedback form 297 Appendix N Section 48 notice 307 Brechfa Forest West Wind Farm Consultation Report 1

1. introduction forEward

1.1 ForEward

1.1.1 RWE Npower Renewables Ltd (RWE NRL) is a responsible developer with a long and successful track record of consulting and engaging with local communities during the development phase of wind farm proposals.

1.1.2 The Planning Act 2008 (“The Act”) introduced a new approach and new requirements for promoters to engage in pre-application consultation with local communities, local authorities and those who would be directly affected by their proposals.

1.1.3 These changes have required RWE NRL to build on its previous consultation experience and established company practices to ensure compliance with the Act. In undertaking pre-application consultation for the Brechfa Forest West Wind Farm, RWE NRL has fully embraced the spirit and letter of the pre application consultation requirements of the Act.

1.1.4 Whilst the formal section 47 consultation for this wind farm proposal ran between 10th February 2011 and 6th April 2011, RWE NRL has been in ongoing dialogue with local communities since March 2009.

1.1.5 This report outlines how a variety of approaches have been utilised to engage with the local communities. These approaches have included community liaison groups, newsletters, public exhibitions, one to one meetings, a project website, making documents available for viewing free of charge at local locations, and the provision of designated points of contact for the project.

1.1.6 Section 42 consultation ran to the same deadline (i.e. 6th April 2011) as the Section 47 consultation. Engagement with a number of the prescribed bodies has taken place for some time (both pre and post formal consultation) and has continued throughout the development of the project. This report outlines which bodies were consulted and how this consultation was undertaken.

1.1.7 This report summarises the responses received from both section 42 and section 47 respondees and explains how the comments have been taken into account and, in the event they were not taken in to account, the reasons for this. Brechfa Forest West Wind Farm Consultation Report 2

the developer

1.2 The Developer

1.2.1 RWE NRL, a subsidiary of RWE Innogy, is the leading developer and operator of renewable generation projects in .

1.2.2 RWE NRL operates a wide portfolio of projects in Wales including 7 onshore wind farms, the UK’s first major offshore wind farm at North Hoyle (North Wales), the offshore wind farm and 7 hydroelectric projects in and around the Snowdonia National Park.

1.2.3 RWE NRL is also strongly committed to developing future renewable electricity projects in Wales to meet the growing demand for renewable electricity. The Company has a pipeline of around 600MW of onshore wind farms at different stages of development including the Brechfa Forest Wind Farms (East and West), Clocaenog Forest Wind Farm, and Carnedd Wen Wind Farm and Habitat Restoration Project.

1.2.4 RWE NRL’s operational portfolio in Wales is also set to expand with the construction of the Gwynt y Mor offshore wind farm. The Company has Section 36 determination for this, the Company’s 3rd offshore development off the Welsh coastline. Onshore preparatory works for this project started in 2009 (the civil engineering contractor is Ruthin-based Jones Bros), with project completion anticipated in 2014. The Company is also currently developing the 1500MW project (under the Crown Estates Round 3 development licensing round) located in the Bristol Channel circa 15 km south of the South Wales coast.

1.2.5 RWE NRL is part of RWE Group – one of Europe’s largest companies, with 70,000 employees across Europe. RWE is currently one of the biggest investors in Wales, with around £1bn worth of committed investment and a development pipeline in Wales worth around £7bn.

1.2.6 RWE NRL currently employs more than 75 people in Wales. With its continued investment in projects in Wales, the Company has the potential to create thousands of jobs both directly and indirectly.

1.2.7 More information about RWE NRL can be found at www.npower-renewables. com and site specific details on the Brechfa Forest West Wind Farm can be found at www.npower-renewables.com/brechfaforest. Brechfa Forest West Wind Farm Consultation Report 3

the proposal

1.3 The Proposal

1.3.1 In 2008, RWE NRL was awarded the rights to seek planning permission to develop a wind farm in Brechfa Forest in Carmarthenshire, South West Wales. The woodland is managed by Forestry Commission Wales (FCW) on behalf of the Welsh Government and lies within the administration of Carmarthenshire County Council.

1.3.2 Brechfa Forest is located within one of seven areas (Strategic Search Areas) designated by the Welsh Government for the development of large scale wind farms. These areas were specifically identified as suitable for such development within the Welsh Government’s land use planning guidance Technical Advice Note 8 (TAN8, 2005).

1.3.3 RWE NRL is proposing two wind farms in Brechfa Forest, Brechfa Forest East and Brechfa Forest West. A planning application for Brechfa Forest East Wind Farm was submitted to Carmarthenshire County Council in 2010 for 12 turbines (expected installed capacity 24-36 MW). This application is undetermined at the time of writing (October 2011).

1.3.4 The proposed Brechfa Forest West Wind Farm comprises 28 turbines and will have an installed capacity of 56-84 MW (subject to the capacity of the turbines constructed). In addition to the turbines, the proposal also includes the: – Construction of approximately 9.1km of new onsite access tracks and the upgrading of 12.7km of existing forestry access tracks; – Construction of an onsite substation, hard-standing areas, external transformers, underground connecting cabling and one permanent wind monitoring mast (separate planning permission has already been sought and granted for two temporary met masts which were installed in April 2006 and August 2008 respectively); – Creation of two temporary construction compounds; – Creation and working of one new borrow pit for the extraction of stone for use on site.

1.3.5 Pursuant to sections 14(1)(a) and 15(2) of the 2008 Act, an onshore wind energy electricity generating station in England or Wales having a capacity of more than 50 MW is a Nationally Significant Infrastructure Project (“NSIP”).

1.3.6 Section 31 of the 2008 Act provides that a development consent order is required under that Act for development that is or forms part of a NSIP. Brechfa Forest West Wind Farm Consultation Report 4

site location

1.3.7 As the proposed Brechfa Forest West Wind Farm is an onshore wind energy electricity generating station with a capacity of between 56 and 84MW, it is a NSIP for these purposes and any application for development consent must be made to the Infrastructure Planning Commission (“IPC”) under section 37 of the 2008 Act.

1.3.8 For the avoidance of doubt, this Consultation Report focuses only on the consultation and engagement that took place as part of the development of the Brechfa Forest West Wind Farm.

1.4 Site location

1.4.1 The proposed wind farm site is located within Brechfa Forest, 10km northeast of , Carmarthenshire in South West Wales. The site itself is located on a ridge of land forming the southwestern tail of the Cambrian Mountains. The site lies between the Cothi Valley (located to the southeast) and the Teifi Valley (located to the northwest). The elevation of the site ranges from 260mAOD in the southwest to 358mAOD in the northeast.

1.4.2 Brechfa Forest covers an area of approximately 5,273ha. The land is owned by the Welsh Government and managed by Forestry Commission Wales. It is comprised of plantations of exotic tree species with Sitka spruce being the primary species, although there are some areas of native trees within the Forest. The Forest is divided into two parts by the common land of Mynydd Llanfihangel Rhos y Corn and Mynydd . The Brechfa Forest West Wind Farm site is positioned in the western part of the Forest in an area that lies between the village of Brechfa to the southeast, and the A485, to the northwest. The site is intersected by the Afon Pîb which flows southeast towards Brechfa.

1.4.3 The proposed wind farm site occupies an area of approximately 1041 ha, although the actual development (including all infrastructure components including access tracks, turbine bases, borrow pits, meteorological masts, and temporary and permanent compounds) will only occupy approximately 4.1% of this wider area. The majority of the site is used for upland rotational forestry, although 8% is improved agricultural grassland used for sheep grazing. Brechfa Forest West Wind Farm Consultation Report 5

role of consultation report

1.5 Role of a Consultation Report

1.5.1 The Planning Act 2008 states that the IPC may accept an application only if various criteria outlined in section 55 of the Act are met, this includes (section 55 subsection 3e) that the applicant has complied with the pre-application procedure outlined in Chapter 2 of Part 5.

1.5.2 Section 55 subsection 4 states that in deciding its conclusion on subsection 3e and deciding whether an application should be accepted, the IPC must have regard to various information including the consultation report received under section 37(3c).

1.5.3 Section 37 subsection 7 states that in the context of section 37 (3c) the ‘consultation report’ means a report giving details of: (a) what has been done in compliance with sections 42, 47 and 48 in relation to a proposed application that has become the application, (b) any relevant responses, and (c) the account taken of any relevant responses.

1.5.4 In effect the role of the Consultation Report is to show how an applicant has complied with Chapters 1 and 2 of Part 5 of the Planning Act 2008 to enable the IPC to determine whether this part of the Act has been satisfied.

1.5.5 This report has been developed in accordance with the Consultation Report requirements set out in the 2008 Act. Attention has also been paid to IPC Guidance Note 1 (August 2011), particularly paragraphs 25 to 27.

Brechfa Forest West Wind Farm Consultation Report 6

2. section 42 prescribed persons

Section 42 - Duty to Consult

The applicant must consult the following about the proposed application (a) such persons as may be prescribed, (b) each local authority that is within section 43, (c) the Greater Authority if the land is in Greater London, and (d) each person who is within one or more of the categories set out in section 44.

2.1 Prescribed Persons (Section 42(a))

2.1.1 The list of prescribed persons (see Appendix B), was based on: – (Initially) RWE NRL’s interpretation of the list of persons to be consulted included in Schedule 1 to the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 (‘APFP Regulations’); and – (Subsequently) On a list of prescribed consultees provided to RWE NRL by the Infrastructure Planning Commission (IPC), under Regulation 9(1)(a) of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (‘EIA Regulations’), on 15th February 2011.

2.1.2 In order to ensure that the consultation documents were sent to the right address and recipient, RWE NRL’s consultants wrote to each of the organisations initially identified by RWE NRL as being relevant (based on the assessment of Schedule 1 of the APFP Regulations). This correspondence sought to confirm who the contact person was for each organisation and to ensure that the address details were correct. Where no response was received, RWE NRL followed up with a phone call to confirm these details.

2.1.3 In addition to the correspondence detailed above, RWE NRL also sent out an introductory letter to each of these organisations on 2nd February 2011. This introductory letter explained that their organisation was shortly to be consulted in accordance with Section 42 (Duty to Consult) of the Planning Act (2008) and to highlight the consultation timescales. An example letter is attached at Appendix C.

2.1.4 At the start of consultation, the prescribed persons identified based on RWE NRL’s interpretation of the list of persons to be consulted as set out in the APFP Regulations were sent letters via recorded delivery enclosing the following documents: – A newsletter summarising the proposals (this newsletter was also circulated to local homes and businesses in vicinity of the proposal); – A DVD containing the “preliminary environmental information” which, for the purposes of this consultation, was the full Draft Environmental Statement for the Brechfa Forest West Wind Farm; Brechfa Forest West Wind Farm Consultation Report 7

– A non-technical summary of the Draft Environmental Statement (English and Welsh); – A Planning Statement setting out the planning policy context for the proposed wind farm (English and Welsh); and – A copy of the notice published in accordance with the requirements of Section 48 of the APFP Regulations, appearing in the Guardian, the London Gazette and Carmarthen Journal on Wednesday 9th February and in the Carmarthen Journal on Wednesday 16th February. – An example letter is attached at Appendix C.

2.1.5 The list of prescribed persons subsequently received from the IPC (under Regulation 9(1)(a) of the EIA Regulations) arrived after the first round of letters had been sent out to the prescribed persons identified by RWE NRL. The IPC prescribed persons list included a number of additional organisations that were not written to by RWE NRL during this first round of correspondence as these organisations were either not considered to be relevant or the criteria for inclusion did not seem to apply. The IPC also provided different contact details for a number of the organisations that had been written to previously.

2.1.6 For completeness, on 16th February 2011 RWE NRL sent out a further set of letters or emails (some on the IPC list only had an email address) to all additional organisations highlighted by the IPC, and again to organisations where contact details differed from the contact details held by RWE NRL. This correspondence directed the consultees to the Brechfa Forest West Wind Farm website where all of the consultation documents and previously distributed documentation could be found, and enclosed (or attached) a copy of the Section 48 notice. An example letter is attached at Appendix D.

2.1.7 The IPC list also named three non-prescribed consultees; the Welsh Language Board; SWWITCH; and CADW. All three consultees were subsequently written to by RWE NRL.

2.1.8 A follow up letter was sent by RWE NRL on 21st March 2011 to all prescribed bodies to emphasise the importance of their responses being received by 6th April in order to be considered relevant responses in accordance with Section 49 of the Planning Act 2008. An example letter is attached at Appendix E.

2.1.9 During the consultation period the RWE NRL project team made themselves available for meetings at the request of the prescribed persons. Specifically, meetings were sought with the Welsh Assembly Government; the Environment Agency Wales; the Countryside Council for Wales; and Carmarthenshire County Council. The only meeting requested and therefore held was with the Countryside Council for Wales on 30th March. Brechfa Forest West Wind Farm Consultation Report 8

local authorities

2.2 Local authorities for the purposes of section 42(b)

2.2.1 With respect to this proposal, the relevant authority under section 42b(1) is Carmarthenshire County Council.

2.2.2 Section 42b(2) states that any local authority that shares a boundary with the relevant authority under section 42b(1) must be consulted. For the Brechfa Forest West Wind Farm proposal the following authorities were also consulted: – Pembrokeshire County Council – County Council – Powys County Council – City and County of Swansea – Neath Port Talbot County Borough Council – Brecon Beacons National Park Authority – Pembrokeshire Coast National Park Authority Brechfa Forest West Wind Farm Consultation Report 9

SECTION 44

2.3 Persons within one or more of the categories set out in Section 44 (Section 42(d))

2.3.1 Section 44 of the Act sets out three categories of persons who must additionally be consulted with under Section 42 (Duty to consult). These categories are: – Category 1: Includes those who are owners, lessees, tenants or occupiers of the land included within the boundary of the proposal. – Category 2: Includes those who are (a) interested in the land, or (b) have power to sell and convey the land or to release the land. – Category 3: Includes those who would or might be entitled to make a relevant claim either (a) under section 10 of the Compulsory Purchase Act 1965, or (b) under Part 1 of the Land Compensation Act 1973 as a result of the order being implemented.

2.3.2 For the purposes of identifying those persons who fall within Category 1 or Category 2, RWE NRL undertook a series of land registry searches and title investigations. Additionally, the owners of the land were contacted and asked for any information that they had about leases, tenancies etc.

2.3.3 Section 44 requires the applicant to make ‘diligent inquiry’ into identifying those it thinks would or might be entitled to make a relevant claim under Category 3. Taking a cautious approach, a number of properties were identified in the vicinity of the proposed site, which may be affected as a consequence of the granting of consent for the construction and operation of the wind farm.

2.3.4 A full list of properties consulted under Section 44 Category 3 can be found in the Book of Reference (Document BFW/AppDoc5/BoR). Brechfa Forest West Wind Farm Consultation Report 10

section 42 summary table

2.4 It is noted that Section 44(c) is not relevant to the Brechfa Forest West Wind Farm proposal.

2.5 Section 42 comments summary table

The following table provides an overview of the comments received during the Section 42 consultation.

Reference Number Date received Organisation Summary/ notes BFW/IPC/S42/001 14/02/2011 OFWAT No comments. BFW/IPC/S42/002 14/02/2011 City & County of 14th February- holding response. 06/04/2011 Swansea 6th April- no comments. BFW/IPC/S42/003 16/02/2011 NATS 16th February- requesting additional info. 08/03/2011 8th March- No safeguarding objection. BFW/IPC/S42/004 18/02/2011 Pembrokeshire Coast 18th February- holding response. 06/04/2011 National Park 6th April- don’t wish to raise any adverse observations. BFW/IPC/S42/005 24/02/2011 Welsh Water Relevant matters included in the ES. No issues of concern to highlight. BFW/IPC/S42/006 24/02/2011 Councillors supported the proposed wind Community Council farm. BFW/IPC/S42/007 21/02/2011 Neath Port Talbot 21st February- Holding response. BFW/IPC/S42/024 30/03/2011 County Borough 30th March- No objections. Council BFW/IPC/S42/008 01/03/2011 Scottish & Southern No comments to make. Energy BFW/IPC/S42/009 01/03/2011 DPTAC Not able to provide views on these types of documents. BFW/IPC/S42/010 01/03/2011 Gas Do not cover this area. Networks BFW/IPC/S42/011 18/02/2011 Fulcrum No equipment on or around the site. BFW/IPC/S42/012 18/02/2011 WAG- Jane Davidson Holding response. BFW/IPC/S42/013 03/03/2011 FCW- as landowner Sets out role as agent of landowner. Emphasises support for the application. BFW/IPC/S42/014 15/03/2011 Health Protection Present information on any health issues Agency clearly- either as an identified section of a report or as a separate report. BFW/IPC/S42/015 17/03/2011 Environment Agency Detailed response. BFW/IPC/S42/016 17/03/2011 CAA EIA adequately addresses aviation issues. BFW/IPC/S42/017 22/03/2011 Community In principle, in favour of renewable energy Council (Welsh). BFW/IPC/S42/018 22/03/2011 Community Turbines must be at least two and a half Council km away from local properties. BFW/IPC/S42/019 23/03/2011 Community Query re compensation. Council BFW/IPC/S42/020 23/03/2011 Wales Resilience Stated that both this was an inappropriate Forum addressee. Brechfa Forest West Wind Farm Consultation Report 11

section 42 summary table

BFW/IPC/S42/021 24/03/2011 Brecon Beacons 24th March- Holding response 07/04/2011 National Park 7th April- late response- no objection to the individual development. However, potential for cumulative impacts which must be given due regard. Suggests two conditions. BFW/IPC/S42/022 24/03/2011 Coal Authority No observations or comments BFW/IPC/S42/023 30/03/2011 Southern Gas Do not cover this area Networks BFW/IPC/S42/025 01.04.2011 SWWITCH No comment to make on this consultation BFW/IPC/S42/026 31/03/2011 Hywel Dda Local Present information on any health issues Health Board clearly- either as an identified section of a report or as a separate report. BFW/IPC/S42/027 03/04/2011 Llanfihangel Rhos Seven observations raised. y Corn Community Council BFW/IPC/S42/028 06/04/2011 CCW Detailed response. BFW/IPC/S42/029 05/04/2011 CCC Detailed response. BFW/IPC/S42/030 04/04/2011 Councillors unanimously voted to oppose Community Council the wind farm. Seven observations raised. BFW/IPC/S42/031 04/04/2011 British Waterways No comments. BFW/IPC/S42/032 06/04/2011 HSE No further comment to make. BFW/IPC/S42/033 06/04/2011 Llanllawddog Comments form completed, various Community Council observations made. BFW/IPC/S42/034 06/04/2011 Powys Police Concerns raised relating to traffic Authority management & associated policing of abnormal loads. Potential issues relating to increased crime and disorder. BFW/IPC/S42/035 06/04/2011 WAG- Roads and Various points raised regarding traffic and Projects Division transportation. BFW/IPC/S42/036 06/04/2011 Forestry Commission Request commitment to compensatory Wales planting for temporary woodland removal. Brechfa Forest West Wind Farm Consultation Report 12

2.6 Summary analysis of Section 42 responses

2.6.1 RWE NRL sent a total of 99 letters (or emails) to bodies prescribed under section 42 (a) and (b) of the Act and the non-prescribed bodies included on the list provided by the IPC under Regulation 9(1)(b) of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009.

2.6.2 A total of 34 responses were received by RWE NRL.

2.6.3 The following points are noted in respect of the responses received: – Response ref BFW/IPC/S42/013 is from a person within a category set out in Section 44 of the Act, not a prescribed body; – BFW/IPC/S42/024 was a duplicate – (a holding response had previously been received from this organisation). – one response received was in Welsh (BFW/IPC/S42/017). – In addition to those listed in the section 42 table above, seven responses were received from persons within a category set out in section 44 but were incorrectly provided with a section 47 reference number. These were: – BFW/IPC/S47/007 – BFW/IPC/S47/014 – BFW/IPC/S47/080 – BFW/IPC/S47/091 – BFW/IPC/S47/092 – BFW/IPC/S47/094 – BFW/IPC/S47/100

2.6.4 Analysis of these seven incorrectly numbered responses is provided in Section 2.9 of this report (see below), as well as within Section 3 which details the Section 47 responses received by RWE NRL.

2.6.5 Of the 34 responses received, two voiced support for the proposal/ renewable energy (Cynwyl Elfed Community Council & Llandysul Community Council). Eighteen presented no comments or objection (OFWAT; City & County of Swansea; NATS; Pembrokeshire Coast National Park Authority; Welsh Water; Neath Port Talbot County Borough Council; Scottish & Southern Energy; DPTAC; Scottish Gas Networks; Fulcrum; Welsh Government- Jane Davidson’s office; CAA; Wales Resilience Forum; Coal Authority; Southern Gas Networks; SWWITCH; British Waterways; & HSE).

2.6.6 The remaining 14 responses are dealt with in more detail in the following section. Brechfa Forest West Wind Farm Consultation Report 13

detailed responses

2.7 Detailed responses

2.7.1 BFW/IPC/S42/014 & BFW/IPC/S42/026

Responses were received from the Health Protection Agency (HPA) and the Hywel Dda Local Health Board (LHB). Most of the content of these two responses was identical.

The HPA response enclosed a position document in relation to application for onshore and offshore wind farms with a separate annex relating to non-ionising radiation.

With regard to chemicals, the HPA’s position document states that at this point in time ‘there is no body of evidence conclusively linking wind farms with adverse health effects arising from emissions of chemicals’ and that ‘wind generation should not produce emissions, pollutants, or waste products’. It does highlight that ‘there is potential for impacts to arise during the construction and decommissioning phases from the transport of material and equipment (e.g. accidental leaks, spills and releases)’. The HPA states that it expects the applicant to adhere to best practice guidance during these development phases to ensure that potential impacts are assessed and minimised.

With regard to non-ionising radiation, the HPA annex on this topic refers to advice published on limiting public exposure to electromagnetic fields. This advice recommends the adoption of the EMF Exposure Guidelines published by the International Commission on Non-Ionising Radiation Protection (ICNIRP).

In summarising its requirements, the HPA states that it considers that the onus is on the applicant to conduct the assessment of compliance with the referenced advice and policy, including compliance with the ICNIRP guidelines. The HPA requests that this assessment should be ‘clearly laid out, either as an identified section of a report which can be read in isolation or as a separate report’.

The LHB reiterate that the HPA advice on limiting public exposure to electromagnetic fields should be adhered to. It also repeats the comments made by the HPA regarding chemicals. For other environmental aspects, the LHB recognises that the most common concerns expressed are related to noise and shadow flicker.

In summary, the LHB similarly request that the assessment should be clearly laid out either in an identified section of a report or as a separate report.

RWE NRL response In response to the feedback received from the HPA and the LHB, RWE NRL are submitting (along with the suite of application documents), a standalone report relating to health issues. This standalone report sets out the evidence demonstrating compliance with the ICNIRP guidelines, and provides a brief overview and cross referencing to relevant sections Brechfa Forest West Wind Farm Consultation Report 14

of the Environmental Statement (ES). In particular, this report will refer to the draft Construction Method Statement which will set out how best practice guidance will be followed by RWE NRL during construction (as well as referring to the noise and shadow flicker chapters in the ES). The application document reference for this standalone health report is: BFW/AppDoc16/Health.

2.7.2 BFW/IPC/S42/015

The Environment Agency Wales (EAW) provided a detailed response covering a number of issues. These are set out in the table below, along with RWE NRL’s response to each separate comment. Unless otherwise stated, any actions required are addressed within the revised ES.

Comment Response As you are aware otters and their resting places are fully protected under No action required the Wildlife and Countryside Act 1981 and the Habitats Regulations 2010. As highlighted within the EIA potential and actual otter resting sites are present on three watercourses within or immediately adjacent to the development site. Otter activity is also widespread on watercourses throughout the site. From the information submitted we do not consider that the impacts on otters have been appropriately detailed and as such we would offer the following comments

The primary location of concern is the otter ‘shelter’ located on the Clarification provided to the EAW of potential Afon Pib. It is not clear what is meant by ‘shelter’ but it is assumed to impacts associated with the proposal, be a resting site which is in use. This shelter lies within 115m from the including various forms of disturbance. Detail section of track linking turbines 9 and 10 and within approximately 250m provided on potential noise impacts. of turbines 9 and a borrow pit. Whilst there should be no direct impact on the Afon Pib, it is quite possible that the construction of the tracks, turbines and the operation of the borrow pit will result in sufficient noise disturbance to render the upper part of the Afon Pib and the shelter unsuitable for use by otters. This potential impact has not been addressed within the submitted information

We also note that Para 13.262 makes reference to felling activity ‘within Clarification provided to the EAW. 50m of a watercourse’ but it is not clear which location this refers to. Without further information it is not possible to conclude that there will be no disturbance to otters and therefore we do not agree with the conclusion in Table 13.34 that the residual impact on otters is negligible

We note that a borrow pit is located within approximately 35m of the The elements highlighted will be micro-sited Afon Pib and the substation and construction compound located near to out of the 50m buffer from the Afon Pib and T12 appear to be within approx 40m of a tributary of the Afon Pib. The tributaries. positioning of these features would seem inappropriate given that for all other operations a minimum buffer zone of 50m is advocated. Justification is required as to the positioning of the borrow pit, substation and compound in close proximity to these watercourses Brechfa Forest West Wind Farm Consultation Report 15

As highlighted within the EIA the development would also result in the Habitat loss calculations are further clarified loss of some notable habitats on site. These habitats are likely to qualify in the revised ES and more information and as BAP habitats and are therefore a material planning consideration. No commitment made by RWE NRL to provision mitigation measures are provided for the loss of these habitats however of habitat elsewhere within the site. it is concluded within the EIA that this loss will have a minor or negligible significant impact. We would disagree with this statement. Given the size of the proposed development and the size of the site, it would be expected that all valuable habitats to be lost could be replaced elsewhere within the site. We would advocate the creation of such habitats, in quantities in excess of those lost resulting in a biodiversity enhancement for the area.

The EIA also states that the loss of a pond feature, labelled Pond 3, The revised ES has been clarified to is acceptable without mitigation. If the loss of this feature cannot be demonstrate that no ponds will be lost. avoided, a replacement pond should be created nearby as a compensatory Best practice construction methods will be measure. We would also note that with regard to Ponds 1 & 2, which implemented to minimise the risk of impacts support populations of palmate newts, no information has been provided on palmate newt populations. on how these features will be safeguarded during the construction phase of the development

The Phase 1 plan does not show all watercourses or ponds on site. This This observation has been reviewed and is an oversight and should be rectified. The plan does indicate one amendments made to the ES (where watercourse running along the southern boundary of the access corridor appropriate) and clarification has been however, no such watercourse is shown at this location on 1:10,000 OS provided in the text in relation to the Phase maps therefore the inclusion of this watercourse on the map may be an 1 plan. error

In addition to the above we would also recommend that the eradication A commitment has been made to eradicate of small areas of Japanese Knotweed be incorporated into the Habitat Japanese Knotweed within the site boundary. Management Plan (HMP) as an ecological enhancement measure The potential for increased flows, due to the need for the removal of trees No action. Following the construction, of the to allow the development to proceed is examined. It is concluded from a wind farm the Forestry Commission Wales literature review that such effects would be temporary, localised and are will re-stock the temporary felled areas in unlikely to alter major flood events in the longer term once vegetation has line with the Forest Design Plan for Brechfa been re-established. In order to reduce flood risks, measures should be Forest. taken to enhance the recovery of vegetation. In this regard a programmed plan would be relevant to ensure that vegetation does re-establish as quickly as possible. The timing of tree felling, ground fertilisation, plant species used as vegetation cover and speed of growth may also be important factors in this regard. We would recommend further liaison with the Local Authority’s County Ecologist and CCW on this matter

Should the IPC be minded to eventually approve the application we Requirement 7 within Schedule 1 of the draft would advise that for the avoidance of doubt a condition requiring details Development Consent Order provides for a for managing surface water management should be provided prior to Construction Method Statement (CMS) to construction be approved prior to the commencement of construction. Surface water management is listed as one of the elements to be included within this document.

To fully and adequately assess the hydrology and hydrogeological regime No action. RWE NRL’s hydrologists are within the water catchment areas will require some intrusive investigation confident that the information gathered and and on site monitoring. However we would anticipate that intrusive presented in the ES is sufficient to assess the investigation of ground conditions will be required in any instance to potential impacts of the wind farm hydrology determine the exact design requirements for the foundations of the wind and the hydrogeological regime. turbines Brechfa Forest West Wind Farm Consultation Report 16

Calculations should be submitted together with detailed designs and Approximate calculations of run off in 1 in layout of any SUDS features that will be used to ensure that existing 100 year flood events have been provided Greenfield surface water run off rates are maintained. The feasibility and outline designs/ indicative numbers, of implementing a SUDS scheme at the site must be confirmed by capacities and effects of SUDS features examination of ground conditions, water table levels, soil types and provided in the revised ES. maximum potential surface water flows, and insitu infiltration testing etc and existing predicted Greenfield run off rates. Any additional evaluation report on SUDS should refer to the Construction Industry Research & Information Association (CIRIA) document C697 entitled ‘the SUDS manual’ 2007. It is imperative that the performance of any future attenuation systems are Noted. maintained for the lifetime of the development. You must ensure that the surface water management system for the site is constructed to agreed specifications and design standards and the monies are available in the future for both repair and maintenance such as cleansing of pipework, desilting any storage ponds/ attenuation basins and any scour repairs. It would be relevant to confirm the proposed permeability of the base and sides of any proposed ponds/ attenuation basins to ensure that storm water is actually retained for a sufficient period within such features. We would recommend that as a part of the management plan you demonstrate that the mechanism by which future maintenance and repair of the system will be guaranteed for the life time of the development.

The storage of potentially polluting material, the risks of any leaks or RWE NRL will incorporate the Construction spills and any potential pollution from the construction phase of the Environmental Management Plan into development needs to be adequately addressed. We note that the EIA the Construction Method Statement states that a management plan will be developed for the wind farm (Requirement 7 as set out above), as will prior to commencement on site. However, should the IPC be minded to Pollution Prevention Measures. eventually approve the application we would advise that the submission of a Construction Environmental Management Plan (CEMP) is included as a condition of any permission granted. We would also request that a programme of monitoring of high risk watercourses is carried out prior and during construction phase to ensure that the pollution prevention controls are operating efficiently.

All appropriate pollution control measures must be adopted on site during Noted. the construction phase of development to ensure that the integrity of controlled waters is assured. This is essential in order to ensure that the development does not cause pollution of the water environment or potential deterioration in the WFD classification. Pollution prevention guidance is available from our website. The following guidance will be of particular relevance: PPG2, PPG3, PPG5, PPG7, PPG8

As you will be aware the construction of access tracks/ roads will pose a Noted. high risk to controlled waters. This aspect should be fully addressed within the CEMP and any safeguards should be installed on site prior to any construction works. If there is a problem with excessive silt run off, straw bales should only be used as a temporary measure and working practices should be adapted to manage this run off appropriately.

Due to the long lengths of trenches required to house the underground Noted. cables we recommend the developer prepare trenches and lay cables in short lengths to avoid any insulative material being washed into watercourses during heavy rainfall Brechfa Forest West Wind Farm Consultation Report 17

Any stockpiles of material should be covered, seeded or bunded to Noted. avoid silt laden run off entering a watercourse. We note that the draft Construction Method Statement (CMS) does indicate that stockpiles will have silt fencing in place to protect the watercourse.

From the submitted information we note that the proposed compound Noted. hardstanding will be graded so that any drainage falls towards drainage ditches. We would highlight that due to the storage of fuels etc this could pose a high risk to controlled waters. As such appropriate pollution prevention measures for the compound areas must be incorporated in line with the CEMP

Any refuelling areas should be bunded and served by an interceptor. All Noted. fuel and waste oil should be double bunded and any spillages should be cleaned using absorbent material and not washed away. Any contaminated material should be consigned as Hazardous Waste

The developer should also be made aware of our new regulatory position Noted. on de-watering excavations, which can be found on the EAW website

We would also highlight that an Environmental Permit from the Noted. Environment Agency may be required for any water discharges from settlement lagoons on site The submitted info also states that Pollution Incident Response Plan will Noted. be produced in consultation with the Environment Agency. We would highlight that relevant guidance is available on the NetRegs website. In addition to this guidance, the plan should also detail sensitive receptors to be protected and list the types of fuels, oils gases and chemicals that will be stored on site and estimated quantities. We would wish to be consulted on this plan prior to any works starting on site.

If any controlled waste is to be removed off site, then the site operator The CMS will incorporate a Site Waste must ensure a registered waste carrier is used to convey the waste material Management Plan (see Requirement 7). off site to a suitably authorised facility. The Duty of Care Regulations for dealing with waste materials are applicable for any offsite movements of wastes. The developer as waste producer therefore has a duty of care to ensure all materials removed go to an appropriate licenced disposal site and all relevant documentation is completed and kept in line with regulations

If during construction or excavation works any contaminated material Noted. is revealed then the movement of such material either on or off the site should be in consultation with Environment Agency Wales

The site may require a permit/exemption under Environmental Permitting Noted. Regulations 2010 for importing waste material to create an area of hardstanding for example. For additional information on this aspect please contact our Environment Management Team on 01554 713639

If any Japanese Knotweed is encountered during any stage of the Noted. development or restoration phase then it should be managed in line with our guidance ‘Managing Japanese Knotweed’ which can be found on the Environment Agency website. If any material contaminated with Japanese Knotweed is removed off site then the material should be treated as controlled waste and taken to a suitably permitted facility and duty of care legislation applies. Brechfa Forest West Wind Farm Consultation Report 18

With regard to the proposed borrow pits, any backfill material must be Noted. inert and of similar permeability to the excavated rock. This will ensure that the recharge of groundwater resources is not significantly altered

With regard to the felling process the developer/ contractor should follow Noted. Forest and Water Guidelines

Our NetRegs website can also provide specific sector guidance which Noted. includes information on harvesting and constructing forest roads and paths

We note that the compound areas will include welfare facilities for the Noted. operators on site. As the site is located outside of the main sewered area, a satisfactory non-mains drainage assessment (Welsh Office Circular 10/99) must be undertaken to determine an appropriate method of foul drainage. We would advise that the installation of a non-mains system may require a permit for discharges of sewage with a volume of 5m3/ day or more to a river, stream, estuary or the sea and for discharges of 2m3/day or more to soakaway or drainage field

For discharges of less than the above, the applicant may be able Noted. to register as exempt from the requirement for a permit under the Environmental Permitting Regulations 2010. This is provided that the installation meets certain criteria. Under the terms of the Water Resources Act 1991, an Impounding licence Noted. may be required from the Environment Agency for the impounding of any watercourse, ditch or stream. This should be considered if the developer intends to alter or divert any existing watercourses during the construction phases. The developer should also be aware that they may need to apply for a licence if they intend to alter any existing impoundments.

Also, under the terms of the Water Resources Act 1991 an Abstraction References to on-site concrete batching have Licence may be required from the Environment Agency for the abstraction now been removed from the ES, it is not of water from any inland water or underground strata. The developer anticipated that abstractions will be required. should consider this if water is needed to be abstracted for any purpose, such as use in concrete manufacture, or for dust suppression. Abstractions for dewatering purposes are currently exempt from licensing however, this exemption is likely to be removed in the near future.

With regard to private water supplies the mitigation measure proposed Noted. should address any impacts on groundwater resources in the area. However, we would highly recommend liaising with Dwr Cymru and the Local Authority’s Environmental Health Team on this matter. If impacts on the source are recorded additional mitigation will be required and if derogation occurs, an alternative source of supply may need to be provided.

2.7.3 BFW/IPC/S42/018

A short response was received from Llansawel Community Council. It stated that ‘As members of the community council we are not against the wind turbines, but they must be at least two and a half kilometres away as promised from local properties, e.g. Bancyglyn, Hafod Wen, Cwmhowell, Cilwenau etc’. Brechfa Forest West Wind Farm Consultation Report 19

RWE NRL response No action. There is no justification for the inclusion of an arbitrary buffer of 2500m between the proposed turbines and local properties. The Brechfa Forest West Wind Farm consultation included a draft Environmental Statement that fully examined the potential effects arising from the proposed development and whether these effects are signficant. The use of an arbitrary buffer is unnecessary to address the potential effects of the development.

The consultation response from the Llansawel Community Council does not explain or identify the evidence base that underpins this requested restriction. The response does not clearly demonstrate that large scale wind farms have an unacceptable impact upon residential amenity within a distance of 2.5km of residential properties. When taken at face value, this proposition seems unjustifiable on the basis that there are many operational wind farms in Wales and the UK that have turbines within this separation distance that have not given rise to any complaints or indeed may not be visible from properties within that buffer.

The request further fails to accord with TAN8, Annex D, paragraph 3.4 which sets out the methodology for Local Planning Authorities to refine their Strategic Search Area’s (SSA’s). In assessing the capacity of refined areas, para 3.4 states that a buffer of 500m radius should be drawn as it is considered a typical separation distance between a and a residential property to avoid unacceptable noise impacts. Furthermore, para. 3.4 states that a 500m buffer should not be applied rigidly as it can lead to conservative results and flexibility is advised. In addition, there is no requirement within the National Policy Statement to require a minimum separation distance from homes.

2.7.4 BFW/IPC/S42/019

A short response was received from Abergwili Community Council. It states that the community council is ‘concerned as to whether householders directly affected by this project would be able to claim some form of compensation. This compensation would be in respect of any reduction in the freehold prices of their properties due to the adjacency of the wind farm, as well as for any enduring noise nuisance from the wind turbines themselves’.

RWE NRL response No change required to the application. Part 1 of the Land Compensation Act 1973 (‘LC Act’) provides a right to affected landowners to claim compensation where their property is depreciated in value by the use of public works. The LC Act places an onus on landowners to prove that depreciation has occurred and that the depreciation is as a result of the wind farm. Compensation under the LC Act is payable in respect of the subsequent use of the wind farm, not the construction process. Brechfa Forest West Wind Farm Consultation Report 20

A person may claim compensation for the depreciation in the value of an interest in land due to physical factors caused by the use of public works. The physical factors include noise, vibration, smell, fumes, smoke, artificial lighting and the discharge onto the land of any solid or liquid substance. The proximity of the works or visual impacts on views are not claimable under the LC Act. The valuation exercise is therefore effectively the difference in the ‘switched on’ and the ‘switched off’ value.

2.7.5 BFW/IPC/S42/021

A consultation response was received from the Brecon Beacons National Park on 7th April, which was after the deadline for responses. It is therefore, according to Section 49 (3) of the Planning Act, not a ‘relevant response’. However, as the letter was dated before the deadline and was received only one day late, consideration has been given to the response.

The response starts by setting out that the Brecon Beacons National Park Authority raises no objection to the proposal subject to the imposition of suitable conditions. However, the Authority does raise concerns over the cumulative impact of the proposal coupled with both operational and proposed wind farms in the general area, and requests that this is given due consideration by Carmarthenshire County Council.

The National Park Authority describes the planning policy context, both for renewable energy in Wales and National Parks. With regard to TAN 8, the Authority draws attention to paragraph 8.4 of Annex D, which states ‘There is an implicit objective in TAN 8 to maintain the integrity and quality of the landscape within National Parks… i.e. no change in landscape character from wind turbine development.’

With regard to the proposed development, the response states that the main issue of consideration is the impact of the proposal on the special qualities of the Brecon Beacons National Park Authority. The Authority considers that the four viewpoints chosen by RWE NRL within the Brecon Beacons National Park provide an appropriate range of locations to assess the impact of the proposal on the National Park. In relation to each of these viewpoints, in general the Authority considers that the distance of the wind turbines, being in excess of 10km, would not give rise to any significant impact on the National Park.

The Authority accepts the ES’s conclusion that the proposal would have a minor impact on the National Park and would not, on its own, have a detrimental impact on the special qualities of the National Park.

However, the Authority raises strong concerns over the cumulative impact of both operational and proposed wind farms within the general area to the north west, where up to 71 turbines could potentially be visible from the National Park. Therefore the Authority requests that due regard is given by the Carmarthenshire County Council to the cumulative impact of this development coupled with both the operational and proposed wind farms in this general location in the determination of this application. Brechfa Forest West Wind Farm Consultation Report 21

The Authority has proposed two conditions be included within the planning permission should the permission be granted for the proposal, these are: 1. The requirement to remove all turbines and associated infrastructure after a period of 25 years, or if use of the turbines cease, whichever is the soonest, and the land be fully restored to its previous state in order to protect the special qualities of the National Park. 2. A condition to ensure that the overall height to blade tip of the turbines does not exceed 145m and that details of the proposed colour and finish of the turbines are submitted to and approved by the Local Planning Authority prior to the commencement of development.

RWE NRL response The conditions recommended by the Brecon Beacons National Park Authority will be addressed with the inclusion of requirements 2, 3 and 4 attached to the draft Development Consent Order covering Time Limits and Site Restoration. Requirement 2 states that the Development Consent endures for a period of 25 years from the first export date. Requirement 3 states that a decommissioning and restoration statement must be submitted to the Commission for approval prior to decommissioning. The scheme shall provide for the removal of all above-ground elements of the development (with the exception of access tracks). Requirement 4 states that if any wind turbine fails to produce electricity to the grid for a continuous period of 12 months, and if the developer is instructed by the Local Planning Authority, the wind turbine and its associated ancillary equipment (excluding the turbine bases more than 1 metre below ground level) shall be removed from the site within a period of 6 months from the end of that 12 month period unless otherwise agreed in writing by the Local Planning Authority.

2.7.6 BFW/IPC/S42/027

Llanfihangel Rhos-y-Corn Community Council provided seven points within their consultation response: 1. The volume of traffic travelling towards Gwyddgrug will be a problem. 2. Two accesses to the same forestry. Surely there is no need to have two new roads build side by side. 3. one dwelling known as Bryngolau, New Inn is only approximately 900m from a proposed turbine. Another dwelling at Blaengwyddgrug is also approximately 900m from the proposed turbine 23. 4. The infrared lights which are to be fitted to the back of the wind turbine to ensure that aircraft can see them at night are a concern. Has anyone investigated how these lights affect the wildlife, animals, birds (Red Kites etc) and bats. Are these lights harmful to these species? 5. Some residents are concerned that the building works will affect the natural spring water supplies to their dwellings and that no provisions have been made to ensure that this will not happen. 6. Tourism will be affected by the proposed wind farm. Many businesses have diversified Brechfa Forest West Wind Farm Consultation Report 22

into tourism, barn conversions etc which will lose their appeal when they will have a wind farm as their backdrop. 7. The public rights of way, footpaths, cycle routes, mountain bike trails and bridlepaths will all be affected by this proposed wind farm.

RWE NRL response 1. No action - Traffic impacts have been considered within chapter 9 of the Environmental Statement. These impacts were judged to be not significant on the A485. Mitigation measures have been proposed in order to control environmental impacts that could occur. 2. No change - RWE NRL have investigated in some detail the possibility of utilising the existing access for the Wind Farm. Unfortunately it has not been possible to reach a commercial agreement with the landowner. In order to mitigate the issues raised by a range of groups and individuals who have responded to the consultation, screening is proposed to mitigate landscape and ecological impacts associated with the new access track. 3. No action - These figures are correct and these properties have been considered carefully by RWE NRL’s environmental consultants on a range of issues. Individual visual residential amenity studies have been done for these properties (amongst others), noise studies and shadow flicker assessments completed. 4. No action - Infrared lighting has been considered by the ecological consultants working on RWE NRL’s behalf, who concluded that it would not lead to any additional impacts on wildlife. 5. Potential impacts on private water supplies have been studied by RWE NRL’s hydrology consultants and are detailed, along with the proposed mitigation, in chapter 8 of the Environmental Statement. The chapter outlines that measures will be put in place to control erosion and sedimentation and water pollution. Specific measures to minimise risks to the water supplies at Coedlannau Fawr, Lan Ddu and Lan Farm are also set out within chapter 8 of the Environmental Statement. 6. No action - There is no evidence that confirms that wind farms have a negative effect on tourism. 7. No cycle routes, mountain bike trails or bridleways will be affected by the development. Efforts will be made to minimise impacts on users of the Brechfa Forest during the construction of the wind farm although there will inevitably be some disruption. Two (and possible a third for a short period) footpaths will be temporarily diverted during construction. Further information about public access impacts, mitigation and gain are set out in chapter 11 of the Environmental Statement and in the Public Access Management Plan appended to the ES.

2.7.7 BFW/IPC/S42/028 Brechfa Forest West Wind Farm Consultation Report 23

The Countryside Council for Wales (CCW) provided a detailed response covering a number of issues. These are set out in the table below, along with RWE NRL’s response to each separate comment. Unless otherwise stated, any actions required have been made within the revised ES.

Comment Response 1.1 CCW has found parts of the draft ES document difficult to A full review of the ES has been undertaken follow because information is often spread across more than and inconsistencies and typographical errors one chapter, is not always clearly cross-referenced, and some corrected where required. information is missing or inconsistent. For example, the labelling of new and existing access tracks changes throughout the document. Figure 1.2 depicting the Site layout clearly shows existing access tracks in green and proposed new tracks in purple; however, Figure 8.2 depicting the Study Area for Hydrology shows the colours in reverse (i.e green for new tracks and purple for existing tracks). Felling periods are inconsistent throughout the ES, sometimes stating 3 months other times 4. Figure 5 as referenced in the HMP does not exist, and Chapter 2 (Approach to EIA) in the ES is incorrectly labelled throughout the chapter at the header with chapter 3s title (Scheme Description and Design Strategy). All of Volume 3 containing the appendices lack page numbers. CCW appreciates that these errors have probably arisen as a result of several changes and iterations to the draft ES document during the development process, but inconsistencies such as these can make it difficult to follow the information outlined in the ES. CCW suggests that the ES is thoroughly checked and any omissions and typographical errors are corrected. 1.2 In our scoping advice of June 2009 we specifically requested All the ES figures have been reviewed and the that where baseline/survey information was presented as maps scheme layout added on if at all possible (e.g. within the ES that it was overlain with the infrastructure lay-out. so long as it didn’t overcrowd the figure so as This advice has not been followed which severely reduces the to make it illegible or at such a scale that it accessibility and clarity of information within the ES and has wouldn’t be possible to make out the various caused problems when inspecting whether impacts assessments/ elements). The provision of an acetate sheet surveys etc are valid. CCW recommend that revised figures are would not practical as many people will view incorporated into the final ES to be submitted to IPC that allows the ES figures in electronic form. the wind farm infrastructure to be shown in relation to e.g. vegetation and ecological survey maps. This could be as simple as incorporating and superimposing an acetate sheet over the figures within the ES. 1.3 Some of the wording and terminology throughout the ES is A review of the ES has been undertaken and overly subjective and open to interpretation. CCW recommends wording changed where considered necessary. that (for example) all ‘shoulds/woulds/where feasible/where However, there are occasions where ‘should’ applicable/where possible to/where reasonably practicable/ has been used for necessary reasons, e.g. to is likely to be’ are amended or removed and the context of the reflect the uncertainty of predicting impacts on paragraph(s) in question explained more succinctly. This would unknown archaeology allow greater confidence in the methodologies, conclusions and mitigation measures outlined throughout the ES. Brechfa Forest West Wind Farm Consultation Report 24

1.4 CCW notes that at several points throughout the ES, in the This issue has been revisited in the revised ES draft Construction Method Statement (CMS), in the Non-Technical and clarified as far as possible. To be clear, Summary (NTS), and the newsletter sent to local residents, that the EIA is not based on a ‘Rochdale Envelope’ the turbine heights are described as having a maximum height approach. A maximum tip height of 145m has to blade-tip of 145m. However, at several others points in the been assessed. ES (e.g. Chapters 1 and 3), the height to blade-tip are confirmed at 145m (with no maximum or minimum heights inferred). To avoid any confusion, the ES should clearly demonstrate whether or not assessment of impacts is based on the ‘Rochdale Envelope’ whereby a series of projected maximum extents to the development are identified for which the significant effects are assessed. Currently, it is not clear that this is the case and that the chapters in the ES based their impact assessments on the maximum-case scenario e.g. were the nosiest turbines used for noise assessment, were the tallest used for landscape and visual assessment etc? Unless justification and rationale for the approach used in the ES is clearly highlighted, to enable CCW to fully assess the impacts of the scheme we will require precise details of turbine heights, blade length, and the base areas of the towers to be used and ask that the ES is consistent in its descriptions throughout. The onus for clarity where there are areas of uncertainty, with reasons for the uncertainty given, is confirmed in the Revised Draft National Policy Statement for Renewable Energy Infrastructure (EN- 3) at paragraph 2.7.22. 2.1 Paragraph 2.4 highlights the specific requirements of an Further information regarding alternatives has ES under Schedule 4 Regulation 2(1) of the Town and Country been provided throughout the ES, particularly Planning (EIA) (England and Wales) Regulations 1999. The second regarding access- both access tracks within bullet of paragraph 2.4 in your ES specifically highlights the need the site and the main access route to the site. for “…an outline of alternatives studied by the applicant and an As CCW is aware, we do not agree that there indication of the main reasons for the applicant’s choice, taking is a need for consideration of alternatives for into account the environmental effects. the grid connection route, which does not Notwithstanding that requirement, alternatives have not been form part of this application. In line with Policy explored or documented thoroughly throughout the ES and Statement EN-1, the IPC must be satisfied that justification for not considering alternatives has not been there are no obvious reasons why the necessary provided. This is particularly true in relation to the main access approvals for the grid connection are likely to into the site and the indicative grid connection, where alternatives be refused. The information provided within have not been fully examined or evidenced. We draw your the ES is intended to satisfy this requirement. attention throughout the text below to the specific examples where this issue has caused problems in advising whether impact Alternative wind farm sites have not been assessments are valid, particularly in relation to access routes assessed and there is no requirement to do (Annexes 7) and grid connection (Annex 14). so. Section 4.4 of EN-1 states that there is no requirement to consider alternatives. 2.2 Paragraph 2.4 bullet 4 states the need for “…a description Where not already completed, cumulative of the likely significant effects of the development on the assessment with Bryn Llywelyn Wind Farm environment, which should cover the direct effects and any has been completed (this information was not indirect, secondary, cumulative (our emphasis), short, medium, available when the draft ES was completed) long-term…effects of the development…” This is confirmed in paragraph 2.18. CCW considers that the cumulative impacts of the proposal in combination with existing, consented and other proposed developments and activities, has not been documented thoroughly in the ES, particularly in relation to: Traffic Assessment; Geology; Hydrology; certain aspects of Non-avian ecology; Public Access, Recreation and Socio-economics, and; Grid Connection. Further, it is questionable as to whether the cumulative effects that arise as a result of individual impacts of the scheme working in combination are adequately addressed in the ES. Again, we draw your attention throughout the text below to the specific examples where this issue has caused problems in advising whether impact assessments are valid. Brechfa Forest West Wind Farm Consultation Report 25

2.3 Paragraph 2.21 states that “RWE NRL is committed to Further and more detailed mitigation has implementing the mitigation measures identified in this ES.” We been discussed in detail with CCW and welcome such a commitment, but have concerns that presently Carmarthenshire County Council (CCC). mitigation measures for all impacts of the scheme are not been Following this further consultation and the fully addressed throughout the ES, particularly in relation to Public conclusions of these discussions additional Access and Habitat Management. CCW welcomed the opportunity mitigation has been proposed throughout to discuss some of these concerns further with you at our meeting the ES and in particular in the draft Habitat on the 30th March 2011, and we now look forward to seeing an Management Plan and Public Access appropriate level of mitigation detail included in the revised ES. Management Plan. We remind you that TAN 5: Nature Conservation and Planning sets out the minimum requirements with regards to the detail and commitments that we would expect to see in the HMP. CCW has a statutory duty to ensure that Wales’ natural heritage is safeguarded and promoted and we will therefore seek to ensure that the agreed mitigation measures are implemented fully through legally enforceable means. 2.4 CCW has serious concerns regarding the content of paragraph These concerns have been noted and the 2.24 which assumes that there may be information gaps in the terminology used within the ES has been baseline due to baseline information not being available. Every revisited and revised. effort should be made to establish the baseline conditions and explicit justification given if baseline conditions are not quantified or qualified. Adequate baseline information is a critical criterion in assessing any ES and failure to establish such information could result in a technically flawed EIA. 2.5 Paragraph 2.25 confirms that the ES does highlight where Noted. “potential technical deficiencies or lack of know-how have arisen”. However, it is CCWs view that whilst in general the quantification and qualification of baseline has been reasonably recorded throughout the ES, there are examples where baseline has not been accurately recorded and these are evidenced throughout this document. e.g. Public Access, certain aspects of non-avian ecology, the HMP, soils data. 3.1 Paragraph 3.4 describes the forestry activities. There is no No action- FCW have a wide ranging role that mention of Forestry Commission Wales’ (FCW) role in Brechfa covers many different topics. This paragraph to restore and maintain Plantation on Ancient Woodland sites does not claim to list all of these and therefore (PAWS). CCW suggest amendment of this paragraph to recognise it is not considered appropriate to particularly their role. mention PAWS restoration as an example. 3.2 Paragraph 3.9 references that there are 5 registered public PRoW registration numbers have now been footpaths within the site and numerous others around and out- included within the ES. with the site. CCW recommends the inclusion of the registration numbers of the PRoW trails in the ES for ease of reference. Scrutiny of an OS Explorer 1:25000 scale map also suggests that there is a possibility of a sixth (13/82) PRoW on the western boundary with the existing Alltwalis farm that deserves inclusion in the text. 3.3 The ES states at paragraph 3.27 that a number of options As above- more information on alternatives were considered in accessing the site for the delivery of turbine has been provided. In addition, the access components and other construction parts and machinery. report (as produced at an early stage in the However, these alternatives have not been clearly evidenced in process) has now been appended and further the ES. Further, the proposed preferred route, in our view, has information provided on the loss of trees/ unacceptable landscape impacts. Further comment regarding hedgerow at the site entrance. alternative access can be found in Annex 7 (Access, Traffic & Transportation) and Annex 14 (Indicative Grid Connection). Brechfa Forest West Wind Farm Consultation Report 26

3.4 Paragraph 3.29 provides detail regarding the length of A section describing the internal access track new and existing access tracks within the forest that require evolution has now been included within the ES. building or upgrading respectively. Paragraph 3.30 then gives the main objectives for the design of the track layout within the forest estate. The first bullet under this Paragraph states a main objective as being to “maximise the use of existing forest tracks where possible” and the fourth bullet states a further objective to “keep overall track length to a minimum to reduce stone requirements and associated potential environmental impacts (e.g. from borrow pit operation)”. However, if one inspects Figure 1.2 it is evident that there are - leading up to the proposed turbine positions – sections of existing forest track that appear to have been disregarded and new tracks proposed alongside these existing tracks instead. This is particularly evident around Turbines 3, 6, 11, 12, 22, 24, 26 and 28 and it appears that these existing tracks offer feasible connection to the proposed turbine location in question. CCW understands that these tracks may not be feasible to use because of topographical, hydrological or ecological constraints, or constraints caused by limits of deviation, however clear justification is required in the ES as to why these tracks have been deemed unsuitable to use. Again, this will help to give more confidence in the design evolution of the scheme. 3.5 Confirmation should be provided that all tracks have been RWE NRL can confirm that the DMRB is designed in accordance with FCWs Design Manual for Roads and incorporated into the Engineering Specification Bridges (DMRB) road specification document. provided by FCW that RWE NRL must adhere to.

3.6 We would welcome sight of draft details of any overtaking/ No action- RWE NRL is not able to provide passing place works on access tracks prior to submission of the this information at this time. It will be subject final ES. This will satisfy CCW that there will be no further impact to detailed design work by the principal on environmental receptors. contractor prior to construction. 3.7 CCW is concerned that limited consideration and information EAW have been consulted and have provided has been provided in relation to the use of Sustainable Drainage comments. Further information on SUDS has Systems (SUDS) throughout the ES. We recommend that further now been provided in the ES. advice is sought from the EAW on this matter. 3.8 Indicative construction works and the Construction Method Noted. Statement (CMS) should be directly interlinked with the Transport Management Plan (TMP), particularly in relation to measures needed to be taken to reduce pollution and its affect on natural heritage interests. 3.9 CCW welcomed the opportunity to discuss the draft CMS with Noted. you at our meeting on the 30th March 2011. Further advice and comments on the draft CMS are provided in Annex 13 (Draft CMS) 3.10 CCW considers that the inclusion of maps and diagrams that Plans showing the turbine layout iterations can be cross-referenced with Table 3.1, to illustrate the design have now been provided within the ES. evolution of turbines and associated infrastructure should be included in the revised ES in order aid examination of the schemes evolution and to ratify that the scheme has been modified under the iterative requirements of EIA. Brechfa Forest West Wind Farm Consultation Report 27

3.11 Paragraph 2.7.25 of EN-3, states that “Whilst it is for the Noted. applicant to specify the level of tolerance they are seeking, a tolerance of between 30m and 50m of elements of the required infrastructure is typical. However, there may be some circumstances where the IPC considers that the micrositing tolerance requested by the applicant is too great, and that on the evidence of the EIA and its own assessment of the proposal, that it is necessary to restrict either the overall tolerance for the scheme or the tolerance of specific elements of the proposal. When making this judgement, the IPC should take into account the reason for the applicant having requested the micrositing.” RWE need to be aware of the recent appeal decision by the Planning Inspectorate which dismissed 19 wind turbines at Mynydd-y-Gwair in Swansea. The decision letter makes reference to a micrositing tolerance of 30m being acceptable in the Welsh context. CCW is satisfied that the 50m micrositing tolerance requested by RWE is acceptable for this application. CCW is of a view that each case needs to be dealt with on its own merits. 4.1 Paragraph 6.7 - As the grid connection will also be dealt with No action- A review has been made of the by the IPC (or successor body), reference should also be made in relevant planning policy documents and this section to Revised Draft National Policy Statement (NPS) for this is not considered to be necessary as Electricity Networks Infrastructure (EN-5). this application does not include the grid connection 4.2 Paragraph 6.10, Bullet point 1 -This bullet point should also This amendment has now been made to the ES recognise that a number of exceptions exist to the IPC determining an application in accord with the relevant NPSs, as stated in the Planning Act 2008 and para 1.1.2 of EN1. 4.3 Paragraph 6.11, Bullet point 1 - Environmental Statements and No action- Having reviewed CCW’s request, we their content: We recommend that this bullet point is amended consider that the suggested wording provides a to read as follows: Environmental Statements and their content, level of detail that is not required where it states that ‘Where some details are still to be finalised the ES should set out, to the best of the applicant’s knowledge, what the maximum extent of the proposed development may be, and assess, on that basis, the maximum potential adverse effects which the project could have to ensure that the impacts of the project as it may be constructed have been properly assessed.’ 4.4 Paragraph 6.11, Bullet point 5 - Grid connections: We No action- Having reviewed the policy recommend that this bullet point is amended to more accurately document, RWE NRL are confident that the reflect the content of this section of EN1, and state that the wording accurately reflects EN-1 applicant ‘should provide sufficient information to comply with the EIA Directive including the indirect, secondary and cumulative effects, which will encompass information on grid connections.’ 4.5.1 Paragraph 6.22 Reference should be made to the following The suggested documents have been reviewed documents: One Wales: One Planet. The Sustainable Development and have been included as necessary Scheme of the Welsh Assembly Government -2009 TAN 5 Nature Conservation and Planning (2009) TAN 12: Design (2009) TAN 16: Sport, Recreation and Open space (2009) TAN 18: Transport (2007) 4.5.2 Paragraph 6.25 Planning Policy Wales - The reference to This has now been updated in the ES Planning Policy Wales and its respective paragraphs need to be updated in the ES to reflect the provisions of the February 2011 version of the document. 4.5.3 Paragraph 6.29 The Development Plan - Reference should This has now been updated in the ES also be made to Policy UT6 which refers specifically to Wind Energy and sets out the criteria that proposals for wind turbines will be expected to meet. Brechfa Forest West Wind Farm Consultation Report 28

5.1 It is CCWs opinion that all walk-over surveys need to be No action - Neither Cadw nor CCC have raised augmented with additional information to include historic maps this as an issue. On review, RWE NRL does not and aerial photographs. This is required in the revised ES in order consider that this is necessary. to ascertain the full impact on the Historic environment with particular reference to the impacts associated with the indicative grid connection. 5.2 Please see further advice and comments in Annex 12 Noted. (Landscape and Visual Impact Assessment) and Annex 14 (Indicative Grid Connection). 6.1 Paragraph 8.2 - Given that this states this chapter includes This has now been changed in the ES to soils, then we suggest that the chapter heading should read Geology, Soils and Hydrology Geology, Soils and Hydrology.

6.2 There is no mention here of any assessment of the peat or A peat survey has now been completed. The wider soil resource at this site: this will be an essential component details of the survey have been appended to of any ES in this context. Even if existing information suggests the ES and incorporated into chapter 8 of the there is little/no peat at the site, validation will be needed in the ES form of an original field survey. Further comment regarding this is given below at points 6.12-6.18. 6.3 Paragraphs 8.19 - 8.22 don’t appear to include any This amendment has been made to the ES. consideration of soil water, groundwater within peat etc, even though groundwater issues are identified in the key issues box under 8.3. CCW recommends that this is amended. 6.4 Table 8.2 seems to be incomplete: BAP priority habitats No action- RWE NRL’s specialist consultants do are not mentioned as such. Why should poor Water Framework not consider that this request is consistent with Directive (WFD) status, poor General Quality Assessment (GQA) EIA requirements. scores lead to a low sensitivity judgement? These are measures of current quality rather than inherent ecological, or conservation importance. CCW recommends that this is clarified and amended accordingly in the revised ES. 6.5 Figure 8.2 (appendix 8) provides only the most rudimentary Geology is based on British Geological Society impression of superficial geology – it does not appear to map geological mapping, the standard source for unit boundaries and paragraph 8.47 indicates no peat, although an ES. Peat survey has been completed to paragraph 8.53 in the ES later concedes that peat may be present supplement the desk based work. on higher ground in some areas. Please see comment under 6.2 above that a validation survey should have been undertaken, as well as further comments below. 6.6 We recommend that paragraphs 8.45 – 8.50 of the ES This amendment has now been made to the ES. specifically mention that there are no Geological Conservation Review (GCR) sites within the Potential Development Area. CCW confirms that there will be no impact on any protected geological sites as a result of the proposed scheme. 6.7 The ES does not consider the possibility that geological BGS have been contacted to ascertain current exposures of sufficient significance to be notified as Regionally status. Important Geological Sites (RIGS) are present within the PDA. The assessment of RIGS by the British Geological Society (BGS) in Carmarthenshire is currently in progress for the WAG. CCW advises that the BGS should be contacted prior to the finalisation of the ES to determine whether any of the existing exposures within the PDA have been evaluated. 6.8 With regard to the proposed reinstatement of quarried areas, As discussed with CCW at subsequent consideration should be given to the potential geological (e.g meetings, it is now proposed to make safe the opportunities for future research, education and public interest) quarry area but not to replant. and ecological (increasing biodiversity) benefits of leaving the excavations without re-instatement. Further comment is provided with regard to reinstatement in Annex 13 (Draft CMS). Brechfa Forest West Wind Farm Consultation Report 29

6.9 It is noted that Dinas Quarry in Llansawel has been identified No action- The environmental impact of as a potential source of roadstone, but the cumulative impact of extracting stone is covered in the relevant the working of this quarry has not been considered at all in this permissions held by Tarmac, the operators of chapter. CCW advises that consideration should be given in the ES Dinas Quarry. to the cumulative impact of working this quarry. 6.10 We consider that within the PDA there are opportunities for No action- RWE NRL do not accept that the geological recording and conservation that represents what is proposals presented by CCW are reasonable or considered as ‘best practice’. We would expect RWE to consider necessary. the proposal for geological recording as outlined below. 6.11 Excavations required by the proposed scheme have potential As above. to reveal new features of significance to geological science. We request that a watching brief is carried out, akin to the principles used where developments have potential to reveal archaeological interest, and details of this should be included in the ES. RWE will need to collate all records for existing trackside and other new exposures in Brechfa Forest West (e.g. BGS records arising from recent re-mapping at a minimum of 1:10000). The walk-over surveys for new tracks and those to be upgraded should include documentation (e.g. photographic recording, graphic logging) and sampling of any exposures not already described. Geological recording should be carried out during/after excavations along trackways, cable trenches, drainage ditches and turbine locations and also at the existing borrow pit and the roadstone quarry (Dinas Quarry) at Llansawel. All recording must be carried out by suitably qualified and experienced personnel (as evidenced by published papers in peer-reviewed scientific journals and experience of geological recording for rocks of the type found at the PDA and roadstone quarry). RWE would be expected to cover the costs of geological recording, however, grant aid may be available (e.g. through the Aggregate Levy Fund). 6.12 There is clearly some uncertainty as to the quantity and As above, a peat survey has been completed extent of peat on the site. In our scoping advice, CCW made clear and incorporated into the ES. that potential impacts of wind farm development on peat is a key concern to us. In addition to their high nature conservation value, peat lands are particularly sensitive to wind farm development. This is because construction and operation of a wind farm requires or results in drainage of water which alters the hydrology of peat in terms of the level of the water table, loss of habitat structure and subsidence of the peat surface. As a minimum, adequate consideration should be given to this habitat whilst assessing the environmental impacts of your proposal. Whilst, CCW does not envisage there to be significant infrastructure overlap with peat at this site, this should be clearly demonstrated in the ES. Currently, it seems that little weight has been given to the presence of peat and peat land habitats at the site and the consideration of these in the assessment of the impacts of the scheme. 6.13 Throughout Chapter 8 (and Appendix 5.1) there are The inconsistencies in the ES text arise from significant inconsistencies in the ES’ description of peat deposits. the different sources of information used. A These are outlined below. peat survey has now been undertaken to verify the desk based work. As described above the peat survey has been incorporated in to the ES.

6.14 Paragraph 8.47 states that “there are no (our emphasis) peat deposits shown within the site area. The geological mapping indicates that there is little (our emphasis) peat present in the general area around the site.” Brechfa Forest West Wind Farm Consultation Report 30

6.15 Paragraph 8.53 states that the “soils have a humose or peaty surface horizon in many areas. There are also some peaty topped, slowly permeable, seasonally waterlogged, loamy soils in the southern part of the site.” It goes on to say that “Peat may be present on higher ground in some areas. However, as indicated in paragraph 8.47, there are no peat deposits shown on the geological mapping for the area of the site.” 6.16 Paragraph 8.55 states that “Soils mapping obtained from the FCW indicates that there are no peat soils present on the Forestry Commission land within the site boundary. Peaty gley soils are present in approximately half the site. Soils descriptions were not available with the mapping.” The paragraph goes on to state that “However, a soils classification issued by the Forestry Commission Research and Development Division indicates that peaty gley soils may have a maximum peat thickness of 0.45m (our emphasis)” and that “peat overlies gley in the soil profile….” This paragraph clearly notes the presence of peaty gley soils in approximately half of the site and based on the classification system used by the FC (which lacks a formal reference) states these might support up to 45cm of peat. CCWs guidance on assessing windfarm impacts identifies soils of around 35cm as worthy of assessment. CCW is concerned that the presence of peat deposits across the PDA have not been adequately considered in the ES and that you have not demonstrated where potential infrastructure overlap on peat may exist. This means (i) that the current ES is unable to assess impacts to peat, (ii) that it is not possible to determine whether typical micro-siting conditions would be sufficient to avoid whatever peat might be encountered, and (iii) that RWE will not be able to demonstrate the extent to which scheme layout demonstrates avoidance of the peat resource. This should therefore be rectified in the final ES. We advise that a ground truthing exercise is undertaken (at turbine locations and along new access tracks) to satisfy CCW that impacts on peat have been adequately assessed and that this new information is captured in the revised ES. In the event that the survey reveals infrastructure overlap on peat deposits, you must ensure that these impacts are adequately avoided, mitigated or compensated for and that this is clearly evidenced and structured in the revised ES. This also needs to be sufficiently addressed in the HMP. CCW will be happy to advise further once additional information is submitted. 6.17 Paragraph 8.77 fails to address any impacts on the hydrology No action- There is no mention of peat in of wet soils and peat in particular. paragraph 8.77 as it is not considered to be impacted by construction 6.18 Paragraph 8.79 highlights that “…indications from available No action- FCW soils information is historical soils mapping, provided by Forestry Commission Wales are that and the background is unknown. It is not peat is only likely to be present on the site as an upper soil layer considered to be appropriate to include the overlaying gley soils…. As a result, the risk of problems associated detail from the FCW. with peat stability during construction of the scheme is unlikely to be a concern…”. CCW requests that any FCW soils mapping methodology and soils data utilised in the ES, is provided as an appendix to the ES before final submission to IPC. This will allow better comprehension of the quality of the previous mapping work and identify the true extent of the mapping undertaken, and further guide survey effort when assessing the presence of peat. CCW is concerned that soil descriptions are not available with the mapping. In our scoping letter, we advised that RWE utilise Cranfield University soils data. We note that this has been done and welcome this. Brechfa Forest West Wind Farm Consultation Report 31

6.19 To highlight the importance attached to peat bog habitat we No action- The situation at Mynydd y Gwair refer you to the recent appeal decision at Mynydd-y-Gwair, which is entirely different and the two sites cannot was based on the potential impact of the proposed development therefore be directly compared. (Note – this on peat bog habitat. There the minister concluded that “…the decision is subject to legal challenge and at at development as proposed raises the risk of an unacceptable the time of writing the Inspectors decision has degree of harm to the peat habitat which is sufficient to justify been quashed by the High Court.) refusal of this proposal...”. 6.20 Given the nature of the site, being mindful of NPSs EN-3 Peat survey completed and incorporated in to and EN-1, and the recent inspectors’ decision at Mynydd-y-Gwair, the ES. CCW advises clarification as to the extent of peat on the site should be provided in the ES. Rather than a peat assessment at pre-construction stage (as outlined at para 8.79), an assessment of potential peat deposits as detailed above should accompany the final application to the IPC. This would fall in line with NPS EN-3 which, at paragraph 2.7.38, makes direct reference to the consideration of peat habitat for onshore windfarm developments, stating “In addition to Section 5.3 of EN-1 there are specific considerations which should inform IPC decision-making where developments are proposed on peat. In these cases the IPC should be satisfied that the wind farm layout and construction methods have been designed to minimise soil disturbance when building and maintaining roads and tracks, turbine bases and other infrastructure. This is to ensure the development will result in minimal disruption to the ecology and that the carbon balance savings of the scheme are maximised.”

6.21 Further comment regarding peat deposits and carbon calculations can be found in Annex 16 (Carbon Calculations). 6.22 As highlighted in our scoping letter, CCW expects detailed EAW have been consulted by RWE NRL and advice and comment on hydrological issues to be sought from have provided comments the EAW, and that any counsel received regarding this draft ES is fully acknowledged and facilitated in the final application to IPC. The ES should demonstrate that robust pollution control & pollution contingency measures are in place during construction and operation. 6.23 CCW does have some initial observations and comments It has been stated that there would be regarding the content of the ES. Baseline data (e.g. discharge & monitoring of sediment content in any streams suspended sediment of streams and at outflow points, chemical and sediment and water quality in private water water quality, estimated rates of run-off etc) is not presented in supplies, which could be potentially affected the ES. Whilst CCW understands that this information may be held prior to, during and post construction, to check by EAW, we request that this information is also provided as an on any impacts. appendix in the ES presented to IPC. This will be essential in order It is not considered valuable to request existing to assess the effectiveness of the measures, as proposed in the ES, water quality data from the EAW to put in the to protect water quality and ecology from any detrimental increase ES at this stage. in suspended sediment and contamination. Characteristics of Regarding the hydrological regime it has groundwater flow in bedded and well-jointed sandstones (minor been stated that a ‘considerable effort will aquifers) in relation to possible windfarm impacts may need be made on site during construction to avoid investigation – chiefly in relation to resultant impacts to soil/peat disruption to features in the natural drainage water status and runoff. Chapter 8 needs to clearly set out the pattern, to ensure impacts are minimised. The hydrological regime that the development is seeking to achieve environmental specialist, appointed by RWE and outline how it will be managed over the lifetime of the NRL for the construction stage, will advise on scheme. maintaining areas of wet ground or open water fed by flows or seepages on the hillsides.’

6.24 In our scoping letter, we advised that consideration of No action- It is not clear what is wanted here physical changes on drainage patterns needed to be investigated that would be of use to the planning process at in both summer and winter conditions. It appears that this advice this time. has been ignored in the ES and we would recommend again that the ES clarify this point. Accurate description of baseline and existing conditions both temporally and spatially will allow broader comprehension of the natural hydrological regime at the site. Brechfa Forest West Wind Farm Consultation Report 32

6.25 Paragraph 8.67 discusses potential acidification of surface No action- Forest & Water Guidelines (Forestry waters in both the Afon Tywi and Afon Teifi catchments, as Commission, 2003) should cover this. Potential described by the Environment Agency’s River Basin Management acidification would be unacceptable so best Plan for the Western Wales River Basin District (December 2009). practice construction practices have been CCW considers the potential acidification (or sedimentation) of proposed. This comment appears to be any surface waters within the PDA unacceptable, and suggests proposing gain and insufficient justification is that serious consideration is given to further management of provided for this. riparian zones within the forest, alongside any pollution control measures that are enforced by EAW.

6.26 Paragraph 8.103, as considered under the Forest & Water Noted. Guidelines (Forestry Commission, 2003), further discusses acidification of surface water environments through the release of nitrates as a result of forest felling. We consider that this adds weight to the need to monitor such activities and that stout remediation and management measures must be put in place. This is particularly important to help minimise the risk on the features of the European designated Afon Tywi Special Area of Conservation (SAC) and Afon Teifi SAC.

6.27 Paragraph 8.167 lists groundwater impacts in relation to No action- EAW have not noted this point operation – construction impacts do not seem to have been in their consultation response and RWE considered at all. This section also fails to address impacts on NRL’s specialist consultants consider that peat. construction impacts would be less than or equal to impacts once the scheme is operating, so nothing has been added to the construction section. 6.28 CCW advises that RWE consider and submit a combined Noted- it will only be possible to produce such Water Management Plan (WMP) that will allow cohesion of a plan once the principal contractor is in place pollution control measures, flood risk and drainage measures with as they will be responsible for pollution control the CMS to ensure protection of water courses and associated measures. habitats and species. This will also assist the IPC in complying with its obligations under the Habitat Regulations. 6.29 It is suggested that a Hydrological Clerk of Works (HCoW) An environmental specialist will be appointed is appointed at the construction phase to ensure compliance of by RWE NRL to oversee the construction phase. monitoring measures and the delivery of the pollution prevention The specialist will be based on site during and response plan. The appointed person is expected to liaise construction. The specialist will ensure that closely with EAW, FCW and RWE and authorise and agree works all the proposed mitigation is planned and – this will be particularly pertinent at periods of heavy rainfall or undertaken to minimise or prevent impacts on when working closing to watercourses. the water environment. 6.30 It is noted at paragraph 8.211 that the ES states that the Cumulative hydrological assessment with Bryn details of the proposed Bryn Llywelyn wind farm were not available Llywelyn Wind Farm has been completed and is at the time of compiling the ES. The Bryn Llywelyn application is addressed in the ES. now available and has been submitted as a planning application to Carmarthenshire County Council (CCC). CCW therefore advises that the Bryn Llywelyn ES is considered in the assessment ofcumulative impacts for both geology and hydrology prior to submission of RWEs application to IPC. Full analysis of Bryn Llywelyn data should be undertaken and not merely a verification of calculations.

7.1 CCW reminds you that due consideration of alternatives is a Further information on access alternatives has requirement under Schedule 4 Regulation 2(1) of the Town and been provided in the ES as requested. Country Planning (EIA) (England and Wales) Regulations 1999. CCW suggests that further details on alternative access routes are required to help to inform the IPC. The onuses on the applicant in respect of these requirements are set out in EN-3 at paragraphs 2.7.76 - 2.7.78 and in EN-1 at section 4.4. Brechfa Forest West Wind Farm Consultation Report 33

7.2 Further information regarding the alternative access routes As detailed above regarding alternatives. into the site is required. Whilst alternative access routes from RWE NRL have investigated in some detail the A485 have been identified in the ES, there appears to be no the possibility of utilising the existing access detailed consideration or assessment of the alternatives. No clear for the Alltwalis Wind Farm. Unfortunately it rationale or justification is given for not using the existing Alltwalis has not been possible to reach a commercial site entrance access track located approximately 200m to the agreement with the landowner. In order to south of the proposed new track. The proposed new access track mitigate the issues raised by a range of groups would require creation of a new site entrance involving junction and individuals who have responded to the re-alignment works to accommodate sufficient swept path area consultation, screening is proposed to mitigate for turbine component delivery as well as road widening requiring landscape and ecological impacts associated landscaping and habitat mitigation. The Bryn Llywelyn proposal with the new access track. on Mynydd Llanllwni has identified the small council road from the New Inn Junction (SN472367) as a route onto the common and this could equally well serve your proposal. Whilst this track will probably also require some re-alignment works and translocation of hedgerows, the ecological and landscape impact of doing this could be less than creating a whole new access track. As highlighted in our scoping letter, CCW would encourage RWE to ensure collaborative working with other developers in the area and recommend that dialogue regarding the access tracks is had with the developer of the Bryn Llywelyn scheme and the existing Alltwallis scheme.. Further, the ES does not provide justification for the new access track as the preferred route. Clarification on this matter should be provided. 7.3 The configuration of a new 2km site entrance and associated Additional detail has been provided in the removal of a section of highway boundary would result not only in revised ES and mitigation proposed. ecological impact but also in local landscape and visual impacts. It is CCWs opinion that these impacts have not been fully assessed in the ES and sufficient mitigation has not been outlined. Further comment regarding these matters is given below in Annex 12 (LVIA) and Annex 15 (Offsite access works) 7.4 We note that concrete batching is proposed to take place It is not appropriate to produce a TMP until all off-site at (paragraph 9.58). CCW advises that a construction details are known. National Policy draft Transport Management Plan (TMP) is produced up-front pre- Statement EN-3, paragraph 2.7.82 states that consent and tightly linked to the CMS and WMP in order to ensure ‘Once consent for a scheme has been granted, pollution incidences are avoided. We expect any TMP to be drawn applicants should liaise with the relevant local up in agreement with CCC and their consultants. highway authority (or other coordinating body) regarding the start of construction and the broad timing of deliveries. It may be necessary for an applicant to agree a planning obligation to secure appropriate measures.’ RWE NRL consider this to be an appropriate approach for the Brechfa Forest West Wind Farm and have included a requirement to produce a TMP within the draft DCO. 7.5 Whilst transport and traffic issues are not strictly related to A dry run has been completed and the CCWs remit, we consider that a dryrun, pre-consent, along the associated report appended to the ES. entire length of the access route is imperative to ensure that no additional road widening works are needed and therefore no further impact on ecology (e.g. hedgerow removal) and landscape is to be expected. 7.6 CCW does not consider that the cumulative impact has been Traffic for Dinas Quarry and felling is adequately addressed in the ES. No consideration has been given considered in chapter 9 of the ES. The chapter to the cumulative impact with Bryn Llywelyn, Alltwalis and Brechfa has been amended to include cumulative East wind farms; the volume of HGV traffic extracting roadstone impact of Bryn Llywelyn Wind Farm. from Dinas Quarry, or with FCW felling lorries. Therefore the worst-case scenario as described in paragraph 9.142 has been underestimated. Cumulative impact is also missing from summary Table 9.10. We recommend that the ES be amended accordingly. Brechfa Forest West Wind Farm Consultation Report 34

8.1 As we discussed with you at our meeting on 30th March A draft Public Access Management Plan (PAMP) 2011, CCW is exceptionally concerned that the baseline for has been produced and discussed with CCW Public Access, Recreation and Socio-economics has been post consultation. It is appended to the ES. severely underestimated and that the impacts of the scheme are misrepresented. Moreover, mitigation for the impacts that have been identified are not provided in sufficient detail to give us confidence that they will be dealt with. CCWs advice remains that the issues surrounding the proposed management of public access during construction need to be adequately addressed. We have discussed with you the critical and urgent need to develop and agree a defensible Access Management Plan (AMP) that sets out how the impacts on the forest estate, as CRoW land also containing PRoW, can be adequately mitigated and managed and the area enhanced in the longer-term to offset the large negative impact that the scheme will have on public access users during construction, and also during operation. This approach will be consistent with the provisions of TAN8 (Paragraph 2.10). The individual requirements of each recreation group (e.g horse riders, mountain bikers, ramblers) will need independent consideration. Consideration should also be given to investing in improving the access network in the forest and surrounding area and the use of appropriate promotion and publicity. The AMP must be holistic with your Brechfa East proposal. We also advise that you consider CCCs Right of Way Improvement Plan (ROWIP) 2007 – 2017. We recommend that the appropriate parties to be involved in the development of the AMP are FCW, CCC, CCW, representatives of the relevant users groups, and yourselves. Should mitigating impact measures be a requirement (a condition of the consent order), then these shall necessitate the full agreement of FCW as land manager. We remind you that the FCW has a duty of care in relation to all users of the forest estate and, until a satisfactory AMP is in place, they retain full rights in relation to closure of their facilities. 8.2 Paragraph 11.3 refers to the desk studies undertaken to Lengths and maps of PRoW are included within collate the assessment information. CCW query why only a desk the ES. Due to the complexity of access points study and questionnaire were used to collate this information. We into the forest it is not considered that a recommend that you augment your baseline data by combining footfall count would be a productive exercise in desk studies with field visit data, data generated from a foot fall this case. count or ATC (Automatic Traffic Counters) at forest entrance sites. Whilst we appreciate that it can be difficult to gather data on user numbers on CRoW land (where access to the land can be at any point in the forest), we consider that further effort could have been applied to obtaining a more accurate baseline from which to work. Details of the lengths of PRoW that are being impacted and maps of the routes should be provided in the ES. 8.3 Paragraphs 11.17-11.20 - CCW questions why data from 2001 The chapter of the ES has been reviewed and and 2008 has been consulted? We consider that this data is old more up to date information provided where and not representative of the current population/usage. Is this the available. most up-to-date and representative information that is available? We recommend that this is amended in the revised ES. Brechfa Forest West Wind Farm Consultation Report 35

8.4 Further detail of baseline relating to tourism in the area is also As above required. Are there any figures relating to user/visitor numbers from further afield? The figures in paragraphs 11.21 & 11.22 need clarifying. The visitor figures do not appear to add up and there needs to be a direct relationship between the figures of South West Wales and Carmarthenshire. Comparisons should also relate to the same year. Discussions with the Visit Wales and local tourism agencies are recommended.

8.5 It is advised that further assessment is made of the proposal’s No action- This not considered to be necessary impact upon tourism as a socioeconomic resource. Considering or appropriate in this case. the content of paragraph 11.26, it is pertinent to comment that mitigation is critical to reducing the impact on local economy and businesses throughout construction and during operation. 8.6 Paragraph 11.29 states “…there are other PRoW in the vicinity A footnote definition of BOAT/ORPA has been of the site but not within the site itself, including OPRA and provided in the ES. BOAT.” This statement suggests that vehicular access is open to all. This is not the case - some individuals may have vehicular access as of right and others may be granted use by permission but there is no general vehicular access for the public and this should be made clear. 8.7 Paragraph 11.36 suggests that dedicated trails Northwest of This has been covered in the ES. could prove to be a greater draw to cyclists; this does not take into account the potential for a simultaneous wind farm development in Brechfa West and Brechfa East when these trails in the East could be closed at the same time. Cumulative impact needs to be assessed further.

8.8 We note that the proposed scheme does not achieve the There are no bridleways within Brechfa Forest separation distance between PRoW and turbines as recommended West. Information outlining proximity of in TAN 8 (Appendix C, paragraphs 2.25 - 2.27). The proposed turbines to tracks/ PROW has been provided in scheme also seems to overlook the British Horse Society’s the ES. guidance of a 200m exclusion zone from bridleways. In our scoping letter, CCW specifically expressed that this was to be considered when designing the scheme. Again, it appears that this advice has been overlooked. Information on turbines within 200m of PRoW and overlay figures 11.1-11.3 (Appendix 11) with the turbine layout indicating proximity from relevant footpaths, bridleways etc, should therefore be provided in the ES as currently, the turbine proximity cannot be accurately gauged. 8.9 Paragraphs 11.52-11.53 - To re-emphasise, CCW considers Further information has been provided that you have significantly underplayed the impact on public both within the ES and the Public Access access and you will need to consider each recreational user group Management Plan. Due to the nature of the individually in terms of mitigating for their impact. Any diversion FCW estate, it is not feasible that diversions of PRoW, promoted routes etc, should be of like-with-like quality will be like-with-like and like distance although and like distance to that from which it is being diverted. This efforts have been made to minimise additional needs to be agreed and confirmed in writing with FCW as land distance following subsequent discussions with owner, CCC as the enforcing body and CCW as statutory nature CCC/ CCW. conservation advisor. All mitigation needs to be strictly tailored in the AMP details of which need to be incorporated in the ES and delivered pre submission to the IPC in support of the wind farm application. The AMP and CMS must be closely linked. We suggest that the AMP is used as a tool to deal with impacts and mitigation in a strategic and focussed way. We advise that a programme of monitoring is adopted and delivered in the AMP, and that in light of the monitoring results a review the management/mitigation of the impacts using the best evidence will be required. 8.10 Paragraph 11.54 - CCW suggests that barriers and fences will This is covered in the PAMP be needed and appropriately installed to control H&S on site. Brechfa Forest West Wind Farm Consultation Report 36

8.11 Paragraph 11.56 - There will be a need to sign routes well This is covered in the PAMP. before users reach the construction area if the continuation of the route is restricted.

8.12 Paragraph 11.64 needs to be amended to state that a Cumulative impact assessment with Bryn planning application has been submitted for Bryn Llywelyn and Llywelyn has been included in Chapter 11 of not that it is at scoping stage. It also needs to be considered the ES. in the cumulative impact assessment for this scheme as well as Alltwalis. CCW encourages RWE to discuss their proposal with RES to consider how all parties can engage in collaborative working. Consideration also needs to be given to the fact that access at Brechfa East may also be affected, as you have stated in the ES that there is a likelihood that the two developments could coincide with each other. This will need to be reflected in the AMP. 9.1 It would be useful if maps relating to modification and As above- comment 3.10 evolution of the scheme design were provided as an appendix to the ES. 10.1 This chapter is difficult to follow because the information Cross referencing in this chapter has been for each topic is spread across so many separate small sections, revisited. with some of it appearing to be relegated to the HMP rather than considered fully in the actual ES. Where cross-references are made between chapters they should refer to the specific paragraphs or sections containing the relevant information, not the whole chapter or appendix. The reader is frequently referred for details to a different chapter or document. We have attempted to comment on the information presented and for ease, we have addressed the main issues of this chapter by topic (habitat or species); but, it is likely that additional issues will be identified once more detail is provided in a revised draft. Overall, it is considered that there is insufficient information of relevant biodiversity enhancement within the ES. Mitigation has not been adequately considered and insufficient mitigation proposed. We expect all mitigation to be addressed fully in the HMP. Further comments are provided herein and monitoring requirements are addressed under Annex 17 (Draft HMP). 10.2 Paragraph 13.26 references TAN 8. CCW considers that the Noted. ES fails to recognise fully the opportunity for enhancement of the site. The application should be demonstrating a net gain for biodiversity. TAN 5: Nature Conservation and Planning confirms this principle stating that planning applications should seek for a development to provide a net benefit for biodiversity conservation with no significant loss of habitats or populations of species, locally or nationally. 10.3 The footnote at the base of the page relating to paragraph Additional Phase 1work has been completed to 13.8 notes that a 110m stretch of the new track and the cover the access track. substation located in the south east corner of the site, were not subject to a full Phase 1 habitat survey, rather the data was collated using local field information. Justification should be provided in the ES as to why this is the case. Further, no information is provided in the ES as to what constitutes ‘local field’ and what assessment methodology was employed. CCW reminds you that Phase 1 survey information is an important baseline and this information should be provided in the ES. 10.4 Although the ES states that the 110m stretch area is This has been clarified on the plan. distinguished on the Phase 1 habitat map, it is not evident on figure 13.4 (Appendix 13). This area needs to be clearly highlighted on the phase 1 habitat map. Brechfa Forest West Wind Farm Consultation Report 37

10.5 Paragraph 13.47 notes that pre-existing botanical and fungi The text in the ES has been updated to reflect records exist. It must be noted and amended that Hypocreopsis the additional information on bryophytes. rhododendri is the only record for this UK BAP species in Wales, not just in Carmarthenshire. 10.6 Several of the bryophyte species highlighted in Table As above. 13.10 are not actually of local importance: they have been wrongly flagged by WWBIC as of regional importance in west Wales based on a list of species of county importance in Pembrokeshire. The RDB 1 status of Orthotrichum striatum is an NBN/Recorder mistake. The key species are those marked as RDB2, plus Plagiochila exigua and Frullania fragilifolia. All except for Sphagnum flexuosum are restricted to ravine habitats and are therefore, with the exception of comments under 11.7 relating to paragraph 13.252, unlikely to be impacted in CCWs opinion. S. flexuosum is distant from any turbines. Borrow pits also hold colonies of Dicranella subulata (Carmarthenshire rarity) [SN488336], Campylopus subulatus (RDB2) [SN488336 & SN479325], and Pohlia bulbifera (Carmarthenshire rarity, only 2 Carmarthenshire sites) [SN479325]. Translocation, as suggested in mitigation, should be an acceptable approach for these species. CCW understands that the documented mistakes in table 13.10 are not a fault on RWE’s part, but recommends that the table is amended to provide the correct information. We would be happy to discuss this error with you further.

10.7 Paragraph 13.48 - Bryophyte recording subsequent As above to your consultant’s (LUC) request to WWBIC has revealed additional bryophytes of local and national interest in small quarries in the area. These need to be documented in the ES. These are Campylopus subulatus (RDB2/Nationally Scarce), Dicranella subulata (Carmarthenshire rarity) and Pohlia bulbifera (Carmarthenshire rarity). 10.8 Considering paragraph 13.250, CCW has major concerns for Following discussions with CCW, it is now bryophyte communities with the loss of 0.15ha of quarry habitat. proposed that full restoration of the quarry will Two of the species mentioned above under 10.7 (Campylopus not take place and it will not be replanted with subulatus and Pohlia bulbifera) grow in the quarry at the head trees. of the Afon Pib, and the Campylopus is scattered elsewhere on the site on the older forestry tracks. Both species are pioneers, but Pohlia bulbifera needs very damp conditions as provided by flushing in the quarry floor. It has not been found anywhere else in the Brechfa Forest area despite considerable searching, and it is likely to have remained in the Afon Pib area since before afforestation (judging by the presence of the quarry on 19th century maps). CCW is confident that translocation of these species should work well, if performed correctly. Brechfa Forest West Wind Farm Consultation Report 38

10.9 Paragraph 13.252 discusses the upgrading of existing Additional information has been presented in culverts on site. CCW is concerned about crossing W001 (Figure the revised ES. 1 Appendix 8.2) at the head of the Pib. This has a potential negative impact on bryophyte communities within the stream through significantly increased scouring, although the known hotspot around the waterfall is at least 1km distant and may well not be impacted. We strongly advise further consultation with CCW regarding this matter and in the interim request that you detail every measure that will be taken to minimise pollution and additional silt inputs to the Afon Pib at this point. We expect to be consulted alongside EAW in this instance. Further to the above, we suggest that the photographic illustrations in Figure 1 (Crossing W001) (Appendix 8.2) are retaken, particularly the photograph looking downstream, as they do not do justice to what is in reality, quite a steep drop. A photograph looking at the existing culvert upstream would also be helpful. Crossing W002 as represented in Figure 2 (Appendix 8.2) requires confirmation of its presence. Currently it is only ‘assumed’ to exist. Merely assuming its existence has the potential to alter the ESs conclusions regarding hydrological mitigation if its existence is not confirmed. CCW suggests further dialogue with EAW on this matter. 10.10 Under paragraph 13.255, the risk of bryophytes loss is very As above for bryophytes low for the species tabulated in 13.10, but high for those in 10.7 above. This needs to be re-considered and reviewed with CCW. 10.11 Mitigation at 13.281. CCW is satisfied that this is Noted acceptable. Translocation is likely to work for the two key species involved, Campylopus subulatus and Pohlia bulbifera, unlike most bryophytes. Nonetheless, CCW expects that a competent bryologist who is able to accurately record and identify (ID) the species involved to be appointed. He/she will need to consult and liaise with the county bryophyte recorder, who can suggest what key species should be assessed and advise on ID features, as the ES was prepared with data from the LRC that predates any recording in the quarries. The appointed bryologist will need to be fully competent. 10.12 CCW considers that the methods, timing, spread and effort Noted. of survey work undertaken are generally adequate and that the assessment covers the site comprehensively. It is evident that the survey methodology evolved over time and in the light of ongoing practice in the field. 10.13 We are pleased to see that the transect surveys have Noted. involved substantial effort in recording bat behaviour at different heights, particularly ‘at-height’ behaviour. 10.14 We are concerned however, that the survey design does not Further information provided in the ES/ HMP appear to have taken account of the bats’ potential vulnerability to collision with turbine blades, barotrauma and to the removal of forest edge. We recommend that this data is provided and addressed adequately in the HMP. Brechfa Forest West Wind Farm Consultation Report 39

10.15 There were some departures from good practice in the Further information and meteorological data is methodology for the transect surveys and further justification is presented in the ES required for these in the ES. CCW generally advises inclusion of meteorological data when assessing fully the impacts on bats, and as such we request that this information is provided to enable us to advise further on this aspect of the ES. The recording of temperature and humidity is standard practice for bat activity surveys as recommended in the Bat Conservation Trust – Good Practice Guidelines. The inclusion of this data should be used to cross reference with the results provided. 10.16 We recommend that a clearer map of roost locations in This map has been provided in the ES. relation to construction activities and infrastructure is provided.

10.17 Paragraph 13.260 mentions lighting in relation to any Stream corridors will not be illuminated. construction works scheduled to take place outside of the normal working hours 07:00 – 19:00hrs. CCW advises that stream corridors should not be illuminated around peak activity times for bat species. The same applies to otter and badger.

10.18 CCW suggests that in respect of monitoring of the wind No action- It will not be possible to include this farm on bats the proposed scheme be also included in a DEFRA as a condition as the timing of the wind farm led study to identify whether the expansion of wind farm construction/ operation is not clear and may development will pose a threat to maintaining UK bat populations not correspond with the DEFRA study. Such a at a favourable conservation status. We would welcome the condition would also not be necessary as the chance to discuss this with you and your consultants as a possible ES concludes that there will be no significant condition of any permission your authority may wish to issue. impacts on bats. 10.19 Under the Conservation of Habitats and Species Regulations Clarification and further information has been (2010), the potential otter shelter identified under paragraph provided in the ES. 13.261 which is sited approximately 115m from the access track between turbines 9 and 10, may be considered as a resting place. Paragraphs 13.261 - 13.263 have not considered the impacts of disturbance or noise on the otter population. Whilst preliminary precautionary measures have been identified in 13.287 and 13.288, we consider that the aforementioned impacts may be significant and that the impacts as outlined in the ES have been underestimated and not been adequately addressed. Further, there is no mention of disturbance buffers in the ES. CCW advises RWE that if the works are likely to result in contravention of the Habitats and Species Regulations (2010), then it may be necessary to obtain a WAG licence for the works. If a licence is required a method statement considering otter disturbance should be detailed as part of the ES. 10.20 Paragraph 13.172 relates to the assessment of habitat No action- The assessment was of habitat suitability for red squirrel. A second assessment should have suitability for red squirrel, not a presence/ been performed in May- August because of the two peaks in the absence survey, Therefore a second assessment breeding season for this species. Further clarification should be was not needed. Grey squirrel control is not provided in the ES in this regard. Consideration could be given to considered to be appropriate. grey squirrel control as a means of mitigation.

10.21 CCW is generally satisfied with the mitigation and Noted management of proposals outlined in relation to badger. However, it must be made clear that work must stop immediately and CCW is to be contacted if an active sett is found during construction. Please see further comments under Annex 18 Brechfa Forest West Wind Farm Consultation Report 40

10.22 Paragraph 13.53 notes a small area of Japanese Knotweed Noted. in the southwestern corner of the site, as a controlled non native invasive plant species under the Wildlife and Countryside Act (WCA) 1981. CCW welcomes the acknowledgment of its presence and the necessary management measures required to control this species. We do advise however, that RWE contact EAW immediately to determine if a license is required for removal or movement of any soil/rubble contaminated with the species. Please see further comment under Annex 13 (Draft CMS) and Annex 17 (Draft HMP). 10.23 CCW advises that due consideration must be given to the No action- No Himalayan Balsam was recorded eradication and/or control and management of Himalayan Balsam during field survey therefore no further action on the site, during construction and operation. The presence of is proposed. this species, as listed under the WCA (1981) must be considered and reported in the ES. 10.24 In our scoping response we advised you that consideration An Habitat Regulations assessment is a must be given to ensuring that any potential damage to the required document for an IPC application and European designated sites i.e. Afon Teifi SAC and Afon Tywi SAC is therefore a standalone document has been prevented. There appears to be no reference to a HRA assessment produced. in the ES that would satisfy the IPC that the proposed scheme would minimise impacts on these designated sites and their features. As we discussed at our meeting on the 30th March 2011, you will need to provide enough information in support of the NSIP application to enable the IPC to meet the requirements of the 2010 Habitat Regulations with reference to the conservation objectives for all the features for which the site is designated. The suggested Water Management Plan referred to in para 6.8 above could play a significant role in this process. Additionally, you are advised to refer to FCWs guidance produced in relation to European Protected Species (EPS) in Wales. This information can be found on their website. 10.25 Paragraph 13.238 states that no detrimental impacts are The Rhos-wen Pond will be included as a predicted on the Rhos-wen Pib Conservation Pond. CCW notes separate topic within the draft Construction however, that the Rhos-Wen pond is located close to the proposed Method Statement- detail to be provided by the borrow pit and access track around the pinch point of the Afon principal contractor. Pib along which all construction activity will be passing. This area is a pinch point for the scheme in relation to vehicle movements and borrow-pit extraction. As such, it is advised that the Rhos-Wen should be examined closely within the CMS to ensure adequate and robust pollution control measures are in place during construction. Brechfa Forest West Wind Farm Consultation Report 41

10.26 Table 13.30 highlights the habitats that are to be lost as a Further information and clarification is provided result of the proposals. Mitigation and/or enhancement should on this issue in the ES. be provided for the loss of all the Phase 1 habitats noted in table 13.30 regardless of the significance of impact noted in table 13.32. There are no mitigation details provided in the ES for the loss of: marshy grassland and scattered scrub; wet dwarf heath and wet heath/grassland mosaics, and; ponds. Some of these habitats are UK BAP habitats and listed under Section 42 of the Natural Environment Rural Communities (NERC) Act (2006). CCW reminds you that these habitats are a material consideration in the planning process, and therefore any loss of such habitats must be addressed in the ES and HMP and adequate mitigation/ enhancement measures identified. TAN 5 reaffirms the need to ensure net benefit for biodiversity conservation with no significant loss [our emphasis] of habitats or populations of species, locally or nationally. The ES should therefore clearly demonstrate avoidance of harm to UK BAP habitats and species where possible, and where harm is unavoidable it should be minimised by mitigation measures and offset as far as possible. Ideally the scheme should show betterment. If field survey for peat (as recommended above) results in the identification of peat areas, then this is likely to require some habitat re-classification, followed by evaluation and impact assessment. However, we strongly advise the avoidance of infrastructure overlap in the first instance. 10.27 Table 13.31 notes that 44 metres of species poor hedgerow As above is also to be lost. Mitigation is required to be included for any hedgerows/tree lines that will be lost in the PDA as a result of construction works. This must also be clearly referenced in the HMP. Further to this, CCW reminds you that any earth banks or hedgerows removed may have reptile interest that will also require assessment under the relevant guidance with details of the necessary mitigatory management provided. 10.28 Paragraph 13.251 highlights a field pond at SN46803380 The ES has now been clarified to reflect the supporting aquatic vegetation that will be lost to the proposal. fact that this pond will not be lost. There is no proposal to mitigate/compensate for this loss in the ES or HMP and this impact needs to be fully accounted for. Accordingly, a survey for amphibians will also need to be conducted prior to construction works and any amphibians detected will require translocation if necessary. 10.29 CCW considers that there is adequate provision for Noted mitigation and enhancement of the loss of these habitats, and that mitigation/compensation and monitoring of these habitats is fully achievable. This detail needs to form part of the ES and HMP. Brechfa Forest West Wind Farm Consultation Report 42

10.30 CCW notes that the 47m radius around each turbine will be Clarification has been provided by RWE NRL kept clear of conifer regeneration and scrub. Further clarification in the ES on this issue following further on a number of issues in relation to this should be provided discussions with FCW/ CCW/ CCC in the ES. How will the area be kept clear? Will herbicides be used? Precautions must be put in place if so and FCW guidelines adhered to in consultation with CCW, EAW and CCC. The ES states at paragraph 13.244 that the regeneration is likely to be marshy grassland. We do not consider that the ES appears to have considered the in-combination impacts of this when examining impacts on species. For example, creating marshy grassland around the base of turbines will naturally attract and encourage associated invertebrate communities, which accordingly, will attract ornithological and bat interest around the turbines. As a direct result of this, such species may be more vulnerable to direct collision risk, noise impact and/or barotrauma. Whilst we would normally applaud the principle of creating marshy grassland regeneration, the 47m buffer around turbines is not an appropriate receptor for this type of habitat. We advise that appropriate and stringement management of these areas must be clearly outlined in the ES and detailed as part of the HMP. CCW would welcome further discussion regarding the management of the areas around turbine bases prior to submission to the IPC. 10.31 Paragraph 13.276 describes measures for offsite It has been clarified in the ES/ HMP that PAWS enhancement and states that offsite mitigation will be delivered restoration is presented as gain, not mitigation. through the restoration of Plantation Ancient Woodland Sites Further detail has been provided. (PAWS) within the wider Brechfa Forest Area. This is unreasonable. CCW suggests that PAWS restoration is strictly gain/additionality and not mitigation/compensation for an impact on PAWS - which is not significantly impacted by the scheme’s proposals. Moreover, CCW is led to believe that PAWS restoration is a project that FCW will be undertaking regardless of the wind farm development. We stress that this cannot therefore considered as mitigation or compensation for the impact of your proposed scheme. This needs to be strictly understood and the ES and HMP amended to reflect this. We would be happy to discuss this with FCW and you further and consider feasible alternative mitigation for the scheme as outlined in the HMP and 11.5-11.30 above. 10.32 The Bryn Llywelyn ES is now in the planning system and Cumulative assessment with Bryn Llywelyn available for your consideration and refinement of the cumulative Wind Farm has now been included in the ES. impact conclusions outlined in your ES. Clear consideration of this should be provided in a revised draft ES or that submitted to IPC.

10.33 The ES should provide firm commitment that all relevant Wording has been clarified in the relevant surveys for species and habitats will be fully considered and sections of the ES- chapter 11 and in the undertaken prior to decommissioning. This needs to be cross- HMP. A requirement is also attached to the referenced in the revised HMP and discussed with the working draft Development Consent Order requiring a group at the appropriate time. decommissioning statement to be agreed with the relevant authority prior to decommissioning taking place.. 11.1 CCW is satisfied that the ornithological assessments and Noted. conclusions in the ES are sound, sufficiently detailed and that adequate regard has been given to all the potential impacts of the proposed scheme. Other than nightjar detailed below, there are no major ornithological concerns. Brechfa Forest West Wind Farm Consultation Report 43

11.2 With regard to nightjar, CCW agrees with the ES’s conclusions Noted. (paragraphs 14.64-14.66; and 14.94-14.102, 14.125 and in Appendix 14.6 and its Confidential Annex) that there may be a negative impact due to noise disturbance. Nightjar is a UK BAP priority species and is listed in Section 42 of the NERC Act (2006). We welcome the intention to undertake monitoring to examine any such impacts and, in the event that an impact is detected, to implement monitoring and appropriate mitigation. 11.3 Nonetheless, CCW reinforces the need for adequate, Further to comments provided in this response appropriate, detailed and robust postconstruction monitoring and subsequent discussions, this section has in years 1,2,3,5,10,12, and 15 (that is comparable to pre- been updated in the HMP. construction survey results), that not only looks at the distribution of churring males, but also attempts to collect information on productivity. Monitoring will need to be agreed in writing with the Habitat Management Plan (HMP) working group. 11.4 We welcome the intention (as outlined in the ES and draft No action- In discussions that have taken place HMP) to make areas around the turbines unattractive/unsuitable post consultation it has been concluded that to nightjar. However, we advise that additional positive mitigatory the appropriate opportunity for lobbying for management of alternative habitat, adjacent to the wind farm site, additional nightjar habitat is during the Forest should also be provided – focussing on the creation of suitable Design Plan review process. breeding and feeding habitats away from the turbines and the PDA. We would welcome the opportunity to discuss this further with you, in agreement with FCW. 11.5 CCW also advises that if monitoring indicates birds in the No action- This will be considered only if vicinity of the turbines at the start of the breeding season, that monitoring indicates negative impacts are RWE consider targeted feathering of certain (specific) turbines at present sufficient to warrant this mitigation. dawn and dusk at key times of the year. 11.6 Co-ordinated monitoring that specifically focuses on This is something that could be considered the unresolved issue of noise impacts on breeding nightjar subject to whether other projects go ahead. is recommended through collaboratively working with other windfarm developers in the area on whose sites potential nightjar impacts have been identified. 11.7 Whilst CCW agrees with the conclusions of your initial A cumulative assessment with the Bryn cumulative assessment with Brechfa Forest East, the Bryn Llywelyn Llywelyn Wind Farm has been added to the ES. ES is now available to consider cumulative impacts fully. We advise that you consider their data and update accordingly any further cumulative impacts. Nonetheless, CCW has undertaken a crude assessment of impact and considers that the only impact which may have also had a cumulative effect was breeding nightjar. However, these are not identified as a major issue in the Bryn Llywelyn ES, so we are satisfied that there are unlikely to be any significant adverse ornithological cumulative impacts with Brechfa West and adjacent developments. We suggest however, that you confirm or refute this through evidenced consideration of the Bryn Llywelyn ES.

12.1 CCW welcomes the assessment of LVIA impacts as provided Noted in the ES and has reached reasonable conclusions on the basis of the information presented. From an LVIA point of view, the design of the proposed scheme appears to have been a serious consideration from the earliest stages of scheme development and the process used is transparent. The ES is unambiguous in its explanation of the evolution of the site design, from a description of design reviews to determine the preferred site selection within SSA G, and micro-siting matters in relation to turbine locations in particular. Brechfa Forest West Wind Farm Consultation Report 44

12.2 We note however, that the individual grid references for Turbine coordinates have been provided in the the locations of the proposed turbines and height data for each revised ES turbine base have not been included. Whilst the absence of this information would not have a bearing on whether or not the landscape and visual effects are predicted to be significant, and we assume that this information would be subject to confirmation in relation to the micro-siting provisions to be requested, we do ask that the preliminary data is appended to the ES as a table, prior to submission to IPC. 12.3 The ES states at several points, that the access to and within Noted the site will require the Construction of approximately 9.1km of new onsite access tracks and the upgrading of 12.7km of existing access tracks” respectively. As aforementioned in Annex 7, the proposed access track into the site is via a new track to be constructed abutting the A485 at a point approximately 1.1kms to the south of Gwyddgrug village. This route would traverse open farmland for a distance of approximately 2kms until it reaches the edge of the existing forestry to the west of proposed turbines numbers 13 and 18, where it would link with the existing forestry access track network. Except for the 2 kms of new access track connecting to the A485, the remaining 7.1 kms of new track would be constructed within the forestry itself. Paragraphs 3.31 and 3.32 provide details of the proposed dimensions and surface treatment of the access tracks as follows: “New tracks and existing tracks (once upgraded) will have a typical minimum running service width of 5m on straight sections, with wider curves at bends and bellmouths. The total width of access tracks will be 7m taking into account 1m shoulders on either side, and the 7m width will be surfaced with crushed stone. Although the running width of the tracks will be maintained, natural, non-woody vegetation growth will occur on the verges and on cut or fill slopes and managed as such.” CCW considers that these measures demonstrate that the minimisation of land take for access track construction - with the consequent reduction in potential landscape and visual impacts - has been given due consideration in the scheme design. 12.4 However, CCW is concerned that despite the ES being explicit Screening mitigation has been added for the in wishing to minimise landscape impacts, the local landscape access track (see chapter 13 and chapter 15 of and visual impact in relation to the new access track appears not the ES). to have been assessed properly in the LVIA chapter of the ES. It is evident from the data presented in the ES that the new access track that will result, which will be surfaced in freshly quarried stone, will be highly visible in even medium and distant views from the west and north west until the surface material darkens through natural weathering processes. CCW therefore requests that additional landscape mitigation measures are considered in this regard. Given the access tracks exposed and relatively high elevation, mitigation could include the local realignment of some sections of the track in relation to topography and the planting of sections of field boundary hedgerows with improved grassland, grass banks, trees or narrow belts of woodland to assimilate the track construction into the local landscape. CCW is led to believe that the access track into the forest crosses a section of land under a section 106 agreement with the objective to reduce grazing. We suggest that you will need to consider the requirements of this s106 when drawing up further mitigation for this track. Further, the inclusion of an assessment of alternative access track provisions - including an appraisal of whether a shared use of the existing access to the operational Alltwalis wind farm or the proposed Bryn Llywelyn wind farm could mitigate the predicted landscape and visual effects - should form an integral part of additional assessment, which is an omission from the ES. Brechfa Forest West Wind Farm Consultation Report 45

12.5 Further to the above, CCW reiterates that consideration must A dry run has been completed and the report be given to performing a dry-run of the route to ensure that no appended to the ES.. further road widening works are to be undertaken and therefore no further landscape and visual impacts are to be expected and mitigated for. 12.6 Despite the reservations outlined in 3.4 regarding the Noted optimum use of existing tracks, the decision to make use of the existing forest access tracks as outlined in the current design, to serve the construction and operation of the proposed wind farm has also allowed the locations of the construction compound, borrow pits, crane hard-standings, the permanent anemometry mast and the proposed on-site electricity substation all to be accommodated within the confines of the existing coniferous forest plantations. CCW welcomes this. This has the advantage of minimising the landscape and visual impacts of such features, even when the tree felling to accommodate such works has been allowed for. 12.7 Appendix 3.2 provides details regarding the indicative grid No action. As CCW are aware, we disagree connection from the proposed on-site sub-station which notes with the proposals they have presented that “…the grid connection will be subject to a separate planning for assessing grid connection and the grid application to the IPC (or subsequent body) under the provision of related works. This disagreement is based on the Planning Act, submitted by Western Power Distribution.” a different interpretation of the guidance and We have concerns that alternatives have not been addressed as what is required. part of this ES. We also question whether the substations (as indicated in the ES) are located in the most appropriate positions bearing in mind that consideration of alternative routes has not been provided. Further comments regarding grid connection can be found under Annex 14 below. 12.8 CCW notes that the content of the assessment in Appendix As above 3.2 is described as being a “high level assessment of the indicative grid connection route”. CCW considers this term to be misleading, in that it could be construed that the assessment contains a high level of detail. In fact, it is confined solely to a desk-based study and analysis of geographical information systems (GIS) data, which are used to make an assessment of the predicted impacts upon landscape character. It provides little in the way of visual impact assessment and so cannot be regarded as comprehensive. We refer you to look back at our scoping letter of June 2009 that specifically requests detailed consideration of landscape and visual impacts of grid connection and associated development in your ES appraisal. CCW requests clarification as to why the visual impacts appear to have been ignored in your assessment of impacts. Brechfa Forest West Wind Farm Consultation Report 46

12.9 The base map of the indicative grid connection route As above provided in appendix 3.2 is barely legible, such that it is very difficult to identify the names of settlements or features and so to plot accurately the line of intended route. The width of the graphic representation used to delineate the route does not vary, so we can only conclude that this is not a defined route corridor but the line of a single preferred route. We have serious concerns that a grid connection route corridor should be identified and then subject to a rigorous visual assessment, as well as a landscape impact assessment. This is to ensure that the impacts upon the amenity of local residents and upon recreational users of the A40 trunk road travelling through the Tywi valley, recreational travellers in the Cothi valley, and upon important historic landscape features and visitor attractions - such as , , Aberglasney Gardens, Paxton’s Tower and Gelli Aur Country Park, Golden Grove - are minimised. This would require the indicative route corridor to be subject to a detailed LANDMAP study - to at least Level 3 - of all five constituent Aspect Area data sets, so as to arrive at a valid establishment of baseline landscape character. This information is missing in the current ES. CCW requires inclusion of it in a revised ES, so that it can be used to form the starting point for assessing the predicted landscape and visual impacts of the grid connection corridor, with a view to informing the identification of the line of the preferred route. 12.10 CCW concludes that the ES is therefore technically As above incomplete in this regard. Your proposal clearly cannot function without the required grid connection, and the proposed or ‘likely’ grid connection is not the subject of a current application by yourselves; nor is it under full consideration of its predicted impacts within this ES. It is evident that this grid connection assessment has been included to satisfy a high-level planning requirement. However, perversely it appears that the guidance in EN-1 and EN-5 has been ignored. Further commentary is provided in annex 14 below 12.11 We note that the indicative grid connection is to be carried As above on overhead lines strung between wood poles. These would be more recessive elements when compared with the larger steel lattice towers which might have been proposed to carry this voltage, but they would still have an intrusive potential if their ‘trident’ frame supporting the insulators is to be constructed with a galvanised metal finish. This material can be very reflective in certain harsh lighting conditions, such as in winter in bright sunshine, when there is a low angle of sun and there is minimum screening effect afforded by vegetation. This reflective effect can persist for a long period until natural weathering processes reduce the reflective qualities. CCW feels this to be an important visual impact issue which needs adequately assessing. Mitigation potential for altering the colour and finish of these frames in visually very sensitive locations must be considered when submitting a revised application to IPC. Further information will be provided when we are in possession of more detail and a revised draft. 12.12 CCW considers that the LVIA approach adopted in the ES is All comments regarding Landscape and Visual broadly consistent with current best practice and widely-accepted methodology and assessments have been national guidelines published in relation to the assessment of reviewed and appropriate action taken within landscape and visual impact. The ES refers to LANDMAP data, and the ES- please refer to ES chapter for details the broad national scale Landscape Character Map of Wales. Brechfa Forest West Wind Farm Consultation Report 47

12.13 Paragraph 15.53 describes the relationship between Noted. magnitude of change and sensitivity that results in the landscape or visual effect. Whilst the definitions are generally reasonable, we consider that the Landscape Character Sensitivity may potentially mislead assessments resulting from infrastructure or access roads for example, by only referring to change brought about by the wind turbines themselves. There is a matrix of significance, and this assists in providing a transparent assessment of significance. We note that significance is defined in terms of the EIA Regulations, and that both ‘major’ and ‘moderate’ impacts are ‘significant in EIA terms’. 12.14 The ES correctly describes LANDMAP and defines the five Previous correspondence with CCW outlining Aspect Areas. The ES illustrates all five of the LANDMAP Aspect RWE NRL’s position on this issue is included in Area data sets for Carmarthenshire, and these are detailed in the revised ES. Figures 15.4 -15.8 (Appendix 15) - although we note that thematic maps to illustrate evaluation of the aspect areas, as recommended in our LANDMAP Guidance, are not provided. Furthermore, these are only provided within a study area of 10km – this is less than the original CCW LANDMAP Guidance recommends. 12.15 It is CCW’s view that there may be ‘likely significant effects’ As above at a distance of greater than 10km. Significant effects have been assessed by the ES LVIA at viewpoints at distances of 12 and 13km and, in this respect, the LANDMAP data in the ES does not meet the above recommendations. However, we recognise that they are in line with the response provided by the local authority as outlined in their scoping response in September 2009 (Appendix 2.2). Nonetheless, a letter to you dated 27 January 2010 in response to a LVIA methodology query, clearly set out the key issues detailed in our LANDMAP Information Guidance Note 3 (November 2008, revised February 2010), which states “As wind turbine developments may influence the landscape character and be visible beyond the immediate site boundary LANDMAP Aspect Areas at Level 3 should be considered for all five layers for the area defined by the site boundary and its immediate environs, which includes the affected and adjacent aspect areas. In addition, the whole area from which the development is visible where “likely significant effects” are anticipated should be included. This is deemed more effective in targeting analysis and interpretation of information (DECC, 2009) than a specific distance (radii) from the proposed development. The “likely significant effects” will be particularly determined by the sensitivity of the site and surrounding landscape, as well as the size of the turbines and their positioning”. We note that there is no reference to this letter in the appendix of the ES and request its submission. 12.16 Notwithstanding, we consider the LANDMAP to be well Noted presented and the key characteristics are described in sufficient detail, together with full descriptions and evaluations for the all 5 Aspects included in the appendices’. Furthermore, the ES assesses the impacts on these LANDMAP Aspect Areas within 10km of the site. 12.17 A detailed landscape character assessment (LCA) has not Noted been carried out. However, the ES describes the existing landscape within the study area with reference to all five LANDMAP Aspect Areas data at Level 3 and Level 4. Brechfa Forest West Wind Farm Consultation Report 48

12.18 We are led to understand that there is no Carmarthenshire No action- RWE NRL believe the Landscape LCA and that CCC are currently finalising their revised Special Character Map for Wales and the LANDMAP Landscape Areas. However, the LVIA does refer in detail to the data together provide sufficient data to inform Landscape Character Map for Wales, as illustrated in Figure 15.3 the baseline landscape of the proposed site. (appendix 15), and describes the ‘Cambrian Mountains LCA’ that the site falls within (Table 15.13). Unsurprisingly, this national scale assessment provides little relevant landscape data to inform the baseline landscape of the proposed site. We request that this is reviewed. 12.19 We note that the ES has included maps illustrating ‘Zones ZTV’s with smaller scales do not fit into the of Theoretical Visibility’ (ZTV) for the proposal - for hub height format of the ES due to the need to print and blade tip height within the 35km radius of the study area. on larger paper. The Landscape and Visual We note that the study area has been drawn from the centre of specialists do not propose to provide these as the development for the larger scale of assessment. The scale of standard as they are indicative only and will these ZTV plans is given as 1:275,000 (at A3). The SNH Guidance have limited use at smaller scales. recommends that, whilst this is sufficient as an ‘overview’, more detailed plans using an OS 1:50,000 base and copied at 1:50,000 or 1:100,000 are also produced. These have been provided for the 10km radius inner study area at a scale of 1:95,000 to 1;100,000 (at A3). We also note that the same approach has been used for the Cumulative ZTV. We request that the ZTVs are submitted at appropriate scale for IPC.

12.20 We endorse that, in line with the advice given in the Noted. Infrastructure Planning EIA Regulations, in respect of Regulation 2(1), and in line with best practice in the preparation of an EIA, as advocated in section 3.10 (Box 3.1) of the current edition of the GLVIA, that the LVIA states whether predicted effects are judged to be adverse, beneficial or neutral. The LVIA chapter also correctly identifies which impacts are considered to be significant under the EIA Regulations. 12.21 CCW viewpoint review For all viewpoints, the conclusions made by the LVIA specialists on behalf of RWE NRL have been revisited in the light of comments made by both CCW and CCC (which do not always correspond). The detail from CCW’s consultation response has not been included in this Consultation Report for brevity, but all comments have been reviewed and any amendments incorporated in the revised ES Brechfa Forest West Wind Farm Consultation Report 49

12.22 In spite of paragraph 15.20 which describes the objective of No action- On all photography occasions a creating a no-parallax effect, we believe that that the photographs fully levelled tripod with panoramic head used in the ES figures (Chapter 15; volume 3) tend to reduce the and high quality Digital SLR camera (Nikon vertical scale of the existing Alltwalis wind turbines wherever D70, Nikon D80, Nikon D3) with fixed shown when compared to the view seen with the naked eye. lens was used. The individual frames were stitched to form panoramic images using cylindrical projection and then aligned to the wireframe terrain (DTM) for each viewpoint. This is done to achieve the most accurate perspective in the wider stitched image without distorting the sizes of objects within the view. Additionally operational wind farms (including Alltwalis) were added to the DTM and the horizontal spacing and vertical dimensions of these turbines matched when visible in the panorama. For each viewpoint the photomontages and photography for print are shown at a 90 degree included angle - to provide a broader contextual view - and then at a 50 degree included angle which meets recommendations regarding image height and viewing distance as setout in the SNH Good Practice Guidance 2006 (Visual Representation of Wind farms). Where the Horizontal field of view is 50 degrees the images should be viewed, printed at A3, at 45cm from the viewers eye. At this distance the perspective in the printed image will most closely reconstruct the perspective of the landscape (and objects within it) as it appears from the viewpoint. It is the opinion of RWE NRL that the Alltwalis turbines are appropriately represented in the photographs presented within the ES. 12.23 We note that many of the ES Figures depicting VP No action- The lighting of the proposed assessment information demonstrate that the pale grey colour turbines for a montage is informed by both of turbines is effective in mitigating visual impacts when viewed the time of day the photography was taken against similarly coloured skies. However, CCW do not consider and the weather conditions. We always seek that this approach is consistent with the need for an ES to assess to accurately represent the appearance of the ‘worst-case scenario’. To do so would require you to show the proposed turbines within the photograph as effects of wind turbines being strongly lit by sunlight or in sharp taken (217 - SNH Good Practice Guidance), silhouette. The difference in perceived visual impact can be seen however if this results in turbines which by comparing the visual effects depicted at Figure 15.22.3 for are not easily perceptible we would use VP2 2.17 kms distant (Alltwalis) with those on Figure 15.23.1 at professional judgement to alter the direction VP3 2.21kms distant (Gwar-allt). At VP2, looking east, the turbines and/or strength of the lighting to achieve are front-lit, as if by a low angle of sun from the west but appear clearer visibility. Photography for Alltwalis more prominent. At VP 3, looking west, there is a lot of mid-grey was taken at 2:50pm (14.50) when the sun cloud cover against which some turbines are seen, others being was in a south-easterly direction resulting in in silhouette, but not strongly so. There are many more turbines front/right side lit turbines. The visibility of visible at VP3 and although they are only 0.04kms further away an existing turbine within the photograph than at VP2, they are not perceived as being as prominent as at additionally assisted in the creation of accurate VP2. conditions. Photography for Gwar-allt was taken at 11:50am when the sun’s position was to the south resulting in the turbines being side lit. While the turbines from Alltwalis appear whiter and brighter than those from Gwar- allt, the appearance of the turbines in both photomontages has been accurately matched to the photographic conditions. Brechfa Forest West Wind Farm Consultation Report 50

12.24 CCW advises that in order to accurately represent the No action- For photomontages of the Brechfa worst-case scenario - all turbines should be orientated towards the West Wind Farm where no other operational viewer. This is not the case in the ES and we request that this is turbines are visible from the viewpoint (e.g. amended. Fig 15.23 Gwar-allt) the turbines are orientated towards the viewer. Where operational wind farms feature in the panoramic photograph we seek to match the orientation of the proposed Brechfa Forest West turbines to the existing visible turbines and thus the prevailing wind. This is evident for viewpoints such as Mynydd Llanfihangel-rhos-y-corn (Fig 15.21) and Alltwalis (Fig 15.22) where the turbines of Alltwalis are clearly visible on the photograph. The SNH Good Practice Guidance (178) states that viewing turbines ‘face on’ does not necessarily produce higher levels of visual impact than when viewed at an oblique angle.

12.25 We are satisfied that the Cumulative LVIA are well addressed Noted and follow best practice guidance. 13.1 The ES states that tracks will be surfaced and designed As above, this is confirmed. to standards that ensure control of water and integrity of the road surface. CCW requests confirmation that this will be done according to FCW specifications. 13.2 How frequently will catch pits, settlement ponds and filters As required. HCoW will be employed during be changed and monitored? This needs to be agreed with FCW, construction.. EAW. The CMS should include provision of a HCoW and/or monitoring officer to inspect measures as outlined at point 6.29 above. 13.3 The ES states that sections through soft or peaty ground will No action- Peat probing undertaken to date at be assessed first by trial pitting to establish depth to a suitable the site by RWE NRL indicates that this is not formation and that following this, an appropriate course of action likely to be encountered at Brechfa Forest West. will be determined. CCW requests clarification on exactly what RWE NRL would expect that in the unlikely the appropriate course(s) of action is/are to ensure that peat is event that it is required, micrositing would be avoided and appropriate mitigation is put in place. used where necessary to avoid peat deposits.. 13.4 The first paragraph states that floating roads are not As above, the presence of peat is considered considered necessary as it is anticipated that peat of any to be highly unlikely - micrositing is available if significant depth will not be found. You are advised to carefully required to avoid peat deposits. consider the requirements of EN-3 where impact on peat habitat is referenced and we draw you attention to the content of paragraph 2.7.38 of EN-3. 13.5 CCW requests to know exactly how excavated soil will be No action- Simple soil storage would be used stored? It is unreasonable to merely state that it will be stock- to avoid sediment run off. This is detailed piled for use during re-instatement e.g Extreme or unexpected design work that would be undertaken prior to heavy rainfall could increase sediment run-off into watercourses if construction commencing. inadequately stored. We expect further clarity on this issue. 13.6 CCW seeks written confirmation that no seeding will take RWE NRL can confirm this and welcome place on FCW land. We would welcome discussion with you discussion nearer the time on specific regarding any seeding works to be proposed off-site, for example, arrangements on non-FCW managed land. along access tracks to ensure that an appropriate seed mix is used. 13.7 The ES states that a small satellite compound may be This has been clarified in the ES constructed. CCW requests clarification if this will be built or not. If so, we would need to see details of the potential impacts of the proposed build in relation to further ecological and LVIA impacts of the scheme as a whole. Brechfa Forest West Wind Farm Consultation Report 51

13.8 The ES states that a detailed statement for work around Noted. watercourses will be provided by the contractor to the EAW prior to works being undertaken and the method included in the finalised CMS. This should also be provided to CCW for comment to ensure there will be no impact on the SAC and its features. The CMS must link with the HMP. 13.9 Given the long-term presence of this quarry as open habitat Further to discussions with CCW/ CCC/ FCW, in the area, consideration should be given to keeping this habitat this has been updated in the revised ES. free from trees. The few quarries in Brechfa Forest West have been in periodic use ever since the area was the open hill of Mynydd Tre-, and they therefore remain as fragments of a relatively ancient open habitat in an area that is otherwise dense forestry (or younger forestry tracks). Biodiversity would benefit far more from the borrow pits either being left to recolonise totally naturally, or perhaps from having their surface soils removed prior to stone ripping and then replaced. We do not consider seeding/ planting to be acceptable and it would be useful to know exactly what restoration is proposed for the borrow pit areas. We would welcome further discussion with you on this matter. Please also see comment under section 6.8. 13.10 CCW requires clarity on alternative procedures if plate No action- In extreme circumstances on sites baring tests prove the bearing capacity of the underlying strata previously developed by RWE NRL where the is too weak. What other procedures are proposed if strata is not ground conditions were generally unstable, suitable. pile foundations have successfully been used. However, given the geology at Brechfa Forest West Wind Farm, any local issues will be resolved through the use of geogrid and additional aggregate. However, unstable ground conditions are not anticipated to be an issue at this site. 13.11 No information is provided in the ES regarding No action- Detail will depend upon technology decommissioning of cables and subsequent reinstatement of the available at the time of decommissioning. ground 13.12 A scaled-drawing of turbine foundations would be a useful This has been added to the ES. in the ES and/or CMS. 13.13 CCW considers that the principle objectives of a Restoration A restoration statement outlining measures set Statement (RS) should be provided to CCW and other key parties out in the ES has been provided as an appendix prior to submission of the application to IPC so that the objectives to the ES. and methodologies are agreed. The RS will need to be closely linked to the CMS. 13.14 Whilst CCW fully expects EAW to deal with all pollution Noted. prevention measures (PPM), consents and licenses, we would welcome input into discussion with EAW to ensure that issues concerning habitats and species are fully covered. We ask that we are provided with any supplementary draft documents that are produced and are given the opportunity to comment. 13.15 CCW seeks confirmation of the location(s) where water This has been removed from the revised ES- no abstractions will take place on site. No information is presented in onsite concrete batching is proposed as such the ES. no onsite water abstraction will be required.. 13.16 CCW strongly advises that the CMS and HMP need to be Noted. inextricably linked, detailed, frequently reviewed and robustly monitored. CCW suggests that CCC will need to be involved in the discussions regarding habitat management and invited to sit on the HMP working group since they retain in-house ecological expertise and moreover, will be the enforcing body. Further comments regarding the HMP are outlined in Annex 17. Brechfa Forest West Wind Farm Consultation Report 52

13.17 We have concerns regarding the use of floodlights in As identified in an earlier response, proximity to watercourses because of potential disturbance impact floodlighting will not be used in proximity to on otter and badger and bat habitat corridors. This should be watercourses. detailed within the HMP and cross referenced with the CMS. 13.18 We advise that measures to control and manage invasive Standard control and management procedures species (including Japanese Knotweed and Himalayan Balsam) are referenced within the ES. during construction are detailed in the CMS as well as the HMP. 13.19 No consideration has been given to bio-security measures FCW biosecurity procedures will be adhered to and control. Serious consideration needs to be given to a potential during the development of this proposal. outbreak of the fungal infection - Phytophthora ramorum - across the forest. Contingency plans and security measures need to be detailed in the CMS. CCW expects RWE to liaise closely with FCW on this serious issue.

14.1 As currently drafted parts of the ES are contrary to the No action- As detailed earlier, RWE NRL does draft National Planning Statements EN-1 and EN5. EN1 (Section not agree with CCW’s interpretation on how 4.9) requires the applicant to provide sufficient information grid connection should be dealt with in the with their application to comply with the EIA Directive including application for this proposal. indirect, secondary and cumulative effects, which will encompass information on grid connections. NPS EN-5 (Section 2.8) requires the IPC to bear in mind the ‘Holford Rules’ and any updates when examining applications for overhead lines. At present the ES does not provide the information to comply with either of these requirements. Your application and ES should therefore be amended to provide sufficient information to comply with the EIA regulations and outline how the grid connection has considered the Holford rules in determining the final route selection. We strongly advise that particular consideration is given to a route that avoids as far as is possible major and smaller areas of highest /high amenity value in LVIA terms and high quality ecological areas. Where this is not feasible clear justification should be provided why that is not possible. 14.2. The 132kV over-head power line connection to the Brechfa As above West windfarm comprises associated development which itself is likely to give rise to significant environmental effects under the EIA Regulations given its length of 57km. Although the power line is considered in a high level assessment within the ES, there is no assessment of the in combination cumulative effects of the windfarm and the power line and other proposals in the area at any level (e.g ecological, LVIA, noise, hydrologically etc). We consider this to be a serious deficiency in the ES as not all of the impacts of the windfarm and its associated infrastructure have been assessed. 14.3 The high level assessment presented in the ES has scoped Further detail on why topics have been out a number of environmental receptors such as hydrology included/ excluded has been provided within and recreation and socio-economics. However, no justification is the ES. given as to why this is the case. Further, the baseline detail that is provided is particularly scant. We consider insufficient detail has been provided on the indicative grid connection to advise on this aspect of your proposal, and that it should be amended accordingly by full assessment in the final version of the ES. 14.4 We are seriously concerned that no alternative routes for There is no requirement to assess alternative the grid connection have been explored, and that the most direct routes. and economical route appears to have been presented in the ES. As a result, we consider the ES to be flawed in this instance and incomplete under the terms of the EIA regulations. Other alternative routes should have been assessed. Brechfa Forest West Wind Farm Consultation Report 53

14.5 We strongly advise that a strategic approach for the grid No action- This is something that is the connection is pursued to ensure there is adequate capacity for responsibility of the DNO and something that is many, if not all of the proposed developments within the Strategic not within RWE NRL’s control Search Area (SSA) so that the landscape/amenity/ecology of the area is not adversely impacted by a plethora of grid connections and any subsequent upgrading. We urge that you actively pursue discussions with the grid provider and other companies developing schemes in the SSA to ensure that environmental impacts can be minimised through a holistic approach for the area. Should it be of assistance, we would welcome the opportunity to contribute to discussions on this issue with the aim of securing a satisfactory solution for all parties. 14.6 Notwithstanding the above and regardless of the paucity As above of information provided in the ES, we have attempted to provide some comment on the information presented. However, we expect that additional issues will be identified once the information is presented in more detail in a revised draft of the ES. We will provide further comment then. Key issues for grid and LVIA are outlined as follows. 14.7 Table 1 summarises key information on the environmental No action- This is incorrect, the Brecon Beacon receptors. It is noted however, that the Brecon Beacons National National Park has been included within Table 1. Park (BBNP) has been excluded from this. This should be revised and amended accordingly. 14.8 Paragraph 15 notes two SSSIs that occur within the route: Wording amended within the ES. Allt-y-Wern and Coed Llandyfan. These two SSSIs have not been denotified as the ES suggests, and are still statutorily protected sites 14.9 Paragraph 17 refers to the record centres consulted. Why It is not considered appropriate to provide this have WWBIC, SWEBREC and Powys Record Centres not been level of detail at this stage, clarification of text contacted? They should all be contacted for their records so that provided an accurate account of impacts is determined. Upon request, CCW will also release our record information to you to augment this information. 14.10 Paragraph 30 makes reference to the Allt-y-Gaer SSSI. This No action - This is not considered to be is designated for, amongst others, its heronry. Rhosydd Castell necessary Du & Plas y Bettws features are fen, neutral marshy grassland and wet heath. Further detail should be provided about the impact, proposed mitigation and management at the international and nationally designated sites referred to in paragraph 30. Brechfa Forest West Wind Farm Consultation Report 54

14.11 Further to the above, the wording of paragraph 31 needs to Clarification of wording has been provided be amended to reflect the correct procedure of conducting a test within the ES. of likely significant effects (TLSE) and an appropriate assessment (AA) on development that might affect a Natura 2000 site. The use of the term compensatory habitat in the penultimate sentence is incorrect, for the reasons set out below. Regulation 61 of the Conservation of Habitats and Species Regulations (2010) requires a competent authority before giving consent for a project that is likely to have a significant effect on a European site (either alone or in combination with other plans and projects) to undertake an appropriate assessment of the implications for the international site. Where it cannot be demonstrated that a project will not have a significant effect on an international site, an appropriate assessment will also be required. This process is referred to as a Habitat Regulations Assessment (HRA). HRA is a 2 stage process which involves carrying out a TLSE as the first stage, followed by an AA where necessary. When carrying out the TLSE or making an AA, only avoidance, cancellation and reduction measures can be considered. Compensation and compensatory habitats cannot be considered as part of those processes. If the appropriate assessment concludes that the project will have an adverse effect on the integrity of the international site (not withstanding any proposed mitigation), it can only proceed if there are no alternative solutions and if it is considered that it is required for imperative reasons of overriding public interest (IROPI). Should such a situation arise following ministerial consent, compensatory measures will then be required to ensure that the overall coherence of Natura 2000 is protected. 14.12 There is no mention, in the reference to mitigation, to the No action- It is not within RWE NRL’s control to use of deflectors to prevent bird strike. Deflectors will need to be propose mitigation for a future application that fitted if the overhead cables pass over any sites where there is a they are not responsible for. particularly high risk of collision e.g. over breeding wader sites, or where cables pass over water courses. 14.13 Paragraph 38 refers to licence applications. The WAG & CCW Noted. will require survey information to enable an informed decision to be made on whether or not a licence should be granted. 14.14 CCW has concerns regarding the impact of the indicative As detailed earlier, RWE NRL does not grid connection route on bryophyte species at the point at agree with CCW’s interpretation on how which the route is indicated to cross the Cothi south-east of grid connection should be dealt with in the Abergorlech (SN592331). This area includes a notable bryophyte application for this proposal. community on steep, rocky slopes, and is a site for the Section 42 moss Rhytidiadelphus subpinnatus. More information should be provided on exactly where the route is intended to cross this woodland, and how RWE intend to avoid damaging ground flora. 15.1 A dry-run along the entire length of the route must be This has been completed and the report considered to ensure that no additional road widening works are appended to the ES. required and therefore no further impacts on ecology are to be expected. Whilst we appreciate that the proposed access route has previously been used by the Alltwalis development, we suggest that the infrastructure used for that farm are significantly different in size and diameter to your proposals. It is therefore considered prudent to perform a dry-run which is not perceived to be overly onerous. Brechfa Forest West Wind Farm Consultation Report 55

16.1 CCW notes that the Carbon Calculations provided in Carbon balance assessment has been updated Appendix 5.1 have been produced using the 2008 version of for inclusion in ES using the most recent the Nayak calculator spreadsheet. A more recent version (v1.0.8 version of the tool. available on 31/08/2010) of the calculator was available for use when your calculations were produced and, as such, we recommend that RWE re-calculate carbon savings and payback period for this scheme using this latest version - for the reasons highlighted below. We also request that instead of supplying a pdf, you supply us with your calculations on the excel sheet directly, as the calculations are much easier to review when provided as a live spreadsheet. So that we can re-advise on this aspect of the ES prior to its finalisation, we therefore request a copy of your calculations as soon as possible. 16.2 It appears that RWE (and your consultants -RSK) have opted No action- It is not possible to provide site to base the estimation of emissions from the construction, specific data at this stage of the project operation and decommissioning of the turbine hardware is therefore it is appropriate to base estimates of based on the installed capacity of the turbines. The spreadsheet emissions on the proposed installed capacity. provides means to do this, but it needs to be remembered that this methodology depends on an empirical correlation between installed capacity and emissions from these activities - rather than any attempt to quantify them for this specific project. From the results presented by RSK, the emissions represent roughly half the overall payback time of the scheme - and therefore the inherent error in the correlation approach taken here will impact significantly on the overall error margins of the payback time. CCW notes that the overall payback time of this scheme, as indicated by the calculator supplied, is still considerably less than the 25 years operating life of the scheme and the margin of error is extremely unlikely to overturn this result. However, one of the primary functions of the calculator is to foster an approach whereby emissions are reduced to a practical minimum, rather than simply making sure the payback time is less than 25 years. In this context, using the empirical approach to emissions from construction operation and decommissioning of hardware does not help inform how these emissions might be reduced. CCW recommend that the calculations are reworked bearing these comments in mind. 16.3 It is noted that the ‘Fen’ option has been selected to describe This change has been made within the ES. the characteristics of the peat land before windfarm development. CCW advise that the ‘acid bog’ option is likely to be a much more accurate description of the characteristics of the peatland at this site and ask that the calculations are reworked based on this advice, or, clear coherent justification is given for the use of the fen option. The selection between the fen and acid bog options in the input data sheet changes the range of equations used for soil emissions factors used throughout the calculator, and the designers of the calculator put this option here to optimise the calculator for the very different conditions in fens and acid bogs. Since the characteristics of this site are more akin to acid bog than fen, the calculations should be reworked based on this advice. Clarification is also required on what is meant by ‘leastworse case’ result? Brechfa Forest West Wind Farm Consultation Report 56

16.4 An average peat depth of 10cm is assumed across the site, No action- Following peat surveys this was which you state is likely to be an over estimate for much of the site considered to be the most appropriate peat - leading to the carbon calculations being pessimistic. However, as depth assumption for this site. CCW are not confident about the amount of peat reported to be present across the site (see comments 7.16- 7.20) and are not in possession of baseline survey results, we are not satisfied with this assumption. The carbon savings for the scheme should therefore be re-calculated with the latest version of the calculator, allowing for the provision of a maximum and minimum estimate of average peat depth, based on field survey of the resource. This will allow greater confidence in the assessment of your assumptions. 16.5 CCW is satisfied that a reasonable dry weight carbon content Noted for the peat has been assumed. 16.6 A 2m radius for the draining effect around areas of peat This change has been made within the ES disturbance is assumed. We advise that a calculation with at least 10m is used here instead of 2m, as currently used. . Again, the more recent version of the calculator allows for an average, max and min to be put in for these types of values, giving a range for payback time which CCW consider to be useful. 16.7 Data to support the figures given for the average water table depth. 16.8 We note and welcome that the time required for re- Noted. establishment of bog plants is 10 years - which will contribute towards the final values being a worst case analysis. 16.9 We confirm that the estimates of Carbon sequestration Noted. from bog plants are satisfactory, and are based on approved guidance estimates. We do, however, suggest that the figures for average rate of carbon sequestration in forestry are improved by determining the age classes of the felling and using values appropriate to age class. 16.10 The ES assumes that there will be no peat removed from This has been revisited following peat survey turbine bases and hard-standings, in effect saying that micrositing work will avoid all turbine location on peat. This statement cannot be supported until the true extent of peat across the site is known. 16.11 It is unclear what methodology is used for calculating Noted. soils emission factors, since the input data table reproduced in Appendix 5.1 is not the actual spreadsheet table. The original input table allows selection of IPCC or site specific methodology. Upon submission of the excel spreadsheet (or revised version) CCW will be able to advise further on the carbon savings of this scheme and confirm whether or not we have more confidence in the assumptions of the ES. 17.1 As discussed with you on the 30th March 2011, the HMP Further discussions have taken place regarding associated with your proposal requires further detail and the HMP and amendments made to this refinement in relation to the impacts, mitigation, extent of document to reflect these discussions influence and indicative costs. As emphasised at the meeting, we suggest that discussions between CCW, RWE, CCC and FCW commence as soon as possible in order to further develop the HMP so that it is fully acceptable to all parties. Currently, we have concerns over the adequacy of the HMP, both in terms of stakeholder consultation and the limited level of detail provided to enable the IPC to make an informed decision. Brechfa Forest West Wind Farm Consultation Report 57

17.2 Section 1.5 states that six conservation features have been HMP has been revised to address the point identified in the HMP, however it appears to contain only five. raised. Taking account of the comments under Annex 10, CCW considers the HMP to be generally lacking in detail and that all of the mitigation required for the significant impacts of the scheme has not been provided within it. 17.3 The only monitoring in place is for nightjar, bryophyte and As above PAWS. Robust and adequate post construction monitoring for bat and bird collisions, nightjar monitoring, vegetation monitoring; invert monitoring and otter monitoring (this will be a request if a WAG licence is required) will be required to be detailed in the HMP and we would be happy to discuss this further.

17.4 The mitigation and enhancement proposed is disappointing. Further detail on these issues is provided PAWS restoration has been identified as mitigation when it should within the ES. be clearly considered as additionality or gain. The scheme does not impact on PAWS and therefore does not require mitigation. Any restoration of this habitat area must be accurately described as gain. CCW advises that the HMP should incorporate sections on the mitigation measures for loss of wet heath/acid grassland mosaics, marshy grassland habitats and any mire habitats (all of which are UK BAP priority habitat); details of mitigation and the protection of ponds, compensation for the loss of a small pond as evidenced under paragraph 13.251; details of pine marten and pole cat mitigation; hedgerow and tree line mitigation. Currently these species and habitats identified as being impacted but no mitigation is described. This is unacceptable. A robust deliverable HMP showing avoidance and adequate mitigation for all species and habitats that are impacted is required. This mitigation should be clearly mapped and fully costed to prove deliverability. Monitoring will need to be identified as an integral part of the HMP with provisions that the mitigation can be adapted to take account of any shortfalls. 17.5 At paragraph 9.4 of the HMP reptile clearance is mentioned. Text has been clarified within the ES. However, there is no inclusion of how this will be carried out. A best practice methodology must be provided. At paragraph 9.9 a contingency measures needs to be considered prior to relocation if an insufficient carrying capacity is reached. Potential receptor sites will need to be identified well in advance of clearance and relocation. 17.6 CCW is satisfied with the mitigation and monitoring proposed As above for bryophytes- additional information for Bryophytes as outlined in the HMP, provided that it is done incorporated under the supervision of a suitably qualified bryologist liaising with the county bryophyte recorder. We welcome the proposal to monitor annually for a total of five years. CCW notes that the three quarry mosses (Dicranella subulata, Campylopus subulatus, and Pohlia bulbifera) outlined under points 10.6-10.8 above), have not been mentioned in the HMP. CCW appreciates that this may be because they were only discovered subsequent to the data request to WWBIC. We advise that further discussion takes place with CCW regarding mitigation of the loss of the 0.15ha of quarry habitat. 17.7 Reptile and bryophyte mitigation will need to be a considered No action- Proposing mitigation now for for their requirements at the decommissioning stage. This is decommissioning seems pre-emptive. Best currently not considered in the HMP but should be included. practice and circumstances may have changed at the time decommissioning is undertaken. Brechfa Forest West Wind Farm Consultation Report 58

17.8 Further information needs to be provided regarding the No action- Standard guidance will be followed. control, mitigation and management of invasive species on It is not necessary to duplicate this information the site. It is considered that the eradication and/or control in the HMP as it will be available within the of invasives should be undertaken as a general site/habitat CMS.. enhancement and details of an eradication/control strategy is required to be included within the CMS and HMP. 17.9 CCW requests that indicative maps of the habitat A plan has been provided to accompany the management areas are submitted with the application HMP. 17.10 CCW requests inclusion within the HMP of indicative No action- As explained to CCW, it is not costings to ensure that the HMP is both deliverable and considered that providing costings is an achievable. appropriate approach- the important thing is that the mitigation is delivered, not how much it costs. Costings can vary over time and citing these figures within the HMP may be restrictive. 17.11 CCW welcomes our inclusion in a HMP working group and Noted. look forward to working with you to deliver a defensible and robust HMP. 17.12 We suggest the provision of a full-time Ecological Clerk of Incorporated Works (ECoW) should be identified. The appointed person needs to be agreed with the HMP working group. 17.13 We encourage the use of the Countryside Management No action- This is the approach that is being System (CuMS) as a tool for recording and managing the HMP. used by RWE NRL. We recommend that if CuMS is used, it is implemented in a streamlined manner, concentrating on the elements which are of most concern in this scheme. The important elements are; clear identification of what is to be achieved by the plan in terms of site features and objectives of the stakeholders; clear, monitorable objectives for projects. FCW would require the use of CuMS to enable clear identification of the financial requirements and commitments. We would welcome the opportunity to discuss the use of CuMS in your scheme with all stakeholders involved. 17.14 A draft terms-of-reference for the HMP working group This document will be produced by RWE NRL in should be provided which must include a clause relating to draft for discussion. provisions for arbitration and timely resolution if no agreement on specific detail can be agreed. 18.1 CCW requests discussion regarding requirements (conditions) CCW were provided with the draft DCO on attached to any consent given to this scheme at the very earliest 7th June 2011. As of 4th October 2011, no opportunity, preferably prior to submission of the final application comments had been received by RWE NRL from to IPC. CCW with respect to this document. Brechfa Forest West Wind Farm Consultation Report 59

2.7.8 BFW/IPC/S42/029

Carmarthenshire County Council (CCC) provided a detailed response covering a number of issues. These are set out in the table below, along with RWE NRL’s response to each separate comment. Unless otherwise stated, any actions required have been made within the revised ES.

Comment RWE NRL response It would clarify matters and make the process more transparent if All elements of the development set out in Part 1 the submission made it clear whether everything is considered as to Schedule 1 of the draft DCO are considered to associated development. be fundamental - not associated WAG is distinctive among the bodies that the IPC interacts with, No action - WAG are included as a prescribed because of:- body and have therefore been consulted on the – Its role in devolved areas of policy formulation in Wales; proposed application. This is not considered by – The direct regulatory functions it performs; RWE NRL to be an EIA issue and has not been – Its role as the decision-maker for certain appeals and other referred to in the ES. consents; – Its duties in overseeing the operations of other bodies, including the Environment Agency and Countryside Council for Wales; and – The context of the Assembly Government having a statutory duty to support and promote the Welsh language. This relationship needs to be recognised by the developer and referred to in the Environmental Statement. Para 2.4 Additional information on alternatives has been This paragraph makes reference to the requirements of Schedule added throughout the ES, with the exception of 4 of the EIA Regulations. The second bullet point states that an grid connection, where this is not considered to be Environmental Statement should include an outline of the main necessary- as has previously been discussed with alternatives studied by the applicant and an indication of the CCC. main reasons for the applicant’s choice, taking into account the environmental Brechfa Forest West Wind Farm: CCC’s Response to S.42 Consultation – Planning Act 2008 effects. This approach, however, has not been taken in the Draft Environmental Statement (DES) when assessing Access and Grid Connection. Para 2.18 Cumulative impact has been reviewed and It will be essential that the in combination impacts are considered amended where necessary throughout the ES – all by all competent authorities in relation to Brechfa West, Brechfa wind farms cited here have been included. East and Bryn Llewellyn wind farms. The proposed grid connection should be examined thoroughly by all parties. At present the impacts of the grid connection and access requirements do not appear to have been considered in cumulative impact assessments. Para 2.28 This sentence is now in the correct tense. RWE NRL has also prepared a Consultation Report. It is considered that this sentence requires clarity as it is premature for the Consultation Report to have been prepared, given that the developer is unlikely to have summarised Section 42 and 47 consultation responses at this stage. A recurrent typing error has been noted in Chapter 2, whereby the This has been corrected header on the top right corner of each page makes reference to 3. Scheme Description and Design Strategy. Brechfa Forest West Wind Farm Consultation Report 60

Figure 3.1 This has been clarified in the text of the ES within Clarification is sought on whether the hub height of 100m is chapter 15 a maximum case scenario? Allied to this it is noted that there are no fixed maximums in relation to hub and blade heights. Is the picture of the turbine an example of a 145m turbine? A comparative photo with a turbine pertaining to Alltwalis Wind Farm would be of use. Para 3.6 This has been included in chapter 3 of the ES In the interests of clarity it is advised that distances from existing and proposed wind farms are provided. Para 3.8 No action- It is not proposed to use the minor road Reference made to the fact that several minor roads surrounding referred to in this comment. The detour referred to the site provide links to the wider road network. In light of the lasted a few days and is not on a route that is to recent partial collapse of a bridge on the B4310 near Brechfa be used for construction. school (08/02/11) causing detours of up to seven miles and lengthy traffic delays, what assessments have been carried out on local access routes in respect of diversionary works during the construction period?

Para 3.10 The text in the ES has been amended in the light A list of four dwellings has been provided giving distances from of this comment the nearest turbine. It is unclear if the distance given is measured from the residential dwelling’ themselves or the curtilage land pertaining to the dwelling. Clarification on this matter is sought. Grid coordinates for the dwellings mentioned should also be provided. Para 3.11 The reference is to the closest turbine as explained It is advised that reference is made to the ‘closest turbine’ in in the text addition to the distance from the red edged site. Para 3.12 Grid coordinates are now included There are no grid references provided for the individual turbines in the ES. This information should be provided and will be essential in assessing the micrositing of any turbines, which should be within 50m of the current proposed location. Para 3.27 A DAS is not a required document for an IPC There does not appear to be a Design and Access Statement application however in the light of this request (DAS). Whilst a DAS is not part of the planning application, it is a from CCC, RWE NRL have produced one. Further statutory requirement and is required by legislation to accompany information on access options considered has all planning applications (outline and full), in accordance with TAN been included in the revised ES. 12 and guidance provided by Carmarthenshire County Council. CCC is not aware of the options that were considered for accessing the site for the delivery of turbines. When making reference to CCC the developer is advised to indicate which Section / Department discussions took place with. It is understood that a highway study was submitted by the developer in 2009; however, this is not contained within the appendix as background information. More details on what options were discussed in respect of accessing the site would help to inform the IPC in support of the preferred option presented. Evidence of swept path analysis in the form of figures / drawings should also be provided. The onus on the applicant in respect of this requirement for IPC consideration is set out in the Revised Draft of the NPS (EN-3), Cl.2.7.76 to Cl.2.7.78. Brechfa Forest West Wind Farm Consultation Report 61

Para 3.28 No action- Lorry movements associated with More details of the preferred route need to be provided. The transport of stone from the quarry to the site have route identified for delivery of stone from Dinas Quarry, has this been assessed within Chapter 9 of the ES been included as part of the permitted access routes and has the suitability of the route been assessed? Is there an increase in the HGV % for the additional deliveries from Dinas Quarry for stone that cannot be sourced from the borrow pit. Again reference to the requirements for IPC consideration is set out in the Revised Draft of the NPS (EN-3), Cl.2.7.76 to Cl.2.7.78. Access Tracks Further information about internal access track Para 3.29 design evolution has been provided in the revised There needs to be more detail provided in respect of geometrical ES. Additional information regarding geometrical alignment of the access tracks on the development site. Have the alignment would constitute detailed design work routes identified been discussed and/or agreed with the Forestry and this will not be completed until a principal Commission Wales? contractor is in place for construction. All tracks Cross reference to ES Appendix 3.1 (3), penultimate paragraph will be designed in line with FCW’s Engineering under the heading ‘Procedure’ reinforces the fact that further Specifications. information is required. Final paragraph refers to peat, have ground conditions been considered? It appears that some existing tracks offer feasible connections to turbine locations, therefore an explanation of why these are not necessary. Details of the design evolution of the access tracks in the form of scaled drawings would assist this explanation. Para 3.30 – Bullet Point 1 Further information in relation to this issue has The ES states that one of the main objectives for the design of been provided within the ES. the track layout was to maximise the use of existing forest tracks where possible. However having examined the site layout (Figure 1.2) and the presence of existing tracks, there appears to be areas where additional length of new tracks are proposed, but where there are existing tracks that appear to offer feasible connections ( Turbines 3, 6, 11, 12, 22, 24, 26 and 28). The ES should clearly document the reasons why, in these instances existing tracks are not proposed to be used and why new tracks are required. Para 3.31 No action- This is an indicative figure. Figure 3.4 referred to in this paragraph appears to be very basic. It does not take into account the possibility of sidelong ground and the potential for increased earthworks as a result – as illustrated in the Forestry Commission (Road Specification) document. Para 3.33 No action- Locational information will not be Details of potential overtaking/passing places would be useful. available until a principal contractor is in place for construction and detailed design work has been completed. Cautious assumptions have been made throughout the ES for the purposes of Environmental Impact Assessment Para 3.34 No action- EAW were also consulted on Have discussions with the Environment Agency taken place in the Preliminary Environmental Information. respect of discharge rates and/or consents required? Discussions have taken place regarding relevant consents and these will not be sought by RWE NRL at this stage. Para 3.36 As above Have discussions with the Environment Agency taken place in respect of these watercourse crossings? Will there be a need for any flood defence consent applications for construction of new or upgraded structures over watercourses? Brechfa Forest West Wind Farm Consultation Report 62

Para 3.37 No action- This is covered throughout the draft ES Anecdotal evidence suggests that the borrow pit referenced in this paragraph is already in existence. Some details of the environmental effects of the proposed borrow pit should be submitted e.g. whether felling will take place? Para 3.40 to 3.43 A TMP has not been produced at this stage. The indicative construction programme needs to be directly linked Details about FCW plans for felling during the with the Transport Management Plan (TMP). construction period are included in the ES. Does the construction programme and TMP take account of the rotational harvesting of the forest within and outside the proposed development? Para 3.44 Cross referencing has been checked and corrected. Not clear why felling isn’t included as part of the construction The duration of felling is not known due to details given that it contributes to the number of HGV movements. the possibility for delays caused by ecological The peak months for HGV movement were found to be 12th-15th constraints, e.g. Schedule 1 birds nests. of the 22 month construction programme in contrast to Chapter 9 which shows months 10-13 to be the peak months for vehicle movements. Para 3.45 The draft CMS has been discussed in detail with Have the details of the Draft Construction Method Statement FCW and comments sought from other bodies (DCMS) been discussed with any of the relevant parties identified? through the consultation process. Reinstatement Post-Construction Noted. Para 3.50 See comments under Para 13.242.

Para 3.54 The access assessment report has been included It is understood that the route used for the operational wind farm as an appendix to the revised ES near Alltwalis is being identified as the preferred access route for this site. Are the turbine components the same as those installed at Alltwalis? - Will different abnormal vehicles be used and have these factors been taken into consideration in assessing the route? Decommissioning Section 3.56 No decommissioning method statement has been provided. Design Strategy This was a consideration when designing the Para 3.72 layout of the internal access tracks Second bullet point – has the feasibility of this been assessed

Table 3.1 Design evolution drawings have been included in It would be useful to cross reference the detail indicated in the the revised ES table with layout drawings in order to gain a clearer understanding of how the scheme has evolved. Brechfa Forest West Wind Farm Consultation Report 63

Para 3.75 Noted. (Note – this decision is subject to legal The developer needs to be mindful of the recent decision by challenge and at at the time of writing the the Planning Inspectorate which dismissed 19 wind turbines at Inspectors decision has been quashed by the High Mynydd y Gwair, Swansea. The decisions letter makes reference to Court.) the impact of the turbines on peat bog habitat and a mircrositing tolerance of 30m being the acceptable limit in the Welsh context. Notwithstanding the above the content of Section 2.7.25 of Revised Draft National Policy Statement for Renewable Energy Infrastructure (EN-3) should be taken into i.e. - Whilst it is for the applicant to specify the level of tolerance they are seeking, a tolerance of between 30m and 50m of elements of the required infrastructure is typical. However, there may be some circumstances where the IPC considers that the micrositing tolerance requested by the applicant is too great, and that on the evidence of the EIA and its own assessment of the proposal, that it is necessary to restrict either the overall tolerance for the scheme or the tolerance of specific elements of the proposal. When making this judgement, the IPC should take into account the reason for the applicant having requested the micrositing. Para 3.78 No action- This is a separate application for Grid Connection Route subject to separate application – no survey consent. It is the responsibility of Western Power or discussions with relevant interested parties have taken place – Distribution and not RWE NRL. ES Appendix 3.2 (2) What is the timing of the Grid Connection? Is the separate planning application being co-ordinated with other major renewable developments in the area. Based upon information presented in ES Appendix 3.2, the route appears to be located along a sensitive corridor. Have any alternatives been considered? Do WPD have statutory powers to obtain land under CPO? The Grid Connection appears to identify the inclusion of Brechfa Forest East development, but does it include the proposed wind farm at Bryn Llywelyn? Will this increase the voltage of the power lines, thus requiring pylons instead of wooden pole installation? Can increased underground cable installation be considered or is 33kV the maximum for underground installation? Para 3.79 Swept path analysis and dry run indicate that Makes reference to Appendix 3.3 for offsite access works, this is minimal off-site access works are required- in not sufficient detail. Further details of the offsite access works particular no land take requirement has been need to be provided. Requirements for sufficient land outside identified. This information is presented in the existing the highway boundary are not clear – ES Appendix 3.3 (9). revised ES As set out in the Revised Draft of the NPS (EN-3), Cl.2.7.84, “it may be appropriate for any non-permanent highway improvements carried out for the development (such as temporary road widening) to be made available for use by other subsequent wind farm developments. The IPC may consider that a planning obligation is necessary to secure appropriate measures.” New Access Track Construction - The first paragraph of this sub- A peat survey has been undertaken and the results section states that floating roads are not considered necessary presented in the ES. The results of the survey as it is not anticipated that peat of any significant depth will be concur with and reinforce the conclusions of the encountered. An assessment of what constitutes a ‘significant desk based work. depth’ of peat needs to be given to provide further clarification on the potential impact upon this habitat. The recent Planning Inspectorate decision at Mynydd Y Gwair makes reference to a figure of 300mm. On this basis it is considered that further survey work is carried out within the site to establish coverage. Brechfa Forest West Wind Farm Consultation Report 64

The developer should carefully consider the requirements Noted of Revised Draft National Policy Statement for Renewable Infrastructure (EN-3) where peat habitat is a known environmental factor. Para 2.7.38 states: the IPC should be satisfied that the wind farm layout and construction methods have been designed to minimise soil disturbance when building and maintaining roads and tracks, turbine bases and other infrastructure. This is to ensure the development will result in minimal disruption to the ecology and that the carbon balance savings of the scheme are maximised. The fourth paragraph of this sub-section refers to two crossings These plans are located within Chapter 8 on watercourses shown on 1:25,000 scale topographical “Geology, Soils and Hydrology” of the ES. mapping (references W001 and W002). In the interests of clarity it is advised that the location of these plans within the DES is indicated. The ES states that a detailed statement for work around Hydrological Clerk of Work has been included has watercourses will be provided by the contactor to the EAW prior to been included in the CMS. works being undertaken and the method included in the finalised Construction Method Statement (CMS). This should also be provided to CCC for comment. It is suggested that the CMS include provision of a Hydrological Clerk of Work and/or monitoring officer to inspect measures. A scaled cross section drawing of the proposed turbine foundation An indicative drawing has been included is considered necessary in order to provide an illustrative interpretation of the descriptive text in this section. It is considered that the main principles of a Restoration Statement A draft Restoration Statement is included as an are given at the submission stage in order for CCC to agree in appendix to the draft ES. principle.

The seventh paragraph of the sub-section entitled Silt states that An indicative figure has been provided. small dams will be placed in roadside ditches to aid silt retention. It is advised that a typical section of the proposed dam is provided with the submission of the application. The sub-section entitled Description states that ecological This has been amended to include the CCC. monitoring will be set out in a Habitat Management Plan(HMP) to be drawn up by a working group including the developer, FCW and CCW. Officers from CCC would expect to be involved in these discussions given the expertise retained and also the likelihood that the HMP will have to be enforced by the Council. CCC would expect the Construction Management Plan (CMP) No action- This is not considered to be necessary. is accompanied by a light pollution impact assessment which As outlined in CCW’s response, it has been will detail flood light height, light specification and proximity confirmed that there will be no lighting of from residential dwellings, in order for potential impact to be watercourse corridors. adequately assessed. Appendix 3.2 Grid Connection Route Assessment Paragraph 15. This has been amended The two SSSIs noted in paragraph 15 have not been denotified. Appendix 3.2 Grid Connection Route Assessment Paragraph 17. No action- This is not considered an appropriate A relevant search for the grid connection should be undertaken level of detail for a high level assessment of an by the West Wales Biodiversity Information Centre (WWBIC) as indicative route that does not form part of this undertaken for the main scheme and mentioned in the CCC application. The grid connection, as previously scoping response. stated, will form a separate application lead by the Western Power Distribution. Brechfa Forest West Wind Farm Consultation Report 65

Appendix 3.2 Grid Connection Route Assessment Paragraph 31. Wording has been clarified within Appendix 3.2, The wording and/or procedures detailed in this paragraph are however, the application for the grid connection incorrect and are of concern. The use of the term ‘compensatory is separate and the responsibility of a different habitat’ in the penultimate sentence is not correct. Regulation 61 organisation (Western Power Distribution). The of the Conservation of Habitats and Species Regulations (2010) grid connection does not form part of the present will require the proposal to be assessed for likely significant application. effects by the relevant competent authority following a specific procedure. This procedure will involve carrying out a test of likely significant effects (TLSE) and an appropriate assessment (AA) (as necessary). When carrying out a TLSE or AA only mitigation (avoidance and reduction measures) can be considered when assessing and concluding no likely significant effects, however compensation and compensatory habitats cannot be considered in this assessment. Taking mitigation into account, if there is a likely significant effect still identified the developer will then need to show there is no alternative to the proposed scheme and secondly if there are no alternatives, the scheme will need to be presented to WAG and they will need to agree that the scheme fulfils the IROPI criteria (imperative reasons of overriding public interest). Only if WAG confirm the scheme meets these criteria, that there are no alternatives and IROPI is fulfilled, will compensation be acceptable. It is a concern that no alternatives for the grid connection have Some detail regarding cumulative impacts with the been considered and the most direct and economical route has grid connection has been provided. Requesting been presented. Furthermore the wind farm has been developed that the grid connection should be fit for on the basis that the grid connection is assumed to be to the purpose, providing infrastructure for all proposed south. It is considered that the proposed grid connection should developments is not within the control of RWE be fit for purpose and should ideally provide the necessary NRL. No alternatives for the grid connection have infrastructure for all the proposed developments and for further been considered. schemes that may be forthcoming in the SSA. The connection should also provide enough capacity for these schemes, to avoid the connection requiring further upgrading in the future, which may result in greater ecological disturbance. The cumulative effects with the proposed developments and the grid connection should be considered thoroughly including ecological issues. Before submitting the application to the IPC the developer needs No action- RWE NRL have reviewed the relevant to be satisfied that it has complied with Para 4.9.3 of Revised policy documents and legislation and are Draft Overarching National Policy Statement for Energy (EN-1) and confident that these have been complied with. must ensure they provide sufficient information to comply with the EIA Directive including the indirect, secondary and cumulative effects, which will encompass information on grid connections. Para 5.24 No action- the proposed Brechfa Forest West Wind CCC recognise the proposed wind farm could produce a large Farm will contribute a saving of 2,771,837 tonnes

annual generation of electricity, however, would question whether of carbon dioxide (CO2) is. The wind farm will this output is ‘significant’ in making a contribution to the UK make an important, and significant, contribution

Government’s target of cutting emissions of CO2, by 34% on 1990 towards the UK Government emissions targets. levels by 2022. Planning and Regulatory Framework Noted. At the time this document was printed the Para 6.6 Localism Bill has not been passed. The requested The developer will be mindful that the status of the IPC will be action is not relevant in this case. confirmed by Parliament’s passing of the Localism Bill. An update of this paragraph is likely to be required at the time of submission. Planning Policy Wales This has been amended within the revised ES. Para 6.25 Planning Policy Wales fourth edition was published in February 2011 and included an updating of the Renewable Energy chapter. The developer is advised to make reference to this when updating the ES. Brechfa Forest West Wind Farm Consultation Report 66

The Development Plan This reference has been amended within the Para 6.27 revised ES. In addition to Policy UT5 of the UDP reference should also be made to the Policy UT6, which provides more specific assessment criteria for wind turbine development. Para 1.3 of Appendix 5.1 states that part of the area is covered by soils described as possibly having a peaty surface layer where wet depressions occur and by a soil type which has a wet peaty surface layer of 0.1 m which may include peat on higher ground. Para 3.1 of Appendix 5.1. The assessment states that the methodology used for the assessment is designed for developments on peat land. The geological map shows no peat within the site. However the assessments have assumed an average peat depth of 0.1m across the site in order to avoid underestimating potential carbon losses from peat. Para 8.8 Not all Private Water Supplies (PWS) owners have During the inspection of the site and surroundings, officers from consented to having the details of their PWS CCC’s Planning Department were informed that the occupiers of included within the ES for the Brechfa Forest West Lan Farm and Lan Du have private water supplies. The dwelling Wind Farm. Further studies have been done on the at Twyllwyd in Llanllawddog is also known to be fed by a private PWS’s at Lan Farm and Lan Ddu. water supply. Without full knowledge of properties on private water supplies it will be difficult to provide comprehensive mitigation details of the construction impacts. Table 8.1 No action- Accurate long term monthly average CCC’s scoping response also requested the inclusion of long rainfall data is not easy to determine for the site. term average monthly rainfall figures within the ES and their Rainfall data is not available from the FEH source significance in relation to the development. Discussions have used for annual averages. Monthly variations for also taken place with hydrologist consultants acting on behalf the site (in general terms), using various sources, of the developer regarding the creation of wetland habitats as a are described within the ES. means of providing sustainable drainage on the site as well as new habitats. Topography, Rainfall and Land Use 1961 - 1990 taken from FEH software which takes Para 8.44 into account catchment area/elevation Over what period has the average annual rainfall been calculated? Rainfall experienced at the site is likely to be greater than the catchment average. Has rainfall been recorded along with wind speed? Para 8.47 Peat surveys have been completed and Peat habitat should be identified by on-site surveys. If there are incorporated within the revised ES. The surveys any wet peaty areas the trees will have failed and this might be an undertaken support the conclusions cited within indicator of where to look for peat. States that there are no peat the draft ES with respect to the nature and deposits shown within the area. The geological mapping indicates presence of peat within the site. there is little peat present in the general area around the site. Para 8.50 This information has been provided It is advised that the division/section of CCC which has provided the information is indicated. Soils Noted Para 8.53 States that there are some peaty topped, slowly permeable, seasonally waterlogged, loamy soils in the southern part of the site. This section states that peat may be present on higher ground in some areas. Brechfa Forest West Wind Farm Consultation Report 67

Para 8.55 States that soils mapping data obtained from the FCW indicates that there are no peat soils present on the FC land within the site boundary, but highlights that peatygley soils are present in approximately half the site. The ES highlights that soils descriptions were not available with the mapping, but considers the soils classification issued by the forestry commission research and development division, this indicates that peaty gley soils may have a maximum peat thickness of 0.45m and that peat overlies gley in the soil profile. Modifications to the Scheme An amendment has been made to figure 8.8. Para 8.76 Reference is made to Figure 8.8 which shows watercourse crossings and constraints. It is advised that the sub-station and temporary construction compounds are shown in relation to 50m buffers along watercourses. Para 8.79 The FCW data is historical and the origins are not States that indications from available soils mapping, provided by clear therefore it is not considered appropriate to FCW are that peat is only likely to be present on the site as an provide the detail. A site specific peat survey has upper soil layer overlaying gley soils. The section states that there now been completed and the results incorporated is no indication of peat deposits on FCW soils mapping, other than within the revised ES. in combination with gley soils. It is considered that the FCW soil mapping methodology and data should be provided as an appendix to the ES to indicate the quality of the previous mapping work and identify the extent of the mapping undertaken. It is a concern that the soil descriptions are not available with the mapping. Based on the information submitted currently it is considered that peaty deposits may be present up to a depth of 0.45m and this may affect the results of the assessment of carbon savings and payback period (which assumed depths of 0.1m only) and may also be pertinent to ecological and hydrological impacts. In the recent Mynydd y Gwair appeal decision, peat was a major consideration in the dismissal of the appeal highlighting the importance of peat with a depth above 300mm. There is a general lack of clarity and information regarding peat in the ES and no firm data or information is contained within the ES which gives certainty to whether peat deposits are present and to what depths. Para 8.79 states that in order to confirm information presented in the ES, a site reconnaissance for peat deposits will be undertaken at turbine locations, along sections of new tracks and at locations for other site infrastructure, following felling but prior to construction. This is not considered adequate and the presence of peat should be considered upfront and should be subject to further investigation and the data should be presented in the ES. It is advised that a comprehensive assessment of potential A site specific peat survey has been completed peat habitat at turbine locations and along new access tracks and the results incorporated in to the revised ES. accompanies the application to the IPC, rather than an assessment at pre-construction stage. Brechfa Forest West Wind Farm Consultation Report 68

As indicated above in the commentary on Appendix 3.1, reference Noted to the consideration of peat habitat is made in Revised Draft National Policy Statement for Renewable Infrastructure (EN-3). 2.7.38 of this document states “In addition to Section 5.3 of EN-1 there are specific considerations which should inform IPC decision-making where developments are proposed on peat. In these cases the IPC should be satisfied that the wind farm layout and construction methods have been designed to minimise soil disturbance when building and maintaining roads and tracks, turbine bases and other infrastructure. This is to ensure the development will result in minimal disruption to the ecology and that the carbon balance savings of the scheme are maximised.” Para 8.103 Impacts on water chemistry as a result of The section states that felling may need to be managed to control felling are assessed as minor significance. Some nitrate loss. It is considered that this should be monitored as it more general monitoring of nitrate levels in may have implications for quality of theAfon Tywi SAC (see Para watercourses in areas of felling will be undertaken 8.67) and remediation measures and management measures put to confirm this assessment, in association with the in place as necessary (also see suggestion under Appendix 3.1). monitoring for private water supplies Para 8.121 & Paras 8.200 – 8.207 No action- Further to the subsequent discussions Many of the proposed mitigation measures and SUDS features between the CCC and RWE NRL on this issue, it is could be multi purpose and create wetland habitats as not proposed to create wetland habitats. enhancement features. This concept has not been explored in the ES in either the hydrology chapter or the non avian ecology chapter and such concepts should be considered and described where appropriate. This could be considered in a combined water management plan, flood risk plan and habitat enhancement plan. Para 8.142 As above, there will be a HCoW engaged during It is suggested that a hydrology clerk of works and/or monitoring the construction of the development. officer be employed to inspect measures, ensure the delivery of the pollution prevention and response plan and authorise and agree certain works, particularly in periods of heavy rain or when working in close proximity to watercourses. Para 8.164 No action- The temporary runoff storage provided The intention should be to keep more water on the site for longer by flow retention features, and rates of release via SUDS and the design of wetland habitats. from storage, will be designed to prevent any increase in peak flows or flood risk. Any additional retention of water might be considered a net gain/ benefit which would be unnecessary in terms of mitigation of the hydrological impact. Para 8.211 A cumulative assessment with Bryn Llywelyn Wind The ES for Bryn Llewellyn is available and more accurate figures Farm has been incorporated in to the ES. will therefore be available. Consideration should be given to carrying out the analysis with the actual data or at least verifying if the calculations which are described in the ES as being a very approximate assessment. This will be particularly useful in undertaking any habitats regulations in combination assessment. Para 8.220 No action- It is suggested that water quality This section states that research in mid Wales has indicated that monitoring should be reviewed as the project impacts on water quality can occur over a period of about three proceeds. It is considered that monitoring beyond years following tree felling. The ES therefore states that water three years is unlikely to be necessary for the quality sampling will continue for a period of about three years reasons set out in CCC’s response. following the completion of felling in each area. It is considered that if impacts on water quality can be expected for three years following tree felling, it would be useful to continue monitoring for a period longer than three years. Details of proposed water quality monitoring should be provided in the CMS and agreed with various parties including CCC and EAW prior to implementation. Brechfa Forest West Wind Farm Consultation Report 69

An ecological/hydrological clerk of works is recommended during This is agreed by RWE NRL. the construction phase. The role could authorise certain agreed works during or after periods of heavy rain, or working near watercourses. The habitat beneath the turbines should be designed to retain Further information on SUDS measures is provided water and sediment, thus reducing the chances of it getting into watercourses. This chapter should set out clearly the hydrological regime that As above the development is seeking to achieve within the application area and how this will be managed through the lifetime of the scheme. SUDS and wetland habitat creation are expected to play a significant role in this, and more details are required at this stage. The ordinance survey map shows the presence of a sheep dip Advice has been sought from the landowner about in the area of the alignment of the proposed access track. The previous use of the sheep dip. Consideration ES should consider any pollutants or contamination or potential has been given to the potential for pollutants or impacts that may be associated with the feature. contamination as a result of this feature. Para 9.7 No action- This chapter in the ES presents an Are the IEMA guidelines the most appropriate guidance for assessment of potentially significant traffic-related this assessment? It follows that the assessment is based on environmental effects for inclusion within an ES. It a 10% threshold impact for the A485 (see para 9.49). – The is not a Transport Assessment. ‘Transport Assessment Guidelines for Development Proposals in Carmarthenshire – May 2009’ would more appropriate, which follows the principles set out in TAN 18? Table 9.1 No action- It is not considered appropriate to States discussions took place with the CCC regarding committed provide the level of detail that is requested in development in the locality and highway and infrastructure terms of scales drawings and cross sections. Some schemes which may have an effect on the feasibility. However, no further information is provided but detailed design comment on this subject has been made within the Development work will only be undertaken once the principal Control Section and no reference made to the aspects of LPA’s contractor is in place. scoping response in relation to scaled drawings and cross sections of the proposed access; advised Npower to consult with the developer of Alltwalis Wind Farm to discuss potential problems associated with the delivery route; details of a wear and tear agreement were also requested. It would be useful to see a comment regarding committed development and highway schemes even if it is to simply state there are no committed developments or highways schemes that would impact upon this proposal. Para 9.13 This has been clarified Second and forth bullet point – what criteria was used to assess the residual capacity on the existing local road network? Para 9.14 No action- SWTRA and MWTRA were consulted by It is noted that the Welsh Assembly Government have responded, RWE NRL’s specialist consultants. WAG’s Roads but no reference is made to any liaison with Traffic Wales in their and Projects division have provided a response capacity as the network managers for the motorway and trunk under the consultation road network in Wales. In addition no response has been received from the maintaining agents SWTRA and MWTRA. Para 9.17 A dry run has been completed Concern that no dry-run has been carried out. This will identify potential physical barriers / obstacles that a desk-top assessment may not pick up. Para 9.23 & 9.24 A DAS has been produced A DAS is not part of the planning application, but it is a statutory requirement and is required by legislation to accompany all planning applications (outline and full), in accordance with TAN 12 and guidance provided by Carmarthenshire County Council. Additional information in respect of the preferred access route and the implications of abnormal loads should be provided, outlining where improvements are necessary. Brechfa Forest West Wind Farm Consultation Report 70

Para 9.39 No action- It is not appropriate to produce a States that a detailed Traffic Management Plan (TMP) should be TMP until all construction details are known. agreed with the council before any development takes place. National Policy Statement EN-3, paragraph 2.7.82 Given that the TMP is referred to throughout the chapter and states that ‘Once consent for a scheme has been later used as part of the proposed mitigation, it would be useful granted, applicants should liaise with the relevant for a timetable for the TMP development and agreement to be local highway authority (or other coordinating identified. body) regarding the start of construction and the CCC is keen to discuss the draft principles of a TMP before the broad timing of deliveries. It may be necessary developer submits to the IPC. for an applicant to agree a planning obligation to Subject to these discussions it may be necessary for the local secure appropriate measures.’ RWE NRL consider highway authority to request that the IPC impose controls on this to be an appropriate approach and have the number of vehicle movements to and from the wind farm included a requirement to produce a TMP within development in a specified period during its construction and, the draft DCO. possibly, on the routeing of such movements particularly by heavy vehicles as set out in the Revised Draft of the NPS (EN-3), Cl.2.7.82. Para 9.41 The access report is included as an appendix The proposed turbines are larger than those at Alltwalis Wind Farm, therefore the developer needs to confirm the dimensions of the components being delivered along the proposed route. Reference has been made to three alternative construction routes, yet there is little in the way of assessment of the merits or problems associated with these routes from a highway safety / transportation perspective. One of the principles of EIA development is to assess alternatives. Para 9.42: New indicative junction designs have been States that a new junction arrangement is to be created between produced and are included within the revised ES the proposed access track on private land and the existing A485. Has such a direct access from the trunk road been discussed with the Welsh Assembly, Traffic Wales and / or the local highway authority? Para 9.45 States that as the traffic data obtained from CCC is not classified then a nominal 10% has been assumed to be HGV traffic. This is considered to be an appropriate assumption. Para 9.46 and 9.47 Further information on FCW felling operations and Discuss the felling operations by the Forestry Commission Wales PIAs is included in the revised chapter. (FCW). It is noted that these operations may create large HGV movements. It would be relevant to know if there is any proposed felling phased to coincide with the construction period. Regarding Personal Injury Accidents (PIA) (Para 9.49-9.53) the information provided is very broad with no details provided for any particular junctions along the A485 route. Therefore it cannot be established if there are any accident patterns. Whilst it is noted that the total PIA over 4 years appears to be quite high, no context is given regarding average or expected accident rates along this length of route. As a result, further consideration of PIAs may be needed in order to fully identify the existing conditions and likely impacts. Table 9.4 This has been corrected PIA column total is incorrect. Correct figure is 5 not 4.

Para 9.54 This is included within chapter 3. Plans, maps etc showing the evolution of the scheme’s design modifications will better explain how the proposal has advanced. Brechfa Forest West Wind Farm Consultation Report 71

Para 9.56 and 9.57 States that night time or Sunday work will not be permitted, however some work may be required during these times. It is not clear to what extent this may occur, but it is not considered to be a significant factor. Para 9.59 Confirmation has been confirmed from Tarmac- Discusses a route from a preferred quarry, this route needs to be operators of the quarry- that the appropriate agreed with CCC. Confirmation also required that the quarry has consents are in place. the relevant licences in place and capacity to provide stone for the proposed development. Cumulative impact on working this quarry needs to be assessed given that other proposed wind farms may be using it. Para 9.60 The assumption that half of the stone for the various activities could be sourced from the borrow pit appears to provide a robust assessment of residual HGV movements required. It is therefore noted that appropriate management of borrow pit stone resources could form a further mitigation measure. Para 9.64 Discusses the average number of construction staff (70) on site and concludes that the movements are minimal and should not be considered further. However the assessment should take the worst case scenario of the peak number of staff (150), although it is acknowledged the impact is still likely to be minimal. Para 9.74 & 9.75 Noted and agree with the additional 10% in order to produce a robust assessment of the length of track required. Para 9.75 This is a cautious approach. The running width of It is noted that it has been assumed that existing tracks require a standard existing forestry access track is 3.5m. half the amount of stone of that required for all tracks undergoing The new access tracks will have a running width of a full upgrade. This is an important assumption and further approximately 5m. In a number of cases, the roads justification would enable it to be verified. Notwithstanding this proposed to be used are arterial routes and will a key factor will be the determination of the optimum footprint require minimal upgrading. based upon the acceptable geometrical alignment, which again is a fundamental aspect of determining the volumes of material required depending upon the existing topography and resultant earthworks balance. Para 9.103 Cross referencing has been checked and corrected Mentions 2 additional months felling which is in contrast to the 3 months felling as stated in Para 9.55

Table 9.5 No action- This comment is incorrect. Shows total vehicle movements for the permanent anemometer mast and foundations as 170 in contrast to the 168 movements in para 9.86. Para 9.108 & 9.109 Factor derived from TEMPRO, chapter amended to Makes reference to NRTF used to factor base traffic from 2009 to clarify 2013 and a local growth factor from Carmarthenshire, however does not state where this has been taken from, assume TEMPRO? How has the 1.054 figure been reached? Table 9.7 No action- CCC did not request that assessment No assessment of impact or traffic flow increases along the A48 took place as far afield as A48/ A40 and A40, particularly at roundabouts (e.g. Cross Hands, Pensarn). Brechfa Forest West Wind Farm Consultation Report 72

Para 9.112 Cumulative assessment incorporating Bryn This paragraph states there will be a 19% increase in HGV Llywelyn has been included. movements (weekdays) along the A485 during the construction period. Concern that the cumulative impact of construction traffic relating to the proposed wind farms at Brechfa East and Bryn Llywelyn could result in a significant increase in overall HGV movements and a higher %. This cumulative impact needs to be addressed in the Chapter. Para 9.114 Agree that the 10% threshold has been exceeded and therefore requires assessment. Para 9.116 Cumulative impact could potentially exceed the 30% figure quoted in this paragraph. Also the movements may be intensive at certain times of the day especially if they take place primarily in the morning to coincide with the daily commute. Para 9.125 No action- In IEMA Guidelines, the threshold Although the pedestrian levels may be minimal on the A485 it for assessment for pedestrian amenity being a would be helpful to have a better understanding of any affected significant effect is where the background traffic communities along the route including widths of footways, flows will be halved or doubled as a result of pedestrian crossing locations and the number of properties within development. This is not the case for Brechfa close proximity to the route. Forest West, therefore no detailed assessment required. Para 9.127 Revised chapter considers these comments As referred to in Para 9.125 above, the pedestrian levels may be minimal on the A485 it would be helpful to have a better understanding of any affected communities along the route including widths of footways, pedestrian crossing locations and the number of properties within close proximity to the route. Are there any schools or other sensitive receptors in the area or directly affected along the access routes? Para 9.136 See above re TMP It appears that the TMP is a fundamental aspect of this proposal and needs to be closely co-ordinated with the construction programme. A TMP should also contain details of a road damage methodology. The condition of the road before construction traffic commences will need to be assessed in order to establish future liability. Para 9.137 Noted Detailed method statements for all mitigation measures need to be provided prior to commencement of construction operations. Para 9.139 Please refer to access appendices Highway improvements – have any assessments been carried out pre-application stage? Concern that plans showing where road widening will take place do not accompany the draft ES. There could be third party land consent implications, retaining works, ecological impact etc at these widening areas. These uncertainties make a dry run even more important. The responsibility for this is clearly defined in the Revised Draft of the NPS (EN-3), Cl.2.7.81. Will there be land issues outside the highway boundary to be dealt with? Para 9.140 Revised chapter will consider these comments Road damage is a potential residual impact. Brechfa Forest West Wind Farm Consultation Report 73

Para 9.141 Cumulative assessment has now been completed. No mention made of proposed wind farm at Bryn Llywelyn, Llanllwni? Para 9.142 As above The assessment does not take account of Bryn Llywelyn development going ahead at the same time? Table 9.9 Yes Do the figures contained here include the percentage HGV’s to/ from Dinas Quarry for the additional stone requirements?

Do the figures contained here include the percentage HGV’s to/ Please refer to ES for details from the Brechfa Forest Area in general during routine forestry harvesting?

Cumulative assessment lacking in analysis/content. Brechfa East Cumulative assessment with Bryn Llywelyn has figures can be obtained. Also Bryn Llywelyn figures should be now been completed. sought as an application has been submitted to the Local Planning Authority. Impact could be significant. Some form of commitment to phasing of construction movement is required as set out in the Revised Draft of the NPS (EN-3), Cl.2.7.83. Para 9.145 These comments have been considered in the Is confusing and appears to be incorrectly worded. revised chapter. Agree the percentage change in total number of vehicles is low and unlikely to have a major impact, however the percentage change of HGVs is more significant and so a full understanding of the impacts on the communities along the route is required. Para 9.146 Noted. Does not provide detail as to how 4-5FTE equates to 40-50 vehicles movements, however agree that the 40-50 vehicle movements stated is unlikely to provide any significant traffic related impact. Decommissioning Agree that it is not feasible to estimate traffic impact with a 25 year horizon and that decommissioning is likely to be less of an impact than construction. Table 9.10 Amended Cumulative missing from Summary table.

In summary the reviewed sections have produced no significant As above issues based upon the way the information has been presented in the draft ES. That said the assessment criteria and relevant guidance used needs to be clarified further to demonstrate and confirm that the significance of the impacts are as stated in the draft ES. The conclusions of the assessment require further evidence and the effect of the cumulative impact needs to be considered on a wider scale. More detail regarding the personal injury accident data and impacts upon local communities is requested. The importance of the TMP in managing the impact is underlined and it would be useful for a timetable for the Construction Programme / TMP development and agreement to be identified. Additional details with regard to the access to the site and within the site need to be evidenced and presented as part of the development proposal. Further review of the scoping correspondence would be beneficial. Brechfa Forest West Wind Farm Consultation Report 74

Para 10.33 and 10.39 Further information about the BBC tool and Para 10.33 states that the BBC Ofcom wind farm tool predicts process provided that the proposed wind farm would be likely to affect 43 homes for whom there is no alternative off air-air service and up to 2 homes for whom there may be an alternative service. Clarification is required as to whether these properties will be affected and whether the wind farm tool takes into account the recent digital switcher. Those properties that could be affected should be listed in the ES in order to inform the relevant occupiers of potential interference. Figures 11.1 - 11.3 Proximity information has been provided A turbine layout overlaid on these plans would indicate the proximity from relevant footpaths, bridleways etc. Turbine proximity cannot be accurately gauged at present. It is advised that a distance chart is provided detailing the proximity of each turbine from the nearest access track. The measurements provided should be based on the nearest point of the 50m micrositing area. Given the Brechfa Forest’s use as a recreational resource for No action- Horseriders have full access and use walkers, cyclists and horse riders, the developer should consider of all the tracks within the forest so can use increasing the separation distance from tracks. The British Horse alternative tracks to avoid turbines if they wish. Society’s 200m exclusion zone is considered an acceptable There are no bridleways within the development dimension in this context. area. Para 11.6 and 11.11 Further information and discussions have fed CCC Planning Services Department has discussed the proposal into the production of the draft Public Access with members of the Carmarthenshire Access Forum. The feedback Management Plan provided indicated the condition of existing tracks, bridleways and footpaths. Based on this information the developer is advised to enter into discussions with Forestry Commission Wales, Countryside Council for Wales, CCC and local access groups to establish an Access and Recreation Management Plan that sets out over the construction period and the lifetime of the proposed development, how public access and recreation in the forest will be managed and enhanced. This approach will be consistent with the provisions of TAN8 (Para 2.10, bullet 4). Para 11.8 No action- This quote is incorrect, the quote refers Revised Draft Overarching National Policy Statement for (Energy to all energy development therefore EN-1) recognises at 5.12.5 that a wind farm’s visual impact may stations, the cooling towers of coal fired power also have an impact on tourism and local businesses stations etc. That isn’t to say that wind farms don’t, but other evidence must also be taken into account. Other Guidance ROWIP has been reviewed Para 11.15 The developer is advised to consider Carmarthenshire County Council’s Right of Way Improvement Plan (ROWIP) 2007 – 2017. Details of which can be provided by CCC’s Rights of Way Section. Recreation and Tourism A review of available information has taken place. Para 11.21 – 11.24 More detail of the baseline conditions relating to tourism in the area is required. For example data derived from the Scarborough Tourism Economic Activity Monitor (STEAM) may establish statistics relating to tourist accommodation in the area. Discussions with the Visit Wales and local tourism agencies are encouraged. Are there any figures relating to visitor numbers from Ireland and further afield? Brechfa Forest West Wind Farm Consultation Report 75

Walking No action- This is stated in para 11.27 Para 11.31 This paragraph needs to highlight the ‘right to roam’ in the forest. Para 11.36 There will be alternative tracks for cyclists to use elsewhere in the Brechfa Forest; however, these may be impacted upon by possible building operations associated with the proposed Brechfa Forest East wind farm. Tourism No action- Robust information to back up this Para 11.46, 11.72 and 11.89 assertion has been requested from CCC but has It is considered that the importance of tourism in north not been forthcoming. Carmarthenshire has been underestimated in the ES. Strong anecdotal evidence suggests that visits to the Brechfa Forest area linked to the quality of the landscape. The development of wind turbines could have a detrimental impact upon tourists’ perception of the area. It is advised that further assessment is made of the proposal’s impact upon tourism as a socio-economic resource. Mitigation measures could include investment in improving the access network in the forest and surrounding area and the use of appropriate promotion and publicity. Para 11.52 – 11.55 No action- This is incorporated into the ES. Consideration of less able bodied / disabled users of the forest needs to be taken into account. Table 1.5 No action- Information has been requested from The residual impacts upon public and equestrian access during CCC about who considers this and why, but the construction phase are described as ‘minor adverse’. It is information has not been forthcoming. considered that the impacts of a project of this scale on an area used by the public for a range of recreational activities, is going to be greater than ‘minor adverse’ Overall it is considered that the various tables in the chapter As above misrepresent the impact of the proposals. The construction of a large engineering project in forest that the public use for a range of recreational activities could have a negative impact upon these users, both during construction and operational phases. Para 12.32 As above It would be useful if maps of the modifications to the scheme design were provided as part of the ES to give a clearer understanding of the schemes evolution and to examine alternatives that have been disregarded. Confirmation is required of the legal aspect of taking forest land No action- It is suggested that this information is out of the forest and using for development i.e. turbine bases, sought from the Welsh Government as owners of crane pads and new access tracks. The same clarity is required for the land. land designated under the CROW Para 13.8 – Footnote This has been subject to further discussion The footnote states that a short stretch of 110m of the new track between RWE NRL’s ecologists and CCC and the substation located in the south east corner of the site was not subject to a full phase 1 survey. The ES states that data was collated using local field data. There is no information however on what constitutes local field and what information/actual methodology was used in assessing the area. Phase 1 is an important baseline and this information should be provided. Furthermore the ES states that the area is distinguished on the phase 1 habitat map. However this does not appear to be the case. This are should be clearly highlighted on the phase 1 map. Brechfa Forest West Wind Farm Consultation Report 76

Legislation This is clarified in the revised text Para 13.21 There is insufficient evidence of relevant biodiversity enhancement within the ES. Para 13.26 As above The ES does not recognise the opportunity that this proposal creates for enhancing, extending and re-creating habitats of significant wildlife and landscape value. This application should be demonstrating a net gain for biodiversity. Para 13.32 ‘Managing for Environmental Quality’ section of WAG strategy for Woodland and Trees makes reference to the following: All woodlands are managed to high standards of environmental stewardship, Safeguarding and enhancing biodiversity, water quality and water resources, soil resources and soil function, landscape and the historic environment Para 13.53 No action- No Himalayan Balsam was recorded This section references Japanese Knotweed as a controlled non therefore no action is proposed native invasive species under the Wildlife and Countryside Act (WCA) 1981. The document also considers its presence and necessary management during the development, however there is no mention of Himalayan Balsam. The presence of Himalayan Balsam (which is also listed under the same schedule in the WCA) should be considered and reported in the ES and where necessary, measures should be put in place to control or eradicate the species as appropriate. Para 13.238 The Rhos-Wen pond will be covered as an The ES states that no detrimental impacts are predicted on the individual section in the final CMS Rhos-wen Pib Conservation Pond, however it should be noted that the pond is located close by to the borrow pit, access tracks and a bend where the access track crosses the Afon Pib. It is therefore considered that this area should be examined closely within the CMS to ensure adequate and robust pollution control measures are in place. Para 13.242 This has been discussed further at subsequent The ES states that a radius of 47m around each turbine base will meetings and proposals are clarified in the text. remain free of trees. The ES states that natural colonisation will be permitted but it will be managed to ensure a scrub layer does not establish. The ES when examining the impact of certain species including bats and birds does not appear to have considered the effects this change of management may have on species within the area. It is considered that the management of the 47m buffer zones may encourage invertebrate populations to increase, which may in turn alter bat foraging patterns and may encourage bats/ birds into the areas and as a result these species may be more vulnerable to direct collision or barotrauma. The ES should be clearer about the proposed management of the 47m radius areas and the management proposals should be detailed as part of the Habitat Management Plan (HMP). It is considered that the ES should set out a strict monitoring plan to monitor vegetation development and invertebrate numbers within the 47m buffers post construction. Bat and bird mortality monitoring should also be undertaken and a methodology detailed in the HMP. This should ideally be undertaken for the lifetime of the development. If any correlation is identified between bat and bird mortality and the vegetation and invertebrate data in the 47 metre radius areas, then measures should be put in place to reduce mortalities, this may include removing vegetation from beneath the turbines. Brechfa Forest West Wind Farm Consultation Report 77

Table 13.30 As above Habitat mitigation and enhancement should be provided for all semi natural areas that will be subject to losses as identified in Table 13.30. This should include marshy grassland, marshy grassland and scattered scrub, broadleaved woodland, standing water (ponds), wet dwarf heath and wet heath/grassland mosaic. Some of these habitats are biodiversity action plan habitats and listed on section 42 of the Natural Environment and Rural Communities (NERC) Act, 2006, and therefore are a material consideration in the planning process. A scheme of this size should provide mitigation/enhancement for all Biodiversity Action Plan (BAP) and Section 42 habitats. The Assembly Government sets out its commitment to the BAP process in section 5.2 of Planning Policy Wales which indicates that planning authorities should further the conservation of habitats and species of principle importance through their planning function. Technical Advice Note 5 - nature conservation and planning states that a key principle for positive planning for nature conservation should look for development to provide a net benefit for biodiversity conservation with no significant loss of habitats or populations of species, locally or nationally. TAN 5 also states that where development proposals may affect As above national or local BAP habitats or species, the same principles as to locally designated sites apply. It is therefore considered that the developer should avoid harm to BAP habitats or species where possible and where harm is unavoidable it should be minimised by mitigation measures and offset as far as possible by compensation measures designed to ensure there is no reduction in the overall nature conservation value of the area or feature. Given the size of the proposed development and that much of the As above site will be opened up for the installation of the turbines, provision of mitigation and enhancement for these habitats should be fully achievable and it is considered that this should be fully addressed in the ES and the HMP (despite not being assessed as significant in Table 13.32). Monitoring the success of the proposed mitigation should also form part of the HMP. The field pond referred to in Para 13.67 as a pond with good water This pond will not be lost. clarity, aquatic vegetation and adjacent scrub habitats will be lost to the proposal and this should be fully mitigated. A check for amphibians using the pond should be made prior to works and any amphibians found should be translocated elsewhere if possible to avoid harm. Table 13.31 This is proposed and set out in the revised ES Mitigation should also be included for any hedgerows/tree lines that will be lost as documented in Table 13.31. Para 13.244 As above Is the proposed management of the 47m felling areas intended as habitat mitigation for the scheme? This should be made clear and fully documented in the ES and HMP if this is the case. Also see relevant comments under Para 13.242. If remediation is required due to monitoring findings for bat mortality, then alternative mitigation for habitat should be proposed and put in place, this should be assessed by the HMP steering group on a regular basis. Brechfa Forest West Wind Farm Consultation Report 78

Paras 13.261 – 13.263 Further clarification has been provided in the Para 13.261 highlights an otter shelter approximately 115m revised ES from the access track between turbines 9 and 10. This will be considered as a resting place under the Conservation of Habitats and Species Regulations 2010. The assessment undertaken under Paras 13.261 – 13.263 have not considered the impacts of noise and the associated disturbance on otter. It is considered that noise and disturbance is a likely significant impact which has not been addressed in the ES and may alter the significance assessment as detailed in Tables 13.33 and 13.34. Furthermore it is considered likely that a WAG otter licence will be required to carry out the works, the requirements of such should be discussed with CCW. If a licence will be required a mitigation statement considering otter disturbance should be detailed as part of the ES. This issue should also be considered more fully in the ES even if a licence is not required. Para 13.276 As above Section 13.276 states that offsite mitigation will be delivered through the restoration of PAWS habitat within the wider Brechfa Forest area. It is considered that this proposed mitigation is inadequate. The mitigation is largely offsite and addresses a habitat which is not significantly affected by the proposals. Furthermore it is considered that clarification should be sought on the PAWS project, if the project is existing, is underway and there is a commitment or statutory obligation to undertake the work anyway, it is considered that this should not be considered adequate mitigation for the development proposal. An activity or commitment which will be delivered anyway should not count as adequate, mitigation or compensation for the proposed wind farm scheme. Para 13.282 Further discussions have taken place and further See comments under Para 8.121 & Paras 8.200 – 8.207, Para clarification/ information provided. 13.242 and 13.244. On site enhancement - “Creation of undulating topography” - this needs to be expanded so it is clear in the ES exactly what is being created and over what area and with what objectives. Para 13.283 Standard procedures re Japanese Knotweed/ other It is considered that the eradication of Japanese Knotweed should invasive species will be referred to. A commitment be undertaken as a general site/habitat enhancement and details to eradicate Japanese Knotweed within the of a Japanese Knotweed control/eradication strategy should be development area has been made. included within the HMP/CMS. The presence of Himalayan Balsam should also be considered as detailed in Para 13.53. Para 13.289 This is clarified in the revised ES/ HMP Details of the proposed enhancement measures should be detailed in the HMP and monitoring should also be put in place and detailed in the HMP. Also see comments under Para 13.276. Cumulative Construction Impacts Cumulative assessment with Bryn Llywelyn has Para 13.308 been done See comments under Para 2.18. Para 13.320 & 13.321 Further detail provided See concerns detailed under Para 13.242, this may affect the significance assessment? Para 13.340 As above The ES for Bryn Llewellyn is available and more accurate figures will therefore be available. Consideration should be given to carrying out the analysis with the actual data. Brechfa Forest West Wind Farm Consultation Report 79

The pond above Tyllwyd, at SN 489307, is not referred to in the These comments have been reviewed and revisions ES Habitat Mitigation and enhancement is considered necessary made where appropriate regarding the losses of the semi-natural areas identified in the ES, and the opening up of the forest for the installation of turbines does provide an opportunity to do this. As stated above wetland habitats should be a feature of a habitat enhancement scheme, together with heathland habitats, scrub some grasslands etc. Mitigation should address the loss of the Phase 1 habitats noted in table 13.30 regardless of the significance of impact noted in table 13.32 Para 14.72 ES text amended to reflect more clearly legislative Surveys/assessment should also be undertaken for all nesting requirement regarding nesting birds. birds prior to vegetation clearance or vegetation clearance should be undertaken outside the nesting bird season. The proposed measures detailed in this section of the ES only appear relevant to schedule 1 birds. However all nesting birds are protected under the Wildlife and Countryside Act 1981 and should be a consideration. Paras 14.62 – 14.68, 14.76, 14.85 – 14.86, 14.91 - 14.102, This has been subsequently discussed with FCW/ 14.121 – 14.122, 14.125 – 14.128 and Appendix 13.10 DHMP CCW/ CCC and clarification provided on nightjars Nightjars are sensitive to disturbance at breeding sites. An analysis in the text of the ES/ HMP of operational noise on nightjars concluded that approximately 40% of the population within the site could be affected. There is currently no information on whether the presence and movement of operational turbines might have any displacement affect on nightjars. The ES highlights there is no published information on whether nightjars can be displaced by the noise created by operating turbines, but the ES highlights that it is reasonable to expect that impacts will reduce with distance. Para 14.125 of the ES states that the severity of the potential effects of most wind turbine related impacts, including noise, decreases with the distance away from the turbines and that the most effective forms of mitigation for potential operational noise impacts on nightjar are likely to include ensuring that nesting habitat is available away from turbine locations and that areas near the turbines are less attractive for nightjar nesting. The ES and DHMP sets out mitigation including making areas around the turbines unattractive to nightjar and carrying out a programme of post construction monitoring or nightjar to gather evidence as to whether nightjar are negatively affected by the turbines. It is considered this would be valuable and details of the monitoring protocols should be detailed in the HMP. No other mitigation is proposed and the ES states that only if the monitoring finds that nightjars are being affected by the turbines, will mitigation be put in place. This is considered inadequate and it is considered prudent that offsite mitigation for nightjar should also be put in place prior to the development commencing (following the precautionary principle assuming that there will be a significant negative effect on nightjar) and monitored. This will also allow the direct comparison between mitigation areas and non mitigation areas and also provide valuable monitoring data, this approach will also ensure that there will not be a time lag in delivering mitigation, if a significant affect is identified by monitoring, the provision of offsite nightjar mitigation and monitoring should be ongoing and detailed in the HMP. Brechfa Forest West Wind Farm Consultation Report 80

Para 14.138 Cumulative assessment with Bryn Llywelyn The ES for Bryn Llewellyn is available and more accurate figures completed will therefore be available. Consideration should be given to carrying out the analysis with the actual data. Para 1.5 Further discussions have taken place on HMP and Para 1.5 states that six conservation features have been identified revisions made accordingly in the DHMP, however it appears to contain only five. Taking into account the comments above I consider the DHMP is generally lacking and it should also include sections on the management of the 47m buffer zones, mitigation measures for heath and grassland habitats, details of mitigation and the protection of ponds, details of pine marten and pole cat mitigation, hedgerow and tree line mitigation and details of monitoring where relevant, including, vegetation monitoring, invertebrate monitoring, bat mortality monitoring, nightjar monitoring etc. Para 3.7 No action- It is not appropriate to include detailed There is no indication/consideration of costings for the proposed costings- the important consideration is that the mitigation, this should potentially be considered to ensure the mitigation is delivered effectively, not how much proposed mitigation is feasible and deliverable in the long term. it costs. Table 3.1 This will be considered at the point of Due to the timescales and the types of management involved, decommissioning- HMP text revised to reflect this. reptiles and bryophyte mitigation may be a consideration at the decommissioning stage. This is currently not considered. Any potential impacts should be documented and mitigation proposed. Brechfa Forest West Wind Farm Consultation Report 81

Paras 15.4 - 15.57 All comments regarding L&V methodology and The ES description of computer modelling and methods employed assessments have been reviewed and appropriate for creating visualisations are in line with best practice. It is action taken within the ES- please refer to ES considered that the assessment methodology is reasonable and chapter for details clearly set out; methodology for defining baseline, magnitude of change and significance criteria is broadly consistent with current best practice and widely-accepted national guidelines published in relation to the assessment of landscape and visual impacts. However, with reference to Significance Criteria paras. 15.50 to 15.53 and Table 15.2 the following observations are noted: - The ES states that in para. 15.52. that ‘The predicted impacts in this LVIA are based on a multifaceted assessment using professional judgement and consideration of the sensitivity of the receptor/ resource and the magnitude of change...... it should be noted that there is a gradual transition between categories and the two axes are not necessarily evenly weighted and therefore the final decision on significance comes down to a professional judgement. It is considered that the ‘gradual transition between categories’ described in the ES reflects the continuum of levels of sensitivity and magnitude of change. The same gradual transition between categories also applies to significance. It is noted that the ES assessment utilises interim categories for impacts of minor/ negligible significance [e.g. Viewpoints 21, 30 and 31] i.e. the ES provides an indication that the impact is assessed to be between minor and negligible. This effectively addresses the nature of significance as a ‘gradual transition’ and acknowledges that the significance of impact is judged to be between the levels limited by the defined categories. It is noted that interim categories are not utilised for definition of assessments for other levels of significance. It is considered that a more transparent representation of the gradual transition of significance assessments would be provided through utilising interim levels of significance. Otherwise, it is considered that the assessment methodology is generally, and appropriately consistent with criteria set out in the Scoping The CCC review of ES assessments provided under the following sections of this report follows the methodology of the ES, however, interim levels of significance are utilised to allow an overview of the transition between categories. Para 15.91. This minor amendment has been made. ‘There are several existing forest tracks which pass through the wind farm site.’ The Brechfa Forest area is open access land, this factor, and the nature of public access within the site boundary has not been addressed in the description of ‘existing conditions.’ Table 15.10 This minor amendment has been made. Typo: SLA reference to Sensitive Landscape Area - should read Special Landscape Area as CCC Adopted UDP. Visual Baseline Para 15.110-15.116 incl. Table 15.11 The visual baseline is described in terms of representational viewpoints and views from settlements. Representative viewpoints are in accordance with recommendations and comments presented as part of the consultation process. The settlements identified within the visual baseline are appropriate and representative. However, the visual baseline does not take into consideration the visual receptors using the Brechfa Forest area as a recreational resource. Otherwise, it is considered that the visual baseline is generally, and appropriately consistent with criteria set out in the Scoping Brechfa Forest West Wind Farm Consultation Report 82

Modifications to Scheme Design [Designed in Mitigation] Turbine locations provided. A footnote has been Para 15.129 included explaining why materials will not be …The wind farm has been designed.... The following aims were specified at this stage. observed to achieve a visually acceptable design: • Turbines were placed to relate to the topography of the landscape; • Avoidance of turbines seen at a great variety of levels; • Avoidance of turbines specifically located at high points were avoided, which may then look prominent above the rest; Locations [grid references] of proposed turbines have not been provided in the ES. Elevations [AOD] of proposed turbine locations have not been provided in the ES to allow the statements concerning design of the relative elevations of turbines to be corroborated. This information should be provided. It is noted that the CCC Scoping Response specifically identifies [at 3.13] the requirement for the specification of materials – colour, reflectivity and texture. It is considered that appropriate details of the finishes of the proposed turbines have not been provided in the ES. Brechfa Forest West Wind Farm Consultation Report 83

Para 15.132 Further information on alternative access options Comments on Site Access has been provided. RWE NRL have investigated The ES does not present details of alternative access options, from in some detail the possibility of utilising the the A485, considered in the design process in terms of landscape existing access for the Alltwalis Wind Farm. and visual impacts. Unfortunately it has not been possible to reach Modifications to scheme design, in para.9.54 [Access, Traffic and a commercial agreement with the landowner. In Transportation] does not present any evidence of consideration of order to mitigate the issues raised by a range of alternative access routes. groups and individuals who have responded to the Further to the above, the ES states [para 3.27.] ‘A number of consultation, screening is proposed to mitigate options were considered for accessing the site for the delivery of landscape and ecological impacts associated with turbines and other construction parts and machinery. Following the new access track. discussions with CCC and an assessment of the routes using swept-path analysis, a preferred access route has been assessed in the EIA (illustrated in Figure 9.1).’ It is unclear from the ES whether the options considered included alternative access options from the A485. Discussions have not been directly undertaken with CCC in respect of the potential landscape and visual impact of access options. Para. 9.41 states that ‘the 2009 Access Study’, considered three routes for the transportation of abnormal loads including a route via an unclassified road at New Inn. However, details of this study have not been provided in the ES; as such, transparent reasons for selection of the preferred route have not been provided. The ES states para. 3.28. ‘The preferred access route to the site assumes that vehicles will leave the M4 at Junction 49 .... before turning north of the Alltwalis Wind Farm onto a new access track across agricultural land to the west of the site... It should be noted that the proposed entrance is located approximately 200m to the north of the existing Alltwalis wind turbine development site entrance. The proposed access would entail creation of a new site entrance accommodating sufficient swept path area for turbine component delivery and visibility splays. The eastern highway boundary at this point is formed by existing tree line [possibly mature remnant hedge] interspersed with smaller apparently naturally regenerated vegetation to an earth bank. The existing roadside boundary forms an important element of local landscape character to the road corridor and provides screening of views, both of the existing Alltwalis wind turbine development and the proposed Brechfa West development, from the A485, and from residential properties to the west of the A485 orientated towards the combined developments. The formation of a new site entrance and associated removal of a section of the eastern highway boundary would result in local landscape and visual impacts. In addition to these impacts, the formation of approximately 2km of new access track from the proposed site entrance would result in additional landscape and visual impacts. The new access track would climb, predominantly perpendicular to the contours, from approximately 200m AOD to 335 AOD to the forested area. The track would traverse open hill land which has depleted hedgerow cover. It is considered that the new access track would be visible in even medium and long range views from the west and north west and would result in adverse visual impacts and landscape impacts to the area traversed by the access road. Brechfa Forest West Wind Farm Consultation Report 84

An iterative design approach, as recommended in best practice guidance, would suggest consideration of alternative access options from the A485 to mitigate for these impacts. As stated above it is considered that the ES does not provide transparent evidence of this process or justification for the preferred route. Further to the above, observation of the scheme proposals indicate two obvious alternative access options from the A485: - A Utilisation of the existing site entrance for the Alltwalis wind turbine site, and existing track to a suitable point for access to the proposed Brechfa West development. This option would avoid the landscape and visual impacts arising from creation of a new site entrance and construction of 2km of new access tracks outside the forested area. B Continuation north along the A485 to the right turn junction in New Inn [SN472367]. It should be noted that this is the proposed access route for the proposed Bryn Llywelyn wind turbine development [subject to a current planning application – E/23947 refers)]. From this junction, a minor road leads to potential site access options on existing road/tracks to the forested area [junction south at SN486354; or, existing forestry track access at SN495354]. This option would not require construction of new access tracks outside the forested area, and as this route has been identified for a proposed development for 127m to blade tip turbines it would be expected that this would represent a viable route. Whilst the alternatives identified above have not been detailed in the ES, it would appear that both of the above options would appear to provide favourable alternatives to the proposed access route from the A485. It is not clear within the ES whether these options have been considered, and if so, justification for the proposed entrance and access as a preferred route from the A485 has not been provided. Notwithstanding the above, it is considered that the landscape and visual impacts of the proposed access track from the A485 to the forested area have not been adequately addressed within the ES. Brechfa Forest West Wind Farm Consultation Report 85

Para 15.134 An explanation of why it is not possible to cut Discussion of general design issues ‘Brechfa Forest West Wind down more trees and reduce the height of Farm was also designed to be as compatible as possible with the turbines has been provided. existing turbines of the Alltwalis Wind Farm - bearing in mind that Also a scaled comparative drawing of Alltwalis the turbines at Brechfa Forest West Wind Farm are likely to have turbines compared to Brechfa Forest West turbines hub heights of around 100m to avoid areas of turbulence above is provided. the tree canopy.’ The proposal is based upon 145m to blade tip turbine structures with, as stated, hub heights of around 100m to avoid areas of turbulence above the tree canopy. The ES does not provide transparent justification of the relationship between turbine size and the dynamics of turbulence. An obvious design stage mitigation to landscape and visual impacts would be the specification of smaller turbines. Draft NPS EN-1 - para 5.9.20 states ‘Reducing the scale of a project can help to mitigate the visual and landscape effects of a proposed project. ...’ It would be expected that a reduction in turbine size would have potential mitigation benefits beyond landscape and visual impacts - e.g. access. Further to the above, the ES states that permission is being sought for turbines with capacity of 2-3MW [para. 3.14]. It is considered that the ES does not provide satisfactory details of the relationship between turbulence effects and justification for the requirement for the turbine size selected. It should be questioned whether capacity within this range could be achieved with a smaller turbine than the maximum for which permission is sought. Whilst the general principle of turbulence is accepted, it is considered that the requirement for turbines to 100m hub height should be interrogated and additional information provided to justify the design size of the turbines and to allow the decision maker to fully consider the appropriateness of the scheme design. Further to the above, it is noted that an area of 47m radius is proposed for permanent clearance around each turbine site. The potential trade off of impacts between area cleared and required turbine height for the same generation capacity objective does not appear to have been explored. It would be expected that greater clearance could help to result in a smaller turbine for the capacity objective. In addition, there would be a benefit, in terms of mitigation of landscape and visual impacts by selecting turbines of a dimension more comparable to Alltwalis [110m to blade tip] in terms of the ES aspirations to achieve a better overall relationship with Alltwalis Wind Farm [ES 3.70] It should be noted that all landscape and visual assessment has been based upon a turbine of 90m diameter, as such all identified impacts relate to this dimension. It is considered that this should be defined as a maximum design parameter upon which decisions are based, as all impact assessments have been based upon this dimension. Further to the above it is recommended that additional graphic material, in the form of a scaled elevation, be requested, providing an image in which direct visual comparison between the existing Alltwalis turbines and the proposed Brechfa Forest West turbines can be made. This would provide a useful additional assessment tool for the decision maker. Details of tower diameters [at base, midpoint and top] would be beneficial. Brechfa Forest West Wind Farm Consultation Report 86

Para 15.134 This paragraph has been reviewed and revisions Brechfa Forest West Wind Farm was also designed to be as made where appropriate compatible as possible with the existing turbines of the Alltwalis Wind Farm - ... The Alltwalis turbines have a hub height of 68.5m and are located on higher land whereas the Brechfa Forest West Wind Farm turbines will have a hub height of around 100m and are located on lower ground… This statement has been interrogated and is found to be factually inaccurate. In the absence of AOD information in the ES, an approximation using contours on OS Explorer Map 1:25000 with estimation to the nearest 5m has been used to compare relative elevations of both existing Alltwalis and proposed Brechfa West Turbines. The table demonstrates the following points:- • The base AODs of 4 no. Brechfa West turbines are higher than base AODs of the highest Alltwalis turbine. • Only four Brechfa West turbines have lower base AODs than the base AOD of the lowest Alltwalis turbine. Accordingly, the statement that the Alltwalis turbines are located on higher ground relative to proposed Brechfa West turbines is not considered to be an accurate representation of the proposal. The table above also demonstrates the following:- • The highest Brechfa West turbine base AOD is 15m higher than the highest Alltwalis turbine base AOD. • All but one of the Brechfa West turbines have a higher tip AOD than the highest Alltwalis turbine tip AOD. • The nearest Brechfa West turbines to the Alltwalis development [3, 4, 8, 9, 13, 14, 17, 18, and 19] are amongst the highest within the proposed development. This would suggest that the stated aims to achieve a design as compatible as possible with the existing turbines of the Alltwalis Wind Farm have not been effectively delivered in the scheme design. • The highest Brechfa West turbine tip AOD [no.13] is 50m higher than the highest Alltwalis turbine tip AOD, i.e. 45% higher. In light of para 5.9.16 of Draft NPS EN-1; that ‘the The IPC should As above consider whether the project has been designed carefully, taking account of environmental effects on the landscape and siting, operational and other relevant constraints, to minimise harm to the landscape, including by reasonable mitigation’. It is suggested that design stage in mitigation could be expected to consider the following opportunities ‘to minimise harm to the landscape:- A Reduce the size of all turbines [within the scope of the 2-3MW capacity objectives] B Increase clearance areas around turbines to allow reduction in turbine height. C Reduce the size of western turbines [potentially 3, 4, 8, 9, 13, 14, 17, 18, and 19] to improve visual compatibility with existing Alltwalis turbines It is considered that alternatives have not been transparently explored and sufficient justification has not been provided to demonstrate that design stage mitigation has been undertaken to minimise harm to the landscape. It is recommended that further information be provided to inform decision makers of the design parameters in relation to turbulence/ turbine size/ clearance and whether the options outlined above have been explored to provide mitigation for significant landscape and visual impacts. Brechfa Forest West Wind Farm Consultation Report 87

Para 15.135 ‘The other proposed wind farm partially within the SSA is Bryn Llywelyn...– this layout showed 21 turbines and accompanying literature proposed a maximum tip height of 127m...’ A smaller turbine size for Brechfa West would also improve visual compatibility with the proposed turbines at the adjacent site at Bryn Llywelyn. Para 15.136 As above The description of effects resulting in potential impacts on landscape and visual amenity during construction, only identifies the plan areas of the infrastructure elements and does not provide a quantification of associated areas of clearance and peripheral construction requirements, as such it is concluded that the assessment of impacts does not include the landscape and visual effects arising from the following:- - Temporary felling areas as referenced in para. 15.139 as 19% of existing coniferous forestry cover. Illustrated on Fig.15.2 - Permanent felling areas around turbine locations of 47m radius. [Para 13.242] all infrastructure elements. - Additional widths of [up to] 2.7m width for cable array trenches associated with access tracks, plus any required offset and any associated drainage requirements. It is noted that extended dimensions are used in Habitat loss calculations described in para.13.228 and Table 13.29. Para 13.228 acknowledges that ‘Habitat loss dimensions are larger than the dimensions for infrastructure to allow for excavation slope edges, and peripheral habitat loss...’ These extended dimensions have not been described under landscape and visual effects. It is considered that this is an oversight in the ES and would result in an understatement of the landscape and visual impacts arising from the construction phase of the scheme. Para 15.137 As above Cross reference to Appendix 3.3 para 29. It is considered that the local impacts to landscape character arising from the removal of roadside boundary vegetation; and the visual impact upon residents to the west of the A485 at the proposed site entrance have not been sufficiently covered within the ES. Para 15.137 ‘In addition, some limited construction related impacts will occur offsite...... Further to these, offsite impacts will arise due to the creation of the grid connection to Swansea North via an overhead line (subject to a separate application), as described in Appendix 3.2. Brechfa Forest West Wind Farm Consultation Report 88

Comments relating to Grid Connection Route Assessment. Please see previous comments relating to grid It is stated in the ES that the proposed Grid Connection will be connection assessment subject to a separate planning application by Western Power No action Distribution. It should be noted that baseline visual conditions in the form of features/ receptors are not identified in Table 1: Summary of baseline conditions. Some brief commentary upon visual impacts is provided in paras 41 to 52 however the assessment is not comprehensive. The CCC Scoping Opinion response states that Landscape and visual impacts arising from ancillary and related elements of the proposal should be included within the ES to provide full representation of the potential impacts. Ancillary elements related to this proposal with potential landscape and visual impacts would be expected to include the following:- • Proposed connections to the National Grid, including connection point, pylons and proposed route corridor.’’ It is not considered that a full or sufficient representation of the potential impacts has been provided in the ES. Based upon information presented in ES Appendix 3.2, the route appears to be located along a sensitive corridor. Initial broad scale review of the route reveals that approximately 70% of the combined Brechfa East and West grid connection route passes through LANDMAP Visual and Sensory Aspect Areas of either High or Outstanding value. The ES identifies important historic landscape features and visitor attractions within the route corridor or within the study area Further to the above, the ES does not explore alternative options for the Grid Connection which may represent less significant impacts upon landscape and visual amenity. It is noted that Draft NPS EN-1 para. 4.4.2 [first bullet] states that ‘applicants are obliged to include in their ES, as a matter of fact, information about the main alternatives they have studied. This should include an indication of the main reasons for the applicant’s choice, taking into account the environmental, social and economic effects and including, where relevant, technical and commercial feasibility; It should be noted that the paragraph above refers directly to environmental and social effects which can be considered to relate to impacts upon landscape and visual amenity. It is considered that the proposed grid connection should be fit for purpose and should ideally provide the necessary infrastructure for all the proposed developments and for further schemes that may be forthcoming in the SSA. The connection should also provide enough capacity for these schemes, to avoid the connection requiring further upgrading in the future, which may result in landscape and visual impacts of greater significance. The cumulative landscape and visual impacts of the effects with the proposed developments and the grid connection should be considered as part of an appropriate landscape and visual assessment. Brechfa Forest West Wind Farm Consultation Report 89

Para.15.146. As above ‘Beyond the wind farm site, perception of construction activities will be limited to views of cranes and assembly of turbines above the tree canopy, offsite works to access routes, and abnormal loads using these routes. Coniferous forest will screen views of ground level elements and activity. The extent of visibility of cranes and partly constructed turbines will be the same as for the turbines during operation which is described in detail in the assessment of operational indirect effects on the landscape’ It should be noted that the additional effects of clearance works for infrastructure and access tracks; i.e. temporary felling areas [19% of existing coniferous forestry] will be evident in views from the surrounding area and would be expected to contribute to indirect impacts on landscape. These elements of the construction phase have not been included in description of the predicted impacts within the ES. It is considered that landscape character areas represented by the following viewpoints will be subject to these additional effects: - Viewpoint 1 - Mynydd Llanfihangel-rhos- y-corn summit; Viewpoint 3 - Gwarallt; Viewpoint 5 - Plasmawr/ Danybanc; Viewpoint 8 - East of Gilfach-y-rhiw. Para. 15.148 Further to comments relating to existing conditions and visual baseline, [i.e. the ES does not take into consideration the visual receptors using the Brechfa Forest area within the site boundary as a recreational resource.] Assessment of impacts of these receptors has not been addressed in the ES. Chapter 3 addresses the nature of access and concludes that public access will be maintained during construction. Assessment of construction impacts upon the visual amenity of recreational users of the Brechfa Forest area within the site boundary should be included in the ES. It would be expected that the impacts would be major significance and of an adverse nature. Para. 15.154. The presence of permanent clearance areas of 47m radius per turbine is not identified as a main potential impact on landscape and visual amenity. Anemometer mast description [second bullet] states ‘on concrete hard standing of 1000m2’; this specification is not detailed elsewhere in the ES - Clarification should be requested. Table 15.13 Impact on Wales Landscape Character Areas within 35km of site 21 Cambrian Mountains The ES concludes an assessment of overall negligible impact upon the LCA as a whole, however, it should be noted by the decision maker that the assessment identifies landscape impacts of major significance in areas of high sensitivity up to about 2-3 km of the site and impacts of moderate significance up to about 5 km from the site. It is acknowledged that these impacts are considered in more detail in the LANDMAP aspect area assessments. Table 15.14: Impact on LANDMAP Aspect areas directly affected Brechfa Forest CMRTVS330 The ES only addresses the turbine structures in the commentary on magnitude of change and does not include the effects arising from infrastructure and permanent clearance within the forested areas; however, it is not considered that this would have any implication to the overall significance of effect. It is considered that the proposed development would have a major, long term, adverse, direct impact upon the area defined by the aspect area [as ES assessment] Brechfa Forest West Wind Farm Consultation Report 90

Mynydd Trebeddau CMRTVS870 This aspect area is assessed in terms of the direct impacts of the proposed access track from the A485 to the forested area. However, it is noted that this aspect area will also be indirectly affected by the impact of the turbines within the adjacent aspect area. The ES does not provide an assessment of these impacts upon landscape character. This should be provided. It would be expected that the impacts would be of moderate significance and of an adverse, long term nature. Table 15.15: Significant Impacts on LANDMAP Visual and Sensory Aspect areas within 10km of site Mynydd Llanllwni CRMRTVS734 It is considered that the significance of impacts to this visual and sensory aspect area has been understated in the ES. The sensitivity to Wind Farm Development is assessed as high in the ES; this is considered appropriate. However, the magnitude of change is considered to be of a medium/high order, as the proposed development will represent a prominent interruption within the 360 degree views for which the aspect area is identified as important on a county scale in LANDMAP. It is considered that the impact upon this visual and sensory aspect area would be major/moderate, long-term, adverse [Significant] 15.161 and Table 15.16: Typo: SLA reference to Sensitive Landscape Area - should read Special Landscape Area as CCC Adopted UDP. Otherwise no adverse comments or observations General Comments: Viewpoint plans and associated data are well presented and thorough in terms of information provided. Viewpoint visual representations and photomontages are of good quality, however, the following should be noted by decision makers when viewing the representations: Viewpoint representations to be viewed at 45 cm [recommended viewing distance] are generally not able to be viewed as a continuous panorama i.e. continuations are on separate pages or separated by A3 page bindings [this is not in compliance with best practice as set out in Visual Representation of Wind Farms: Good Practice Guide; it may be considered appropriate to request fold out copies of representations, to aid assessment. Wireframe representations indicate all turbines in an unnatural arrangement in terms of blade orientation, all rotors are presented symmetrically. This may result in a visual perception of order which would not be evident in an operational situation. It is acknowledged that photomontages indicate a natural randomisation of rotor angles. CCC review of ES Viewpoint Assessments. This detail has not been included in this Consultation Report for brevity but all comments have been reviewed and any amendments incorporated in the revised ES Brechfa Forest West Wind Farm Consultation Report 91

Summary comments on CCC Review of ES Viewpoint Assessments The review of the viewpoint assessment has identified some instances in which it is considered that the magnitude of change or viewpoint sensitivity has been understated in the ES. Where this is considered to be the case a revised assessment has been provided as part of the CCC review. These revised assessments are based upon professional judgement on the information presented in the ES and site observation. The CCC review has utilised interim levels of significance [between criteria identified in the ES Table 5.12] to allow identification of significance between moderate and major. Notwithstanding the outcome of the review, it should be noted that the revised assessments do not change the pattern of significance of impacts from that presented in the ES. A summary of the viewpoint assessment review and the ES assessments reveal the following:- • All viewpoints within 13km of the nearest turbine [with the exception of viewpoint 6 -Brechfa] will be subject to significant adverse visual impacts. It is recommended that comments made in relation to scheme design, particularly in terms of turbine heights should be fully considered in the context of the pattern of significant visual impacts. It is considered that a reduction in turbine height, particularly of the westernmost turbines would provide mitigation for these significant adverse visual impacts. Visual Impacts on settlements during operations This detail has not been included in this Consultation Report for brevity but all comments have been reviewed and any amendments incorporated in the revised ES Para 15.170 The Habitat Management Plan would not be expected to provide additional mitigation to visual impacts. General Comment on Additional Mitigation The opportunities for further visual mitigation through toning the turbine tower bases is not stated as having been addressed as part of designed in mitigation. It is considered that, for this site, in which the turbines are based in forested areas, and with some close to mid range views including the base of the tower against a backdrop of forestry, this approach may provide effective visual mitigation. It is recommended that this opportunity be explored. Micrositing An amendment has been made to the revised Para 15.173 chapter in the light of this request. The micrositing scope of 50m may result in adjustment of turbine locations to higher elevations. It is considered that this would lead to an increase in the magnitude of change of landscape and visual effects and would lead to an increase in the significance of impacts. It is recommended that these effects be fully considered in micrositing. It may be considered appropriate to impose a constraint on micrositing, which would restrict adjustment to a location of higher elevation than that used for the ES assessments. Cumulative Landscape and Visual Impact Assessment The cumulative landscape and visual impact [CLVIA] assessment undertaken in the ES addresses the effects in cumulation with existing, consented and pre application wind farm schemes, as agreed through the consultation process. The methodology adopted is in line with best practice and the assessment is clearly set out. Brechfa Forest West Wind Farm Consultation Report 92

Appendix 15.8 General Comments Further to comments made in relation to Table 15.2 under commentary on overall methodology above, the following is noted: - In all residential viewpoint assessments in which a ‘medium’ magnitude of change has been identified, experienced by a residential receptor [high sensitivity], the impact has been assessed as of ‘moderate’ significance. Table 15.2 would provide a significance of ‘Moderate or major’ in this situation. It is considered that the assessments do not transparently demonstrate the nature of significance, and provide an overall picture of a lower significance than would be suggested by Table 5.12. It is considered that for the purpose of the decision maker it should be noted that all impacts of ‘Moderate’ significance recorded in the residential viewpoint have been derived from a ‘Moderate or major’ assessment. Further to the above, it is considered that the significance assessments would be more usefully identified with the interim category of ‘major/moderate’ to clarify the level of significance to the decision maker as within the transition between moderate and major. Likewise, Table 5.12 would identify a significance of ‘minor or moderate’ for a ‘low’ magnitude of change, experienced by a residential receptor [high sensitivity]. The ES presents assessments of ‘minor’ significance for all viewpoints of this nature. As above, it is recommended that these viewpoint assessments would be more usefully identified with the interim category of ‘minor/moderate’ Notwithstanding the points above, which relate to an issue of calibration, the ES generally provides a thorough assessment of residential visual amenity; CCC have undertaken site visits to corroborate the observations and assessments and are broadly in agreement with the magnitude of change assessments. Chapter 16: Noise A meeting specifically on noise issues was held between CCC and RWE NRL and their specialist consultants. A full response has been provided to all points raised in a separate letter. Detail of the CCC comments and the response provided by RWE NRL has not been included in this Consultation Report for brevity but all comments have been reviewed fully and responded to. The letter sent from RWE NRL to CCC has been attached at Appendix F. Chapter 17- Shadow flicker Comments on shadow flicker have been reviewed but, as they generally support the approach taken in the chapter and the conclusions, few actions were necessary CHAPTER 18: SUMMARY This has been reviewed in the light of comments Para 18.8 (Bullet 6) made by CCC Significant adverse residual impacts will occur in relation to 18 viewpoint locations rather than 10 which is referred to in the ES. Moreover these locations are within 13km of the site, not 10km. Brechfa Forest West Wind Farm Consultation Report 93

2.7.9 BFW/IPC/S42/030

Llanegwad Community Council provided a letter of objection which stated that the community councillors unanimously voted against the proposed wind farm and listed seven observations as follows: 1. Brechfa is an area of outstanding beauty which attracts tourists to this area for its peace and tranquillity. 2. Local residents feel too much will be lost if the wind turbines were to dominate the skyline. 3. As one travels down the hill into Brechfa village, there lies before you panoramic views of hills, fields and forest with the village nestling between. 4. The proposed wind farm would totally spoil the natural and unique view of the area. 5. We want to preserve this lovely piece of Wales for our children and their children to enjoy. 6. Apart from our feelings, the proposed wind turbines would destroy the tourist area and vital income for the people of Brechfa. 9. The effects on communities of the erection of new electricity lines from wind farms to electricity grids is a concern.

RWE NRL response No action - This objection has been noted.

2.7.10 BFW/IPC/S42/033

Llanllawddog Community Council (LCC) completed a feedback form in response to the consultation. It highlighted that members of the LCC, as well as the clerk, had visited the Brechfa Forest West Wind Farm exhibitions at various locations. The LCC considered that the three main priorities for the proposal were: 1. minimising visual impact 2. recreation or public access impacts 3. transportation and access

A number of observations and comments were included by the LCC within its feedback form. These comments are set out below: – Could consideration be given to the feasibility of constructing a wood burning plant to use up forest waste and assist in creating jobs – Queried statement in the ES regarding barn owls- members reported that barn owls have been heard calling on the periphery of the forest – Members expressed concerns about the effect of visual effects on house prices – Concerns are raised about the deteriorating condition of the unclassified roads leading from the A485. With the increased volume of heavy traffic in the area due to the wind farm, the roads will deteriorate further unless they are regularly maintained. Could RWE/ FCW contribute towards ensuring that the minor roads remain in an appropriate condition for use by the increased traffic. – Concerns about increased traffic could be substantially reduced if the primary access to the development could be shared with the existing wind farm at Alltwalis Brechfa Forest West Wind Farm Consultation Report 94

– The community of Llanllawddog has no recreational facilities and assistance from the community benefits package when in place would have a positive effect on the area – The LCC expressed disquiet that properties in the locality and elsewhere may reduce in value as a result of wind farm developments and should be appropriately compensated as a result. Whilst there is no statutory provision for compensation, could community benefit funds be used for this purpose? Further approaches by the LCC will be made to both the Home Secretary and the Welsh Assembly Government.

RWE NRL response Regarding roads, the unclassified roads surrounding the site are not proposed to be used for construction traffic. However, should any damage be done by construction traffic associated with the Brechfa Forest West Wind Farm, provision of funding to make this good would be covered by agreements under the Highways Act.

RWE NRL have investigated in some detail the possibility of utilising the existing access for the Alltwalis Wind Farm. Unfortunately it has not been possible to reach a commercial agreement with the landowner. In order to mitigate the issues raised by a range of groups and individuals who have responded to the consultation, screening is proposed to mitigate landscape and ecological impacts associated with the new access track.

Part 1 of the Land Compensation Act 1973 provides a right to certain owners to claim compensation where their property is depreciated in value by the use of public works. Compensation payable therefore would be in respect of the subsequent use of the wind farm, not the construction process.

A person may claim compensation for the depreciation in the value of an interest in land due to physical factors caused by the use of public works. The physical factors include noise, vibration, smell, fumes, smoke, artificial lighting and the discharge onto the land of any solid or liquid substance. The proximity of the works or visual impacts on views are not claimable. The valuation exercise is therefore effectively the difference in the ‘switched on’ and the ‘switched off’ value.

Community benefits will be covered separately to the planning process. The method of administration and allocation of funds will be determined locally, in consultation with the community.

2.7.11 BFW/IPC/S42/034

The response from Dyfed-Powys Police Authority (DPPA) states that the main focus of concern relates to the net effect on traffic management and the associated policing of abnormal loads. The Police Authority draw particular attention to cumulative impacts across the Dyfed-Powys Police Authority area. Brechfa Forest West Wind Farm Consultation Report 95

The Police Authority request that RWE NRL produce the following: 1. Detailed traffic management plans supplied in advance of trial runs for length and width 2. The plans must include details of the specific measures required to move the loads safely, such as any temporary traffic orders required (e.g. road closures), as the police will not be relying on their emergency powers 3. The plans must be agreed in advance by all relevant authorities 4. The police resources required to complete this safely will be determined by the Dyfed- Powys Police Force 5. RWE NRL will be required to pay for all police involvement in the planning and implementation of the trial run 6. No abnormal loads are permitted within the Dyfed-Powys Police Force area during the hours of darkness 7. All carriers should have the ability to have their loads followed with a capability to fix any breakdowns and get going within an hour

Two other areas that are highlighted are the potential for an increase in crime levels in the area and the risk of disorder and disquiet amongst residents. The Authority requests that RWE NRL give consideration to mitigating any future crime and disorder issues during the construction period and for a period negotiated after commissioning by providing funding.

RWE NRL response Whilst the concerns of the Police Authority are acknowledged, it is not appropriate nor purposeful to produce a TMP until all construction details are known. National Policy Statement EN-3, paragraph 2.7.82 states that ‘Once consent for a scheme has been granted, applicants should liaise with the relevant local highway authority (or other coordinating body) regarding the start of construction and the broad timing of deliveries. It may be necessary for an applicant to agree a planning obligation to secure appropriate measures.’ RWE NRL consider this to be an appropriate approach with respect to this proposal and have included a requirement to produce a TMP within the draft DCO.

The considerations of the police will be a high priority when drawing up the TMP and they will be consulted throughout the process. It is acknowledged that RWE NRL will be required to pay for police involvement in transportation issues.

RWE NRL does not consider it appropriate that it should provide funding to Dyfed-Powys Police Authority for potential increased crime levels and risks of disorder because this request has not been substantiated.

2.7.12 BFW/IPC/S42/035

A response was received from the Welsh Assembly Government’s Roads and Projects Division, responding in its capacity as Highway Authority for the Welsh trunk road network. This explains that the Division’s main interest relates to the delivery of the turbine structures and the resulting impact upon the trunk road element of the route, i.e. M4 – A48 – A40. Brechfa Forest West Wind Farm Consultation Report 96

The response states that the Roads and Projects Division would be prepared to give favourable consideration to a formal submission for the proposal, provided that the following points are addressed: – A Construction Impact Assessment Plan should be produced including details and proposed schedules for deliveries – A Traffic Management Plan should be produced showing proposals for transporting Abnormal Indivisible Loads (AILs). This should include proposed timescales and delivery schedules as well as numbers, dimensions, weights, axle distributions etc. – Scale drawings of all affected junctions should be produced along with swept path analysis of the vehicles. Detailed drawings will be required to show any improvement works. – The developer should identify all street furniture that may be affected by AILs and provide details of relocation or modification – The developer should provide an assessment of the impact of AILs on all structures along the trunk road network – The developer should identify requirements for and be liable for the provision of holding areas/ passing places to facilitate the movement of the AILs – Land ownership boundaries must be provided on drawings showing proposed modifications requiring land take – The above criteria shall be agreed in writing with the Welsh Government as highway authority prior to commencement of the required works – The improvement works shall be substantially complete to the satisfaction of the Welsh Government prior to the commencement of AIL deliveries – The developer would be liable for the cost of making good any incidental damage to the trunk road network – Prior to the movement of AILs, the developer should give consideration to undertaking condition surveys of existing third party buildings/ structures so that the effect of vibrations – The developer will be required to comply with the requirements of the Traffic Management Act and liaise with the Highways Agency, the Welsh Government and its Trunk Road Agents and police – The AIL deliveries will need to comply with the Welsh Government’s Trunk Road embargo programme – The developer will be required to submit a completed ‘road space booking’ form for each AIL delivery – The developer will be liable for the cost of any Traffic Road Orders – The developer should liaise with all appropriate statutory undertakers whose apparatus may be affected – The developer would be responsible for liaison with all appropriate stakeholders affected – The developer should undertake full scale dummy runs prior to commencement – The developer would be liable for the cost and provision of appropriate publicity arrangements prior to commencement of the delivery programme. Brechfa Forest West Wind Farm Consultation Report 97

RWE NRL response Whilst the concerns of the Roads and Projects Division are acknowledged, it is not appropriate to produce a TMP until all construction details are known. National Policy Statement EN-3, paragraph 2.7.82 states that ‘Once consent for a scheme has been granted, applicants should liaise with the relevant local highway authority (or other coordinating body) regarding the start of construction and the broad timing of deliveries. It may be necessary for an applicant to agree a planning obligation to secure appropriate measures.’ RWE NRL consider this to be an appropriate approach and have included a requirement to produce a TMP within the draft DCO (Requirement 6), which incorporates the relevant sections from the Roads and Projects Division’s response.

A number of the requirements that are set out in the response from the Division are not relevant as the swept path analysis work and subsequent dry run undertaken by RWE NRL has shown that no works will be required on the Trunk Road network to facilitate deliveries of AILs. This work is presented within chapter 9 of the revised Environmental Statement.

It is acknowledged that RWE NRL would be responsible for covering costs associated with transportation along the trunk road network.

2.7.13 BFW/IPC/S42/036

Forestry Commission Wales’ (FCW) Grants and Regulations team responded in their capacity as a prescribed body. Their response sets out the role of Forestry Commission Wales and its Commissioners and provides an overview of the Welsh Government’s ‘Woodlands for Wales’ strategy (July 2009). The response also includes FCW’s policy position paper on development affecting woodlands (July 2010).

It is requested by the FCW’s Grants and Regulations team that the final ES is amended to include statements setting out that compensatory planting will be provided for ‘temporary woodland removal’ and suggests locations for these statements. The response from the Grants and Regulations team explains that these areas of new planting do not need to be located within the immediate geography of the project but must be located within Wales.

RWE NRL response The Welsh Assembly Governments’ “Woodlands for Wales” strategy (July 2009) sets out a number of outcomes sought from existing and new woodlands in Wales. This includes the following statement- ‘There is a strong presumption against the permanent removal of woodland…’. Whilst the removal of woodland for wind farm infrastructure (turbines, crane hard standings and substation) is for the life of the wind farm only, it has been decided that to mitigate these effects for the 25 year operational period, RWE NRL will work with FCW’s Wind Energy Programme team to locate and plant equivalent areas of woodland. The objective is to ensure no net loss of trees associated with the wind farm as set out in the Forestry Commission policy on development affecting woodlands. The new planting may take place away from site but will be within Wales and will be mixed woodland. Brechfa Forest West Wind Farm Consultation Report 98

meetings

2.8 Meetings

A number of meetings have taken place during and post-consultation. These are listed in the following table:

Date Topics covered Attendees 30th March 2011 General discussion about topics of RWE NRL, CCW, FCW concern- HMP, public access, grid connection. No commitments made (as prior to end of consultation) 20th May 2011 Noise RWE NRL, Hoare Lea Acoustics, CCC, Parsons Brinckerhoff 15th June 2011 Development Consent Order RWE NRL, CCC 13th July 2011 Overview of issues raised in S42 RWE NRL, CCC, CCW, EAW, FCW responses 28th July 2011 Public Access Management Plan RWE NRL, CCC, CCW, FCW 28th July 2011 Habitat Management Plan RWE NRL, Land Use Consultants, CCC, CCW, EAW, FCW

Meeting minutes for each of these meetings are attached at Appendix G. Brechfa Forest West Wind Farm Consultation Report 99

section 44

2.9 Section 44

A response was received from Forestry Commission Wales (FCW) in their capacity as agent for the landowner (the Welsh Ministers) (BFW/IPC/ S42/013). This response confirms that RWE NRL have met the obligations set out in the Option Agreement between the company and the Welsh Ministers. Notwithstanding the legal necessities, FCW emphasises its support for the application for development consent to construct and operate a wind farm at Brechfa Forest West. Additionally, seven responses were received from residents consulted under section 44 (4) of the Act. These are summarised below.

Section 44 summary comments table

Letter Reference Summary of Letter Commentary Number BFW/IPC/S47/007 Do not object to the Cumulative landscape impacts are assessed in the ES. scheme per se but specific elements. Cumulative Tall turbines are required at Brechfa Forest West due to the need to elevate the blades above the forest canopy to avoid major turbulence impacts. visual impact resulting Further explanatory information about this is included in the revised ES. in a change of landscape character. Believes height There is no justification for the inclusion of an arbitrary buffer of 1mile between the development and “homes”. The Brechfa Forest West Wind Farm of turbine should match consultation included a draft Environmental Statement (ES) that fully examined the potential effects arising from the proposed development and Alltwalis wind farm. whether these effects are acceptable. The suggested buffer is arbitrary in so much as it does not take in to consideration potential effects arising Concerns over noise. from the wind farm. Suggests a distance from homes of 1 mile. Concern The consultation response does not explain or identify the evidence base that underpins this requested restriction to clearly demonstrate that large that the ES has not scale wind farms have an unacceptable impact upon residential amenity within a distance of 1 mile of residential properties. When taken at face taken into account noise value, this proposition seems unjustifiable on the basis that there are many operational wind farms in Wales and the UK that have turbines within this complaints from Alltwalis separation distance that have not given rise to any complaints or indeed may not be visible from properties within that buffer. Wind Farm. Concern over the weather conditions The request further fails to accord with TAN8, Annex D, paragraph 3.4 which sets out the methodology for Local Planning Authorities to refine when background noise their Strategic Search Areas (SSAs). In assessing the capacity of refined areas, para 3.4 states that a buffer of 500m radius should be drawn as it is was measured. Objection considered a typical separation distance between a wind turbine and a residential property to avoid unacceptable noise impacts. Furthermore, para. to the height of the 3.4 states that a 500m buffer should not be applied rigidly as it can lead to conservative results and flexibility is advised. turbines and proximity to homes. Objection to Noise complaints relating to Alltwalis Wind Farm are not something that RWE NRL can comment on as the full information is not available to the Company. turbines 17,18,19,23 and 24, especially 17 and 23. Weather conditions during background noise monitoring are described in the ES and the length of the monitoring period was extended at a number of properties to reflect the poor weather conditions.

No clear justification is provided for the objection to the specific named turbines. Brechfa Forest West Wind Farm Consultation Report 100

BFW/IPC/S47/014 A comments form was A bespoke response answering this query was provided within the acknowledgment letter from RWE NRL. received from this respondent. The form included a specific query regarding archaeology. BFW/IPC/S47/080 A short letter received RWE NRL will engage with the property owner about the provision of tree screening as a potential form of mitigation. from one of the nearest RWE NRL can confirm that the draft ES did identify the water supply for the property in question. The survey concluded that there would be no properties to the proposed impacts on this water supply as a result of the proposal. wind farm. It states concerns about visual and audio intrusion and requests a tree screen as mitigation. It states that the private water supply survey has not identified the properties’ water supply. BFW/IPC/S47/091 A comments form Three main points are raised in this response: was received from this 1. No clear justification is provided by the respondent for the objection to the specific named turbines- the noise assessment conducted (and respondent. The form supplemented following consultation) concludes that there should be no significant adverse noise effects, associated with the Brechfa Forest stated that Turbines 17, West Wind Farm, on this property. 18 and 23 should be 2. Noise- the property in question has been the particular focus of work undertaken by RWE NRL’s specialist noise consultants. As the Alltwalis removed. It highlighted Wind Farm is operated by another company, RWE NRL have no control over the noise emitted from this wind farm. However, efforts have been that the property is made to ensure that the Brechfa Forest West Wind Farm does not have a significant adverse impact on residences in general, and this property suffering from the noise in particular. from Alltwalis Wind Farm. 3. Access track- RWE NRL have investigated in some detail the possibility of utilising the existing access for the Alltwalis Wind Farm. Unfortunately Regarding visual effects, it has not been possible to reach a commercial agreement with the landowner. In order to mitigate the issues raised by this resident, screening is the respondent states that proposed to mitigate landscape and ecological impacts associated with the new access track. the turbines 17, 18 and 23 are too close and would mean the continuation of turbines around the property. It states that the access track as proposed would be a blight on the property. It states that the noise problems from Alltwalis Wind Farm must be rectified before any further applications are submitted. Brechfa Forest West Wind Farm Consultation Report 101

BFW/IPC/S47/092 This respondent included Three main points are raised in this response: a comments form and 1. No clear justification is provided for the objection to the specific named turbines- the noise assessment conducted (and supplemented following supporting information. It consultation) by RWE NRL’s specialist noise consultants concludes that there should be no significant adverse noise effects associated with the is stated that the property Brechfa Forest West Wind Farm, including at the respondents property. has a private water supply 2. Noise- the property in question has been the particular focus of work undertaken by RWE NRL’s specialist noise consultants. As the Alltwalis Wind and queries work done Farm is operated by another company, RWE NRL have no control over the noise emitted from the wind farm. However, efforts have been made by RWE NRL to date. It is to ensure that the Brechfa Forest West Wind Farm does not have a significant adverse impact on residences in general, and this property in stated that turbines 17, particular. 18 & 23 are too close 3. Access track- RWE NRL have investigated in some detail the possibility of utilising the existing access for the Alltwalis Wind Farm. Unfortunately it and should be removed. has not been possible to reach a commercial agreement with the landowner. In order to mitigate the issues raised by this resident, screening is The respondent also proposed to mitigate landscape and ecological impacts associated with the new access track. states that the proposed 4. Private Water Supply- RWE NRL has committed to undertaking a full survey of private water supplies prior to construction commencing. In the access track would be a case of private water supplies that could be affected, the residents will be contacted to explain the potential issues. Actions to be implemented blight on the property. in the event that the water supply was affected would be discussed with the residents prior to implementation. Queries are raised in the accompanying letter regarding apparent work that has been taking place on the proposed access track. It is highlighted that noise problems from Alltwalis Wind Farm are ongoing and that problems need to be rectified prior to any further applications. Further supporting information is provided on this issue. The respondent states that they would require a legal binding contract to protect their house from further noise problems and devaluation of property. Brechfa Forest West Wind Farm Consultation Report 102

BFW/IPC/S47/094 A comments form was Regarding private water supplies, it is highlighted in the ES that there is the potential for the spring used for livestock watering to be affected by received from this the construction of the access track to Turbine 17. An in depth study of the spring will be undertaken by RWE NRL before any construction starts to respondent. It highlights assess more precisely the risk to the spring discharge, and the measures that may need to be taken to minimise the risk. Any necessary measures will that the property is be discussed with the residents before any construction work is undertaken. Actions will be set out by RWE NRL, to be implemented in the event that dependent upon spring the supply is affected. water. It is also stated that the property has 10 turbines within 800 metres of the house and that they can be seen all the time. It states that the turbine layout is ‘too near and too noisy’. BFW/IPC/S47/100 A comments form was In response to the information provided about the farm water supply, RWE NRL’s specialist consultants have been in contact with the owners of this received from these farm. In order to minimise the risk of impacts on their water supply, the alignment of the access track has been changed to move it further away from respondents. It highlights the water source. Should any additional measures be required to protect the farm’s water supply these will be discussed with the resident. that the proposed access track is very close to the farm water supply. It is stated that the minimum distance to homes is currently insufficient and that more attention should be paid to contours rather than building on ridge lines. These respondents highlight the existing noise from the Alltwalis Wind Farm as something that should be considered further. It states that consultation on Brechfa Forest West Wind Farm has been an improvement on previous consultation and they ‘hope that RWE will listen’. Brechfa Forest West Wind Farm Consultation Report 103

3. section 47

Section 47 Duty to consult local community

(1) the applicant must prepare a statement setting out how the applicant proposes to consult, about the proposed application, people living in the vicinity of the land.

(2) before preparing the statement, the applicant must consult each local authority that is within section 43(1) about what is to be in the statement.

(3) the deadline for the receipt by the applicant of a local authority’s response to consultation under subsection (2) is the end of the period of 28 days that begins with the day after the day on which the local authority receives the consultation documents.

(4) in subsection (3) ‘the consultation documents’ means the documents supplied to the local authority by the applicant for the purpose of consulting the local authority under subsection (2).

(5) in preparing the statement, the applicant must have regard to any response to consultation under subsection (2) that is received by the applicant before the deadline imposed by subsection (3).

(6) once the applicant has prepared the statement, the applicant must publish it –

(a)in a newspaper circulating in the vicinity of the land, and

(b) in such other manner as may be prescribed.

(7) the applicant must carry out consultation in accordance with the proposals set out in the statement. Brechfa Forest West Wind Farm Consultation Report 104

statement of community consultation

3.1 Statement of Community Consultation

3.1.1 The Statement of Community Consultation (SOCC) explains how the local community will be consulted and is made public prior to consultation commencing.

3.1.2 The objectives of the consultation for the Brechfa Forest West Wind Farm were:

– To inform local people about the proposals in a clear and concise way; – To provide access to information to all people in the community; – To provide an opportunity for local people to put forward their ideas and have a role in developing proposals; – To provide an opportunity for local people to meet face-to-face with RWE NRL staff who were involved in the development; – To create a process through which local people can comment on the formal proposals; – To respond to local people.

3.1.3 Research was undertaken by RWE NRL to establish what methods / materials other bodies (such as the County Council) used when they needed to consult in the area.

3.1.4 It was considered that a range of consultation techniques should be used to engage with, inform and consult with people. These techniques included:

– Newsletters; – Exhibitions; – Media engagement; – Points of contact- postal address, phone number and email address; – Provision of information at a range of local locations; – Freely available non-technical summary information; – Full sets of preliminary environmental information available on request (payment required); – one to one meetings; – Website

3.1.5 The formal consultation materials included ‘Preliminary Environmental Information’ (comprising a draft Environmental Statement) and the Non- technical summary of the draft ES. Brechfa Forest West Wind Farm Consultation Report 105

3.1.6 A range of bespoke communication materials were produced to support the consultation process, these included:

– Publication of the Section 48 notice on five separate occasions, across three different publications; – Information sheets (available at the public exhibitions and on request); – Newsletters; – Posters; – Non technical summary of the draft ES; – A0 maps of the proposal (at 1:7,000 and 1:50,000 scales); – Exhibition display panels; – Photomontages; – Feedback forms.

3.1.7 These communication materials and their use, are described in more detail in paragraphs 3.3 to 3.10.

3.1.8 The consultation materials and a draft Planning Statement, the section 48 notice and feedback forms were also made available on the Brechfa Forest West Wind Farm page on the RWE NRL website. This enabled people to review the draft ES and complete a feedback form to be sent back electronically to the dedicated Brechfa Forest email address.

3.2 The Local Authority’s Comments

3.2.1 The draft SOCC was sent to Carmarthenshire County Council (CCC) for their comments under section 47(2) on 8th January 2010.

3.2.2 The CCC took a report to their Planning Committee on the draft SOCC and responded on 4th February 2010 with the following recommendations:

1. The SOCC should provide a succinct summary of the IPCs role as examining authority, and draw attention to the status of the National Policy Statements (NPSs). The distinction should also be drawn between sub 50MW projects, notably Brechfa Forest East Wind Farm. 2. The SOCC should provide sufficient detail of the project, referring to both positive and negative aspects of the scheme so as to encourage participation in the process. 3. The developer should carefully consider the timing of its 42 day formal consultation period. If it coincides or overlaps with popular holiday periods, people may not have sufficient time to assess and comment on the technical information supporting the application. Brechfa Forest West Wind Farm Consultation Report 106

4. RWE NRL should not restrict their ‘face to face’ contact with local people to public exhibitions and community liaison group meetings as some people may have difficulty attending. Furthermore individuals may have specific questions that would demand a longer period of engagement. Representatives from RWE NRL should make themselves available for more informal meetings with individuals. This commitment should be reflected in the OS CC. 5. Hard to reach groups such as the elderly and disabled may request face to face meetings. RWE NRL are advised to make themselves available for this form of public engagement. 6. your attention is drawn to the Council’s community newspaper which has extensive coverage of the area and could be used as a means of communicating with the local residents 7. The period of consultation be extended from 42 days to 56 days 8. The 5km buffer be extended where a community can be identified as having direct views of the development or along key transport routes

3.2.3 Recommendations 1, 2, 4, 5 and 7 were incorporated by RWE NRL into the final OS CC. The request in recommendation 3 to consider the timing of the formal consultation was taken into account. Recommendation 6 was noted but it was felt that a bespoke newsletter about the wind farm proposal and consultation process, would be just as effective. . RWE NRL responded to Carmarthenshire County Council on recommendation 8 on 16th November 2010 as follows:

“The 5km buffer covers settlements along the A485 north of Carmarthen which will be the route used by construction traffic. It is not clear how ‘direct views of the development’ should be defined, nor ‘community’. As the Zone of Theoretical Visualisation plans are only indicative at the current time, and do not take into account any screening effects, it is considered that they are a blunt tool for determining whether communities have direct views. It would be confusing and potentially divisive to take a selective approach to choosing communities that should be included. A 5km buffer is a clear method of selecting communities for newsletter distribution.

People living beyond the 5km buffer area are welcome to participate in the consultation process and all responses received during the consultation period will be formally recorded, reviewed and responded to, regardless of the location of the sender.”

3.2.4 The SOCC for the Brechfa Forest West Wind Farm was printed in the Carmarthen Journal on November 24th, 2010 under Section 47(6)(a). The Carmarthen Journal is a weekly paper and has a circulation of 50,108.

3.2.5 The SOCC is attached at Appendix H. Brechfa Forest West Wind Farm Consultation Report 107

community liason group

3.3 Community Liaison Group

3.3.1 RWE NRL won the rights to develop a wind farm in the Brechfa Forest following a tender process managed by Forestry Commission Wales (FCW). RWE NRL made the commitment to hold Community Liaison Group (CLG) meetings for the Brechfa Forest East and West wind farm proposals as part of the original bid.

3.3.2 The community liaison group was set up, at the request of RWE NRL, to facilitate useful two-way dialogue between the Company’s development staff and representatives of local community or interest groups, specifically in relation to the proposals for a wind farm within the Brechfa Forest. The CLG is not a forum in which to garner support nor is it a platform for opposition to the wind farm. The CLG seeks to ensure that information is disseminated into the community by its members and to feedback any issues that they wish to be discussed or considered by RWE NRL.

3.3.3 The first meeting was held st1 October 2009 and the meetings have been held in various venues around the site. The first meeting introduced the developer (RWE NRL) and the ‘general‘ wind farm proposal (including both Brechfa Forest West and Brechfa Forest East Wind Farms) to the community as well as incorporating a presentation from the FCW. Subsequent meetings in January 2010 and July 2010 have covered Environmental Impact Assessment; Communications and Engagement; Public Access; and the IPC process.

3.3.4 The CLG has provided a useful conduit for explaining the IPC process and role of the IPC to the community. Within the context of a meeting of a smaller group, more detail can be provided and queries can be raised more easily than via mass communication.

3.3.5 Members of the CLG were also invited to attend an IPC outreach event which was held on 24th November 2010 in Brechfa Village Hall.

3.3.6 Additionally, members of the CLG were invited to preview the consultation exhibition on 17th February to raise their awareness of the consultation process and format. CLG members were asked to encourage the groups that they represented to engage in the consultation process.

3.3.7 An additional CLG meeting was held towards the end of the consultation process, on 30th March, to update people about the exhibitions to date and issues that had been raised and to encourage people to continue to ask the groups that they represented to engage in the consultation process. Brechfa Forest West Wind Farm Consultation Report 108

visits to local residents

3.4 Visits to Local Residents

3.4.1 As set out in the SOCC, RWE NRL staff were available for face-to-face meetings with local residents during the consultation process. In the event, only one such meeting was requested during the consultation process. The table below sets out all of the face-to-face meetings that RWE NRL have had with local residents at their homes during the development of the wind farm, from 2009 to date.

Date Local resident Issues/ concerns 4th June 2009 Ms Atkinson, Ms Davey, Ms Proximity to homes, interruption of tranquillity, noise issues, McFednes disruption caused by construction, more details about turbine locations, some questions about wind farm myths. 12th April 2010 Mr & Mrs Harris Noise (Alltwalis issues) visibility of turbines from farmland (upper fields) Concern about T17, 18, 19 and 23 in particular. 13th May 2010 Mr & Mrs Hellier, Noise, visual impact, ecology and access

2nd August 2010 Mr & Mrs Morgan; Mr & Mrs Neil Concerns about noise, particularly in the light of issues at Alltwalis. Seeking reassurance that noise will NOT be an issue and if it were to be an issue, that it would be dealt with appropriately. Emphasised the need for consultation to be in ‘plain English’ 1 April 2011 Mr & Mrs Harris, Rhodri Glyn Concerns about noise, access track visibility and impact Thomas AM Brechfa Forest West Wind Farm Consultation Report 109

newsletters

3.5 Newsletters

3.5.1 Three sets of newsletters have been produced by RWE NRL and circulated locally.

3.5.2 Newsletter 1- introducing the site (at the time this included both Brechfa Forest West and Brechfa Forest East proposals). The newsletter was sent out at an early stage of development, in March 2009 to 3620 addresses, within a 5km buffer of the Brechfa Forest boundary (excluding small, outlying areas of forestry). The distribution area for this initial newsletter was based on 2008 postcode data..

3.5.3 Newsletter 2- setting out progress on both the Brechfa Forest West and Brechfa Forest East proposals, was sent out in March 2010 to 3620 residential addresses and an additional 128 commercial addresses, within the same 5km buffer.

3.5.4 Newsletter 3- making people aware of the formal consultation process, where they could view the draft ES and exhibition details, was sent out in February 2011 to 3922 residential addresses and 115 business addresses, within the 5km forest buffer, based on 2010 postcode data.

3.5.5 Copies of each newsletter are attached at Appendices I to K. Brechfa Forest West Wind Farm Consultation Report 110

presentations

3.6 Presentations

3.6.1 During the development of the proposal (since 2009), presentations were requested by various groups and bodies. Presentations introducing the Brechfa Forest West Wind Farm proposal were organised for Capel Dewi Coffee morning in February 2010 and Community Council in June 2010 Brechfa Forest West Wind Farm Consultation Report 111

telephone calls

3.7 Telephone calls

3.7.1 Phone calls from six individuals were received by RWE NRL during the formal consultation period. The callers’ contact information and the content of the calls were logged by the recipient, and the callers were informed that their comments needed to be received in writing by RWE NRL (unless there were extenuating circumstances) before 6th April 2011 to be treated as a relevant response. Brechfa Forest West Wind Farm Consultation Report 112

public exhibitions

3.8 Public Exhibitions

3.8.1 Prior to formal consultation, an earlier round of public exhibitions were held in Llansawel Village Hall, Brechfa Church Hall and Cae’r Felin Primary School, Pencader in March 2010. These exhibitions related both to Brechfa Forest West and Brechfa Forest East Wind Farms and were intended to update members of the local community on the development of the project. This March 2010 round of public exhibitions were attended by approximately 280 people over the course of the three days.

3.8.2 A further round of public exhibitions were held during the formal consultation period. The main purpose of these exhibitions was to enable local people to view the Preliminary Environmental Information, make comments and ask questions of the RWE NRL project team. The draft Environmental Statement was made available in paper format and electronically on laptops.

3.8.3 Information was also provided around the venue on exhibition boards and included detail about Welsh planning policy on renewable energy, the IPC process, community benefit, and large scale maps showing the location and layout of the wind farm in the context of the surrounding communities.

3.8.4 A0 sized maps were provided to show the proposed layout of the wind farm at 1:7,000 scale and the location of the wind farm in the context of the communities surrounding the site at 1:50,000 scale. Maps were also made available showing the Zones of Theoretical Visual Influence which depict whether different localities will be able to see wind turbine tips or towers factoring in topographical relief. Photomontages, produced from 31 different viewpoints to provide an impression of what the Brechfa Forest West Wind Farm could look like from various locations, were also made available for viewing by the public at the exhibitions.

3.8.5 RWE NRL also provided a number of information sheets that gave information on various topics in both English and Welsh, including:

– Wind power – Climate change – Technical Advice Note 8 (2005) (“TAN8”) – Forestry Commission Wales – How impacts will be managed at Brechfa Forest West – The Planning process and the Infrastructure Planning Commission – Community Benefits – The developer- RWE Npower Renewables Ltd – Project details for Brechfa Forest West Brechfa Forest West Wind Farm Consultation Report 113

– How a new wind farm could look – Brechfa Forest East Wind Farm – How to have your say – Brechfa Forest West Wind Farm- Questions and Answers

3.8.6 These information sheets were all made available for people to read and/or take away from the exhibitions. All exhibition boards were presented bilingually (in both English and Welsh), and Welsh speaking RWE project team staff were available at every exhibition to answer any questions presented in Welsh. The draft Environmental Statement (ES) was presented in English, and the non technical summary was available in both English and Welsh. As the ES is a technical document written in English, there is a risk that translating it in to Welsh might result in different interpretations of the meaning – as such only the non-technical summary has been translated in to Welsh.

3.8.7 Consultation undertaken by RWE NRL in relation to this proposal has been consistent with the IPC’s Welsh Language scheme which adopts the principle, so far as it is both appropriate in the circumstances and reasonably practicable, that in the conduct of its public business in Wales, it will treat the English and Welsh languages on a basis of equality. The Brechfa Forest West Wind Farm proposal was prepared in accordance with the Welsh Language Act 1993 (“1993 Act”) and in accordance with guidelines issued by the Welsh Language Board under section 9 of the 1993 Act.

3.8.8 Copies of the panels presented at the public exhibitions are attached at Appendix L.

3.8.9 There was also the opportunity for members of the public to see how the proposed wind farm would look from their property or other specific locations using ‘wind farmer’ a software package that can be used to provide representative views from specific properties. This model is a ‘bare earth model’ that does not take into account the screening effects of any trees, houses, walls, hedgerows and other vegetation. This was demonstrated by a member of the RWE NRL project team who talked members of the public through what they could see and the limitations of the software. It was made clear to the members of the public during the demonstrations that the views presented were representative but not definitive noting these limitations. Brechfa Forest West Wind Farm Consultation Report 114

3.8.10 Details of the timing and venues for the public exhibitions were advertised in the third newsletter, on the Section 48 notice as published in the Carmarthen Journal, the Guardian, and the London Gazette, and by posters distributed locally. Letters were also sent to Welsh Assembly Members and Members of Parliament, Carmarthenshire Councillors, and Community Councils, informing them about the process and inviting them to attend a preview event (prior to the exhibition opening to the general public) on 17th February 2011.

3.8.11 In addition to the preview event, seven days of exhibitions were held across five different venues during the consultation period. These are as follows:

Date Location Times Attendees Friday 18 February Brechfa Village Hall 2pm-8pm 21 Saturday 26 February Community 10am-3pm 8 School Monday 28 February Llanllwni Church Community 2pm-8pm 12 Hall Tuesday 8 March The Old School Hall, 2pm-8pm 30 Alltwalis Thursday 10 March Llanpumsaint Memorial Hall 2pm-8pm 9 Saturday 19 March Llanllwni Church Community 12pm-5pm 14 Hall Saturday 26 March Brechfa Village Hall 12pm-5pm 20

3.8.12 The additional exhibition (highlighted in bold font in the table above) held at Alltwalis was added by RWE NRL in response to local demand.

3.8.13 In rural areas it is often difficult to find appropriate exhibition venues. Venues need to be available for a ‘one off’ booking, big enough to accommodate the display boards but also be accessible to members of the community and ideally easily reached by public transport. The venues were chosen by RWE NRL to be representative and accessible to the communities near to the proposed wind farm.

3.8.14 The timings, frequency and locations of the exhibitions were carefully chosen to ensure that members of the public were able to participate in the consultation process should they wish to. A spread of exhibitions across weekdays, weekday evenings and weekends were included. Brechfa Forest West Wind Farm Consultation Report 115

documents available for viewing

3.9 Documents available for viewing

3.9.1 The Preliminary Environmental Information was made available for viewing free of charge at a number of local venues during the formal consultation process. This was publicised both in the newsletter and in the Section 48 notice (detailed earlier). Details of venues are below:

– Carmarthen Planning Office – Carmarthen Library – Planning Office – Llandeilo Library – Brechfa Community Shop – Pencader Post Office & Albion Stores – Gwyddgrug Post Office – The Old School Community Centre, Llanybydder Brechfa Forest West Wind Farm Consultation Report 116

feedback forms

3.10 Feedback Forms

3.10.1 Feedback forms were prepared in English and Welsh and offered both at the public exhibitions and online on the RWE NRL project website to enable people to make their comments. Whilst some people preferred to write letters, others preferred the structured approach offered by the feedback forms. People were able to either complete the feedback form in situ at the exhibition or take it away to complete at their leisure.

3.10.2 A copy of the feedback form is attached at Appendix M.

3.10.3 All emails, letters and feedback forms received were given an individual reference number and acknowledged. Letters were reviewed and where queries were raised that could be easily responded to using publicly available information, bespoke responses were provided directly to the author. Correspondence was welcomed in English or Welsh, which in turn has allowed correspondents to receive a reply in the language of the original letter. Brechfa Forest West Wind Farm Consultation Report 117

summary of feedback

3.11 Summary of Feedback Received under Section 47

3.11.1 The following table provides an overview of the responses received, including the form of receipt:

Reference Number Date Name Type Language BFW/IPC/S47/001 11/02/2011 Cllr Linda Evans Email English

BFW/IPC/S47/002 13/02/2011 Dr Kelvin Broad Email English

BFW/IPC/S47/003 14/02/2011 Petra Wood Email English

BFW/IPC/S47/004 11/02/2011 Janet Dube Email English

BFW/IPC/S47/005 17/02/2011 Michael Norman Email English

BFW/IPC/S47/006 24/02/2011 P I Tofts Letter English

01/03/2011 P I Tofts Letter English BFW/IPC/S47/007 22/02/2011 Gus and Nell Hellier Email English

BFW/IPC/S47/008 18/02/2011 Steve & Andrea Bloom Email English

BFW/IPC/S47/009 28/02/2011 John Askew- GLASS Email English

BFW/IPC/S47/010 18/02/2011 Caroline Evans Comments form English

BFW/IPC/S47/011 18/02/2011 Emyr Griffiths Comments form English

04/04/2011 Emyr Griffiths Comments form English

BFW/IPC/S47/012 18/02/2011 P Winchester Comments form English

BFW/IPC/S47/013 18/02/2011 P T Dyer Comments form English

BFW/IPC/S47/014 18/02/2011 Belinda Thorogood Comments form English

BFW/IPC/S47/015 27/02/2011 Lynne Denman Comments form Welsh

BFW/IPC/S47/016 27/02/2011 Mr J M Rowsell Comments form English

BFW/IPC/S47/017 27/02/2011 Sara Rawlins Comments form English

BFW/IPC/S47/018 04/03/2011 Mr & Mrs J Clarke Comments form English

BFW/IPC/S47/019 04/03/2011 D Emery Comments form English Brechfa Forest West Wind Farm Consultation Report 118

BFW/IPC/S47/020 08/03/2011 Michael Wood Comments form English

BFW/IPC/S47/021 08/03/2011 Carole Smith Comments form English

BFW/IPC/S47/022 08/03/2011 M Evans Comments form English

BFW/IPC/S47/023 09/03/2011 David Foot Comments form English

BFW/IPC/S47/024 10/03/2011 Alltwalis Resident Comments form English

BFW/IPC/S47/025 17/03/2011 Dilwyn Green Letter English

BFW/IPC/S47/026 19/03/2011 Richard Beecher Comments form English

BFW/IPC/S47/027 23/03/2011 Mr J L Hubert Comments form English

BFW/IPC/S47/028 25/03/2011 CPRW Comments form English

BFW/IPC/S47/029 30/03/2011 CONFIDENTIAL

BFW/IPC/S47/030 30/03/2011 Elizabeth Olwen Davies Comments form English

BFW/IPC/S47/031 30/03/2011 D M Jones Comments form English

BFW/IPC/S47/032 30/03/2011 Trevor Marshall Comments form English

BFW/IPC/S47/033 28/03/2011 John R Davies Comments form English

BFW/IPC/S47/034 26/03/2011 H R Dare Comments form English

BFW/IPC/S47035 26/03/2011 ANONYMOUS Comments form English

BFW/IPC/S47/036 31/03/2011 Roy Davies Comments form English

BFW/IPC/S47/037 31/03/2011 E Davies Comments form Welsh

BFW/IPC/S47/038 31/03/2011 T D Green Comments form English

BFW/IPC/S47/039 30/03/2011 WITHDRAWN English

BFW/IPC/S47/040 01/04/2011 Mr J P Hewer Comments form English

BFW/IPC/S47/041 01/04/2011 Mrs L Hewer Comments form English

BFW/IPC/S47/041 01/04/2011 Miss Sarah Amanda Hewer Comments form English Brechfa Forest West Wind Farm Consultation Report 119

BFW/IPC/S47/042 01/04/2011 William Davies Comments form English

BFW/IPC/S47/043 01/04/2011 Mr Kenneth Davies Comments form English

BFW/IPC/S47/044 01/04/2011 Mr E J Davies Comments form English

BFW/IPC/S47/045 01/04/2011 M Davies Comments form and English letter

BFW/IPC/S47/046 04/04/2011 Norma Jones Comments form English

BFW/IPC/S47/047 04/04/2011 Robert F Jones Comments form English

BFW/IPC/S47/048 04/04/2011 Peter Tofts Comments form English

BFW/IPC/S47/049 04/04/2011 Anwen Evans Comments form Welsh

BFW/IPC/S47/050 04/04/2011 John Evans Comments form English

BFW/IPC/S47/051 04/04/2011 Verona Evans Comments form and English letter

BFW/IPC/S47/052 04/04/2011 Yvonne Griffiths Comments form English

BFW/IPC/S47/053 04/04/2011 E W Griffiths Comments form English

BFW/IPC/S47/054 04/04/2011 Stella Thomas Comments form English

BFW/IPC/S47/055 04/04/2011 Philip John Thomas Comments form English

BFW/IPC/S47/056 04/04/2011 Malcolm Evans Comments form English

BFW/IPC/S47/057 04/04/2011 Ann Evans Comments form English

BFW/IPC/S47/058 04/04/2011 Mark Evans Comments form English

BFW/IPC/S47/059 04/04/2011 Margaret Cule Comments form English

BFW/IPC/S47/060 04/04/2011 Mrs L …… Comments form English

BFW/IPC/S47/061 04/04/2011 Michael Richardson Letter English

BFW/IPC/S47/062 04/04/2011 Mrs Freda Vickers Comments form English

BFW/IPC/S47/063 04/04/2011 Rosemary Richardson Letter English

BFW/IPC/S47/064 04/04/2011 Anthony R Armstrong Comments form English Brechfa Forest West Wind Farm Consultation Report 120

BFW/IPC/S47/065 04/04/2011 Mrs J Armstrong Comments form English

BFW/IPC/S47/066 30/03/2011 Carolyn Smethurst Email English

BFW/IPC/S47/067 30/03/2011 John Hubert Email English

BFW/IPC/S47/068 03/04/2011 Grwp Blaengwen Email English

BFW/IPC/S47/069 03/04/2011 Steve & Andrea Bloom Comments form English

BFW/IPC/S47/070 03/04/2011 Howard Dare Email English

BFW/IPC/S47/071 03/04/2011 Cllr Linda Davies Evans Email English

BFW/IPC/S47/072 04/04/2011 Beverley Griffiths Comments form English

BFW/IPC/S47/073 04/04/2011 Diane George & Peter Phillips Comments form English

BFW/IPC/S47/074 04/04/2011 Julian Wormald Comments form English

BFW/IPC/S47/075 04/04/2011 Jennifer Harrison Comments form English

BFW/IPC/S47/076 05/04/2011 Jonathan Edwards MP Letter English

BFW/IPC/S47/077 05/04/2011 Carmarthenshire Riders Comments form and English email

BFW/IPC/S47/078 05/04/2011 Brechfa Forest Tourism Cluster Comments form and English Group email

BFW/IPC/S47/079 05/04/2011 Jillie Gardiner Comments form English

BFW/IPC/S47/080 05/04/2011 Ivan Langley Email English

BFW/IPC/S47/081 05/04/2011 Tim Martin Comments form English

BFW/IPC/S47/082 06/04/2011 Tim Lewis Comments form English

BFW/IPC/S47/083 06/04/2011 David Groom Comments form English

BFW/IPC/S47/084 06/04/2011 RSPB Email English

BFW/IPC/S47/085 06/04/2011 Brechfa Forest Energy Action Comments form and English Group email Brechfa Forest West Wind Farm Consultation Report 121

BFW/IPC/S47/086 06/04/2011 Llanfihangel Rhos-y-Corn/ Comments form and English Brechfa Community Association email

BFW/IPC/S47/087 04/04/2011 Rhodri Glyn Thomas AM Email English

06/04/2011 Rhodri Glyn Thomas AM Letter English

BFW/IPC/S47/088 05/04/2011 Paul Hobbs Comments form English

BFW/IPC/S47/089 05/04/2011 Elinor Hobbs Comments form English

BFW/IPC/S47/090 05/04/2011 John Beynon Comments form English

BFW/IPC/S47/091 05/04/2011 Mr J Harris Comments form English

BFW/IPC/S47/092 05/04/2011 Mrs C Harris Comments form and English letter

BFW/IPC/S47/093 05/04/2011 Yvonne Baxter Comments form English

BFW/IPC/S47/094 05/04/2011 D A George Comments form English

BFW/IPC/S47/095 05/04/2011 T Harries Comments form English

BFW/IPC/S47/096 05/04/2011 Helen Mitchell Comments form English

BFW/IPC/S47/097 05/04/2011 Lisette Chesshire Comments form English

BFW/IPC/S47/098 06/04/2011 GALAR Comments form English

BFW/IPC/S47/099 06/04/2011 Julie Owen Comments form English

BFW/IPC/S47/100 06/04/2011 T M F Neil & Mrs K M Neil Comments form English

BFW/IPC/S47/101 06/04/2011 Ben Morris Comments form English

BFW/IPC/S47/102 06/04/2011 D R D F Hogg Comments form English

BFW/IPC/S47/103 06/04/2011 H Hogg Comments form English

BFW/IPC/S47/104 06/04/2011 Sion Prys Davies Comments form Welsh Brechfa Forest West Wind Farm Consultation Report 122

3.11.2 A total of 108 individual relevant responses were received. Please note that the reference numbers do not reflect the overall number of responses received. A number of respondents provided more than one response on the proposal; two respondents were given two separate reference numbers for each of their separate responses; and one reference number (BFW/IPC/ S47/041) was given to two separate respondents in error.

3.11.3 A total of 82 comments forms were returned during the consultation period and 26 standalone letters or emails were received. Of those who filled in comments forms, 8 respondents provided additional information either in the form of a letter or email. One respondent requested that their response be treated as confidential and another withdrew their response on receipt of the acknowledgement from RWE NRL. In addition:

– Four responses were received in the Welsh language; – Nine responses were from organisations; – one response was received from an Member of Parliament, one from an Assembly Member and the local Councillor also provided a response (two reference numbers); – Two responses were anonymous; – Three responses provided no address or contact details (this includes the two anonymous responses) and therefore RWE NRL was unable to send an acknowledgment or reply.

3.11.4 Four responses were received after the deadline. In accordance with Section 49 (3)(b) of the Planning Act 2008, these responses are not considered relevant responses and have not been included in the analysis below. However, the responses have been reviewed so that any important points could be noted. These are set out below:

Date Name Type Language 07/04/2011 Sioned Elin Comments Welsh Form

07/04/2011 K Diffey Comments English Form

07/04/2011 V Z Diffey Comments English Form

07/04/2011 Lynette Morris Comments English Form Brechfa Forest West Wind Farm Consultation Report 123

feedback forms

3.12 Feedback forms

3.12.1 The following section provides an analysis of information received in feedback forms.

3.12.2 Question 1: what is your nearest town or village?

40

35

30

25

20

15

10 Number of respondents of Number 5

0

Talley Brechfa New Inn visiting Cwm Du Pontarsis Gwenogle Llansawel LampeterPencader LlantrisantLlandovery Llanybydder Carmarthen Gwyddgrug Capel Isaac Maesycrugiau Llidiad Nennog

Prefer not to disclose Alltwallis / Nearest town or village

Figure 1: Location of respondents

2.4.3 As shown in Figure 1, we can see that the significant majority of people who completed a feedback form were from Gwyddgrug (36 out of 82). The second most popular place was Brechfa with 12 out of 82 respondents.

2.4.4 Question 3: How did you learn about this consultation exercise?

2.4.5 When asked how attendees had learnt about the consultation exercise for the Brechfa Forest West Wind Farm, the feedback forms provided 103 answers. Respondents were asked to highlight all means through which they were made aware of the consultation process. It can be seen that the most effective means of raising awareness of the consultation exercise was the newsletter and ‘other’ options. Brechfa Forest West Wind Farm Consultation Report 124

Newsletter other Press notice CLG poster other media coverage via community council no answer

Figure 2: How respondents were made aware of consultation

3.12.6 Of all the answers given by people who completed a feedback form, 22% of answers suggested people were aware of the consultation process because of the newsletter. The press notice and Community Liaison Group (CLG) meeting were also referred to by 15% and 14% of the answers given. 9% of respondents had heard about the consultation from their Community Council.

3.12.7 The high proportion of people who completed a feedback form and stated that they were aware of the consultation exercise by other means was surprising (22%). It is apparent from RWE NRL’s analysis of the explanations for ‘other’, that this was mainly down to word of mouth. Overall the results received suggest that the various means of communicating with the public during the consultation process were successful.

3.12.8 Question 5: When developing the final application for the Brechfa Forest West Wind Farm, which elements do you feel are most important for RWE npower renewables to consider? Please circle your 3 main priorities

3.12.9 This question aimed at establishing the most important elements that respondents wanted RWE NRL to consider when developing the final application for the Brechfa Forest West Wind Farm. It should be noted that whilst respondents were asked to highlight their top 3 priorities, some highlighted less than 3 and others more than 3.

3.12.10 It can be seen that the 3 priorities identified by people who completed feedback forms were: – Maximising the distance of turbines from homes (23.2%) – Minimising visual impact (21.5%) – Transportation and access (16%) Brechfa Forest West Wind Farm Consultation Report 125

3.12.11 Together these 3 priorities comprised 60% of all priorities highlighted by respondents.

3.12.12 The next most highlighted priorities out of the options presented were: – recreation and public access impacts (10.1%) – minimising impacts on plant and animal habitats (8.4%) – impacts on the forests (6.75%) – impacts on water supply (4.6%)

3.12.13 2.5% of respondents highlighted the creation of jobs, 1.68% preferred not to give their priorities and 1.26% of answers given stated that all of the options presented on the feedback form should be considered as priorities.

3.12.14 2.1% identified different priorities to those presented on the feedback form. All of the 2.1% of respondents who completed feedback forms and highlighted “other”, stated that their other priority was noise issues.

3.12.15 Ensuring energy of supply and combating climate change, were both considered low priorities and together comprised just 1.68% of responses given.

maximising the distance from homes

minimising visual impact

transportation and access

minimising impacts on plant and animal habitats recreation and public access impacts

impacts on the forests

impacts on water supply

Creation of Jobs

prefer not to say

all of the above

other

ensuring security of energy supply

Combating Climate Change

Archaeology

Figure 3: Priorities identified by respondents on the wind farm feedback form. Brechfa Forest West Wind Farm Consultation Report 126

nrl response to summary feedback

3.13 RWE NRL response to summary feedback

3.13.1 The following table summarises the issues raised by respondents in the feedback forms, letters and emails. Commentary from RWE NRL is provided in response to the issues raised (presented by subject matter).

3.13.2 Please note that a more detailed summary of the issues raised is held in Appendix A.

3.13.3 Summary of responses included within feedback forms

Summary of responses RWE NRL response Archaeology Various issues were raised with regard to the impact of the proposed Chapter 7 of the ES: “Historic Environment”, assesses archaeological issues. The Brechfa Forest West Wind Farm on Archaeology. Common concerns comments received by respondents relate to on-site archaeology and appear to relate where that archaeological evidence should not be disturbed or to potential construction impacts (as this is primarily when disturbance or damage damaged, full studies of archaeology in the area should be undertaken, may occur). Chapter 7 has considered the possibility of finding archaeological remains the Environmental Statement (ES) ignores the historic value of the site currently covered by forest growth and, by way of mitigation, proposes that trial and the important archaeological features that are currently covered by trenches be excavated at the sites of Turbines 13, 17-19 and 23 prior to construction to forest growth. In addition, it was raised that archaeological sites should establish presence or absence of archaeological remains. If it is found that remains are not be disturbed for the financial benefits of wind farm developers. present, a watching brief will be undertaken during construction to record any surviving archaeological remains. A watching brief will also be undertaken during construction of all other infrastructure to record any previously unknown archaeological remains that may be present. This will be undertaken in accordance with the IFA Standard and Guidance for an Archaeological Watching Brief (IFA, 2008). Brechfa Forest West Wind Farm Consultation Report 127

Combating Climate Various issues were raised with regard to the impact of the proposed Further consideration has not been given to these comments due to the clear Change wind farm on combating climate change. Comments made included demonstrated need for this type of project set out in the National Policy Statements. issues such as: wind power is too unpredictable to be relied upon, Part 3 of EN -1 sets out the need for new nationally significant energy infrastructure climate change does not exist, the proposed wind farm would produce projects such as the proposed Brechfa Forest West Wind Farm. This policy makes it clear

more CO2 in production than ever recouped in use and we should be that the UK needs a mix of all types of energy infrastructure in order to achieve energy adapting to climate change and not combating it. security at the same time as dramatically reducing greenhouse gas emissions (para. 3.1.1). The policy further states that the IPC should therefore assess all applications In contrast comments were received that reflected a clear desire to on the basis that the need for energy infrastructure has been demonstrated by the UK combat climate change but did not feel that the proposed wind farm, Government and that this need is urgent (para. 3.1.3). a large scale industrial approach, was the most appropriate method Section 2.7 of EN-3 provides policy specific to “Onshore Wind”. The policy states that to combat it. It was suggested that a more holistic approach would be onshore wind farms are the most established large-scale source of renewable energy in more beneficial, such as co-working with Forestry Commission Wales the UK and that onshore wind farms will continue to play an important role in meeting (FCW) and Welsh Assembly Government (WAG) to construct a local renewable energy targets (2.7.1). wood burning plant to use forest waste which would in turn reduce the impact on transporting wood to a distant wood plant. It was suggested A carbon balance assessment was provided as an appendix to the Preliminary that the Forestry Commission Strategy of managing forests for carbon Environmental Information and an updated assessment has been provided in the final capture and tourism would be more beneficial. ES. This carbon balance assessment provides information in relation to the carbon It was also suggested that tidal energy would be the best way to footprint of the proposed wind farm. combat climate change with a lesser visual and noise impact to local residents. Further comments in relation to alternative methods of energy production as a mode of combating climate change were received such as the promotion of offshore wind farms, hydro schemes and small scale turbines.

Criticisms were made with regard to: lack of information in the ES in relation to the carbon footprint of the proposed wind farm; little evidence provided of the positive impact that the proposed wind farm would have of combating climate change and; lack of information with regard to carbon inputs of the scheme so that an assessment of the payback can be made against the embedded carbon loss from construction. Brechfa Forest West Wind Farm Consultation Report 128

Creation Of Jobs Few comments were received in relation to the importance of creation During construction, it is RWE NRL’s intention to source construction materials and of jobs as a result of the proposed wind farm. Of those comments labour locally where possible, and use local transport and plant hire companies received, issues ranged from concerns that any jobs created as a wherever possible to ensure maximum benefits are accrued by the local economy. result of the proposed wind farm would be transitory and short term, This is a practice that RWE NRL has employed successfully on other wind farm criticism that those jobs created would not be for local people and that development sites. wind farms are managed by a minimum of staff that would not benefit the local community. In addition comments were received stating During operation, direct employment will be generated for the maintenance and repair that the proposed wind farm would have an adverse impact on local work on the turbines. It is likely that this will be carried out by a team of staff. It is tourism which in turn would have an adverse impact on tourism jobs in estimated that this will equate to approximately 4-5 Full Time Equivalents (FTE’s). the locality. In relation to tourism, the wind farm will not directly prevent the public from visiting It was recognised that the proposed wind farm would create the area, however, there is the potential for indirect impacts on recreation and tourism construction jobs in the short term, during the construction period, which could occur due to perceived changes in the landscape and personal opinions however criticisms were made that the proposals would not create relating to the development. permanent posts. Furthermore, comments were made that of the construction jobs that would be created as a result of the proposed The impact that changes in views will have on tourism and recreation will partly depend wind farm would not benefit local companies. Reference was also made on the personal opinion of the viewer regarding the visual qualities of turbine structures to the neighbouring Alltwalis Wind Farm and that local people did not and perceptions regarding what they represent. This is a subjective matter; while some benefit from any job creation during its construction. Comments were people may dislike wind turbines, others view them as a complement to the landscape. also received referencing other sources of employment such as that Likewise, whilst some people consider wind turbines to be an unwanted mark of many more jobs would be created by tidal, biomass and small scale industrialisation in the landscape, others feel that turbines represent a progression energy generation and a managed forestry. Criticism was made that towards cleaner industry and welcome them as a means of addressing climate change. the ES failed to carry out a full evaluation of the economic importance Perceptions and attitudes towards wind farms have been the subject of several public of the forest and failed to highlight that securing the existing jobs in opinion surveys throughout the UK over the last 20 years. The report of the Sustainable the tourism and equestrian industry should be of importance. Development Commission Wind Power in the UK (2005) summarises the findings of 24 surveys conducted between 1992 and 2005, and reports that across these studies an average of 80% of respondents support the development of wind energy technologies.

Current research appears to suggest that whilst the ‘reactions’ of visitors to wind farms are varied; visitor behaviour does not tend to change significantly as a result of the development of a wind farm. The most recent research for the Scottish Government (Glasgow Caledonian University et al, 2008) indicates that delivering renewable energy targets through wind farm development will have a minimal impact on the tourism economy. A Wales Tourist Board survey found that wind farms are unlikely to affect peoples’ decisions to return to Wales although a small proportion of people would be put off by wind farm development (NFO, 2003). Brechfa Forest West Wind Farm Consultation Report 129

Effects On The Forest Concerns were raised about the impact of the wind farm on recreation, In response to comments raised about recreational impacts from both section 47 and ecology, hydrology, felling, economy, visual impacts and noise and section 42 respondents, further work has been done by RWE NRL to create a Public other pollution within Brechfa Forest. Concerns were raised with Access Management Plan and to provide further information about the impacts that regard to potential restrictions on recreational use within the forest may be expected during construction (although efforts will be made to minimise the such as walking and cycling. Comments were made with regard to the identified impacts). impacts of felling trees to make way for the proposed wind turbines and the resulting impact on wildlife and peat. In particular it was Similarly, in response to comments raised about wildlife impacts, further detail has been stated keyhole felling within the forest would decimate most of the provided in a Habitat Management Plan (HMP) appended to the ES. Within both the forest; loss of trees would result in the loss of wildlife and rare flowers; HMP and the non-avian ecology chapter of the ES (chapter 13), further commitments the creation of tracks, crane pads and turbine bases would damage have been made with regard to habitat creation across the site. or destroy fragile and scarce habitats; and adverse impact on peat resource within the forest. Whilst the Preliminary Environmental Information concluded that there was little or no peat at the site and therefore impacts would be negligible, a further peat probing study Suggestions were made that constructing fewer turbines would have has been conducted by RWE NRL in the light of comments raised by respondents. This less of an impact on the forest. In addition, comments were made that peat survey has reinforced the conclusions of the original desk-based work previously the construction of a wind farm within the forest would result in an presented and has been incorporated into the ES. industrial landscape. Concerns were raised in relation to the adverse impact the proposed wind farm would have economically both in terms In response to concerns raised about tree loss, and in discussion with FCW, it has been of forestry and to the recreation/leisure industry. decided that to mitigate these effects for the 25 year operational period, RWE NRL will work with FCW’s Wind Energy Programme team to locate and plant equivalent areas of It was also stated that the forest is not ancient woodland, it is a fast woodland in Wales. The objective is to ensure no net loss of trees associated with the growth forest and almost entirely commercial, whilst this does not development of the wind farm occurs, as set out in the Forestry Commission’s policy on arguably make for a habitat to be protected there is nonetheless, development affecting woodlands. The new planting may take place away from site but evidence that the forest and surrounding area are increasingly will be within Wales and will be mixed woodland. important to avian species and to dismiss the impact on these species would be negligible. Additionally a number of responses With regard to Phyhophera Ramorum, RWE NRL would cooperate with FCW who are the raised concerns with regard to the spread of Phythophera Ramorum experts on dealing with this issue. As the respondents correctly point out, information to the Brechfa Forest areas. Those that raised concerns with regard is available on the FCW website and RWE NRL would work closely with FCW to ensure to Phythophera Ramorum quoted information from FCW website that the necessary biosecurity measures are put in place. providing information about the fungal-like pathogen that kills many of the trees it infects including Japanese larch and rhododendron.

Further comments stated that the WG would fell the forest regardless of the development of the proposed wind farm. Brechfa Forest West Wind Farm Consultation Report 130

Effects On Water Supply Comments with regard to water supplies predominantly focus on the Flooding is a topic that is covered within the ES and following feedback from EAW and potential risk of flooding and potential adverse impacts on private through the S47 process, additional work has been done to supplement the existing water supplies as a result of the proposed wind farm. Responses information in the Preliminary Environmental Information that concluded that there received by RWE NRL highlighted issues such as: the risk of increase would be no increase in peak runoff and flood levels as a result of the presence of the run off and the effect it would have on rivers with the possibility of scheme. This additional work provides indicative designs of SuDS measures- highlighted flooding downstream (posing a risk to local villages); and the impact as important in one of the S47 responses. diversions of watercourses would have on potential flooding in the area. Criticisms have been made in relation to lack of knowledge of the Potential impacts on private water supplies have been studied by RWE NRL’s specialist potential impacts of the proposed wind farm on water supplies and hydrology consultants and are detailed, along with the proposed mitigation, in chapter that these may occur after it is too late to stop. 8 of the ES. Chapter 8 also outlines the measures that will be put in place to control erosion, sedimentation and water pollution. Specific measures to minimise risks to Common concerns with regard to proposed wind farms potential the water supplies at Coedlannau Fawr, Lan Ddu and Lan Farm are also set out within impacts on private waters supplies range from: impacts of construction chapter 8. The private water supplies at Lan Ddu and Lan Farm were highlighted and pollution to private waters supplies; impacts on wells and through the consultation process and this has allowed RWE NRL to take action to boreholes; and the potential of chemicals leeching into water supplies. address the risk of potential effects on these water supply (e.g. the realignment of the Requests were made for a legal binding agreement that should a access track within the site). private water supply be adversely impacted as a result of the proposed wind farm the issues would be rectified at no cost to the affected occupier.

Additionally, comments have been made with regard to the “lack” of studies into hydrological impacts of the wind farm, in particular impact on the water table. Suggestions were made that the Environment Agency (EAW) should produce a Sustainable Drainage System (SuDs) report, as per TAN15 “Development and Flood Risk” on which people should be consulted. In contrast to concerns relating to adverse impacts of additional run off as a result of the proposed wind farm comments received stated no concerns with regard to adverse impacts on drinking water. Brechfa Forest West Wind Farm Consultation Report 131

Ensuring Security Of Few comments were received in relation to the security of energy Further consideration has not been given by RWE NRL to these comments due to the Supply supply. clear demonstration of need for this type of project set out in the National Policy Statements. Of those comments received, issues such as: reliability of energy generation from wind farms; transmission losses; impossibility of wind Part 3 of EN-1 sets out the need for new nationally significant energy infrastructure farms securing energy supply; and possible alternatives sources of projects. It makes it clear that the UK needs a mix of all types of energy infrastructure in energy were highlighted by respondents. order to achieve energy security at the same time as dramatically reducing greenhouse gas emissions (para. 3.1.1). The policy further states that the IPC should therefore The comments made by respondents were predominately made on assess all applications on the basis that the need for energy infrastructure has been matters such as intermittency, unpredictability and unreliability of demonstrated by the Government and that this need is urgent (para. 3.1.3). wind energy generation in terms of security of supply. In particular, a number of comments received stated that wind turbines were Section 2.7 of EN-3 provides policy specific to “Onshore Wind”. It states that onshore inefficient and non productive. Specific references were made to wind wind farms are the most established large-scale source of renewable energy in the turbines not turning for long time periods at the neighbouring wind UK and that onshore wind farms will continue to play an important role in meeting farm. Alternative methods of energy security have been suggested by renewable energy targets (2.7.1). respondents such as hydro generation, biomass, ground/air source heat pumps and micro generation. Brechfa Forest West Wind Farm Consultation Report 132

Maximising The Distance A significant number of comments were received from respondents Consideration has been given by RWE NRL to the request to delete turbines 17, 18 From Homes with regard to maximising the distance of the proposed wind farm and 23 (spacing issues within the site mean that they cannot simply be moved further from homes. Assertions were made by some respondents that the back to increase the separation distance). The ES includes the results of a number of proposed wind farm should be located further away from properties. assessments undertaken on a wide range of issues and through the iterative design A number of comments were made with specific reference that the process it was not considered that any of the impacts identified were so major as to proposed wind farm, in particular turbines 17, 18 and 23 would be justify deleting these turbines. No clear reason has been provided for why the turbines too close to the village of Gwyddgrug. Additionally, comments were should be deleted and it is not considered that the resulting significant decrease in the made that the proposed property buffer was not sufficient and should capacity of the development is justified. be increased and that the proposed wind farm would have an adverse impact on property values. In contrast to this comments were also In terms of property buffers, the nearest residential property at Brechfa Forest West made by some respondents that the proposed wind farm was distant is approximately 900m away from the closest turbine. There is no justification for the enough from homes and that the existing neighbouring wind farm inclusion of an arbitrary buffer when there is no effects based reason to justify the Alltwalis was not audible. removal of the turbine.

Common concerns were raised included concerns that the proposed The Brechfa Forest West Wind Farm consultation documentation included a draft wind farm would have an adverse impact on the local population in Environmental Statement that fully examined the potential effects arising from the terms of noise pollution. Specific comments were made that many proposed development and whether these effects are acceptable. people have noise issues with the existing neighbouring wind farm Alltwalis and considered that additional turbines in the area would The consultation responses do not explain or identify the evidence base that underpins increase this noise issue. Additionally, specific comments were made this requested restriction. The responses do not clearly demonstrate that large scale that noise considerations should address the fact that individuals wind farms have an unacceptable impact upon residential amenity within a large buffer tolerance to noise varies. of residential properties. When taken at face value, this proposition- as presented in the responses to this section of the feedback form- seems unjustifiable on the basis that Additional concerns were raised that the proximity of the proposed there are many operational wind farms in Wales and the UK that have turbines within wind farm to properties would cause increased medical conditions and this separation distance that have not given rise to any complaints or indeed may not be requests for studies into these assertions were made. visible from properties within a specific buffer.

It was suggested that the turbines should be sited offshore and not The request further fails to accord with TAN8, Annex D, paragraph 3.4 which sets out within a tourist attraction. the methodology for Local Planning Authorities to refine their Strategic Search Areas (SSAs). In assessing the capacity of refined areas, para 3.4 states that a buffer of 500m radius should be drawn as it is considered a typical separation distance between a wind turbine and a residential property to avoid unacceptable noise impacts. Furthermore, para. 3.4 states that a 500m buffer should not be applied rigidly as it can lead to conservative results and flexibility is advised.

Noise issues are considered in great detail in Chapter 16 of the ES. Following comments made in the section 47 consultation exercise, and as received from Carmarthenshire County Council, additional information has been provided (see appendix F) and investigated. Brechfa Forest West Wind Farm Consultation Report 133

Minimising The Effects Various issues were raised with regard to the impact of the proposed It is not the intention to deal with each of these species in turn within this document as On Plants And Animal wind farm on plants and animal habitats within the Brechfa Forest. each is covered in some detail within the ES. It is noted that further information has also Habitats Concerns were raised with regard to: the potential negative impact been added to the draft chapter on non-avian ecology to supplement it following the the proposed wind farm could have on rare plants and flowers given responses received by RWE NRL. that Brechfa Forest is an environmentally sensitive area; and habitats being destroyed as a result of constructing the proposed wind farm In response to the comments raised about wildlife impacts, further detail has with particular concerns regarding noise and destruction affecting been provided by RWE NRL in a Habitat Management Plan (HMP) appended to the protected species. Environmental Statement. Within both the HMP and the non-avian ecology chapter further commitments have been made by RWE NRL with regard to habitat creation Specific comments were made with regard to potential negative across the site. impacts on birds such as red kites and barn owls. In addition, a number of comments were raised with regard to a potential negative impact to RWE NRL’s specialist ecological consultants are confident in the conclusions presented bats, polecat, pine marten and a red squirrel population within Brechfa in the ES and are confident that the mitigation proposed is appropriate to address the Forest. impacts associated with the wind farm..

Criticism is made that the ES concludes that the proposed wind It is not possible to avoid the removal of hedges as the proposed site access to the wind farm would not have a significant impact on wildlife species within farm requires the creation of a new access point off the A485 (with associated hedge the forest. Additionally criticism is made of the proposed mitigation removal). However, mitigation in the form of planting of new hedges along the new measures proposed within the ES. Requests were made that no hedges access track is proposed. should be removed and the habitats of rare species such as the red squirrel, polecat and pine marten should be safeguarded. Brechfa Forest West Wind Farm Consultation Report 134

Minimising Visual Effects Comments with regard to minimising visual impact of the proposed RWE NRL must balance the urgent need for renewable energy with a range of wind farm predominantly focus on the height of the proposed wind environmental constraints- including visual effects. The need is set out in National Policy turbines. Comments received suggested that the proposed wind Statements. EN-1 sets out the Government’s conclusion that there is a significant need turbines should be reduced in height and moved further into Brechfa for new major energy infrastructure (see Section 3.3 of EN-1). EN-1 Section 3.4 includes Forest or deleted in order to minimise their visual effect. assessments of the need for new major renewable energy infrastructure.

Specific comments were made with regard to: the proposed wind As the site has been developed, specialist landscape and visual consultants have played farm being an eyesore to the countryside; the proposed wind farm a vital role in the design process. The principles applied in this design strategy are set dominating the skyline and towering over the neighbouring villages; out in chapter 3 of the ES. impossibility of minimising the visual effects of the proposed wind farm which would be visually intrusive across South Wales; and not Wind turbines are large structures that cannot be hidden. Deleting turbines 17, 18 and being able to screen the proposed wind farm. 23 would not drastically change the visual impact in the wider area. The loss of clean energy production associated with this change would also be significant. Common concerns were raised with regard to the visual impact of the existing neighbouring Alltwalis Wind Farm. Particularly that the Alltwalis Wind Farm was far more visually intrusive when constructed compared with what was shown on the development plans, raising further concerns that the proposed Brechfa Forest West Wind Farm would also be more visually intrusive when constructed. Particular reference was made with regard to deleting turbines 17, 18 and 23. It was also suggested that in order to minimise the visual effect of the proposed wind farm the proposed wind turbines should be painted with invisible paint.

Criticism is made that the developers had made no attempt to take into account the responses from the community during the consultation process with regard to the visual impact of the proposed wind farm. Brechfa Forest West Wind Farm Consultation Report 135

Recreation Or Public Various issues were raised with regard to the impact of the proposed In response to comments raised about recreational impacts from both section 47 and Access Effects wind farm on recreation and access at Brechfa Forest. The concerns section 42 consultees, further work has been done by RWE NRL to create a Public Access raised included: ramblers, walkers and cyclists would be pushed out of Management Plan and to provide further information about the impacts that may be the forest; tourism and leisure activities would be adversely affected; expected during construction (although efforts will be made to minimise the impacts concerns with regard to the safety of forest users once the wind identified). farm had been constructed and loss of access to the forest during construction of the proposed wind farm. Concerns were raised about The impact that changes in views will have on tourism and recreation will partly depend compliance with Policy EN1 in terms of impacts on open access land. on the personal opinion of the viewer regarding the visual qualities of turbine structures and perceptions regarding what they represent. This is a subjective matter; while some In contrast comments were made by some respondents that the people may dislike wind turbines, others view them as a complement to the landscape. proposed wind farm would have an adverse impact on tourist, visitor Likewise, whilst some people consider wind turbines to be an unwanted mark of and holiday maker numbers to the area which was considered to be a industrialisation in the landscape, others feel that turbines represent a progression good thing. towards cleaner industry and welcome them as a means of addressing climate change. Understanding the potential effects of the wind farm can sometimes be subjective and Common concerns were that people would not want to use the therefore hard to quantify. Perceptions and attitudes towards wind farms have been forest for recreation post the industrialisation of the forest as a the subject of several public opinion surveys throughout the UK over the last 20 years. result of the proposed wind farm. Additionally, requests were made The report of the Sustainable Development Commission Wind Power in the UK (2005) that paths through the forest should be safeguarded. Furthermore summarises the findings of 24 surveys conducted between 1992 and 2005, and reports comments were made negative impact on tourism in the area would that across these studies an average of 80% of respondents support the development result in adversely impacting the Welsh economy and that the WAG of wind energy technologies. had not consulted the local community before allowing a wind farm development at Brechfa Forest. Transportation And Access Comments received included those that cited a lack of understanding RWE NRL have investigated in some detail the possibility of utilising the existing as to why RWE NRL has considered another entrance when an existing access for the Alltwalis Wind Farm. Unfortunately it has not been possible to reach a one is “more than adequate”. This was proven mid February 2011 commercial agreement with the landowner. In order to mitigate the issues raised by a when the existing track was operational for repair. Other comments range of groups and individuals who have responded to the consultation, screening is cited that the access track will “blight our property” with no proposed to mitigate landscape and ecological impacts associated with the new access consultation carried out about this. track.

Local roads are identified as already being inadequate and additional A Traffic Management Plan will be prepared for the proposed wind farm in advance of traffic will exacerbate this. Local residents walking, cycling or riding on construction to ensure that impacts on local people in the form of delays, inconvenience roads will be placed at risk. Local people encountered significant delays and additional risks are minimised. and inconveniences when the adjacent Alltwalis Wind Farm was being constructed. Concerns about accidents and the impacts on other road Council tax payers will not have to pay for repairs to roads caused by construction traffic users, pedestrians etc were also raised. associated with the wind farm proposal – costs for repairs to roads will be covered by RWE NRL. Concerns were also raised that Council tax payers will have to pay for repairs to road caused by construction traffic. Brechfa Forest West Wind Farm Consultation Report 136

Anything else to be People already losing sleep due to existing turbines, It is assumed that losing sleep is in relation to noise impacts. Chapter 16 of the ES considered? covers noise impacts and concludes that there will be no significant adverse impacts Preserve the mature trees beside the A485. caused by the Brechfa Forest West Wind Farm- both on its own and cumulatively with other wind farms. RWE NRL is not able to comment on issues that may be occurring with Concerns about health impacts and noise transmission through rock noise at another developer’s wind farms. and noise pollution within the forest. The Developer should fund a noise expert for the community. It is not possible to commit to conserving all the mature trees alongside the A485 at the site entrance as there will be a need to create a new access off the A485 which will RWE NRL should help support local microgeneration. require some removal of trees/ hedgerows.

The forestry commission has always managed to haul their timber The standard noise assessment criteria as recommended by National Policy Statements, out on artic lorry’s and the same roads should be used, upgraded Welsh Government Policy and local policy is ETSU-R-97. This relates to noise at if necessary. There will be enough damage done to the countryside residential properties. Assessment of noise within the forest is not therefore required. without building new roads and massive visibility splays. There will be a community benefits package associated with the proposed wind farm The impact on the Cambrian Mountain Initiative. that will be administered locally. The respondent may wish to make an application to the fund when it is in place.

Alternative access options have been considered in some detail and in the light of comments made through this consultation, this information is now set out in detail in the ES. If you think the project will Cannot think of any positive effects. have positive effects, how can these be enhanced or Access to the wind farm after construction will be interesting. maximised? Will only benefit Developers bank balance. Brechfa Forest West Wind Farm Consultation Report 137

If you have concerns Concerns about properties being devalued and noise impacts being A requirement is attached to the draft Development Consent Order that commits RWE about the project, how do experienced. A legally binding commitment was requested to protect NRL to operating the Brechfa Forest West Wind Farm within specified noise limits. you think these could be home owners from devaluation and noise impacts. Enforcement action can be taken against the developer if this requirement is not avoided or minimised adhered to. It was suggested that a smaller scale of development would be more appropriate. It is not considered that the potential adverse impacts and constraints of the Brechfa Forest West Wind Farm justify reducing the size of the development. There were concerns about cumulative effects, lack of jobs linked to the wind farm and regarding the routing of turbine deliveries. Cumulative effects are assessed throughout the ES.

Planning permission should be refused. During construction, it is RWE NRL’s intention to source construction materials and labour locally where possible, and use local transport and plant hire companies Development should comply with British Horse Society (BHS) guidance. wherever possible to ensure maximum benefits are accrued by the local economy. During operation, direct employment will be generated for the maintenance and repair work on the turbines. It is likely that this will be carried out by a team of staff. It is estimated that this will equate to approximately 4-5 Full Time Equivalents.

Traffic and transportation impacts have been assessed in the ES. The turbine layout Concerns were raised about turbines 17, 18 and 23 and it was Consideration has been given to the request to delete turbines 17, 18 and 23 (spacing suggested that the turbines were too close to properties and should be issues within the site mean that they cannot simply be moved further back). The ES moved back into the forest to minimise noise and visual effects. has undertaken assessments on a wide range of issues and through the iterative design process it was not considered that any of the impacts of the wind farm were so It was also felt that the turbines are close to properties already substantial as to justify deleting these turbines. No clear reason has been provided for affected by noise from the existing wind farm. why the turbines should be deleted and it is not considered that the resulting significant decrease in the capacity of the site is justified. Forest tracks are used by tourists. Cumulative noise has been assessed in the ES and further considered by RWE NRL’s Does not comply with BHS advice. specialist noise consultants following responses received via the Section 47 consultation and from Carmarthenshire County Council.

The BHS guidance refers to ‘all routes including roads’. Given that the all tracks in the forest may be used by horse riders under permissive rights granted by Forestry Commission Wales, it is impossible to provide stand off distances from all tracks- this is also inconsistent with the objective of using existing tracks as far as possible to reduce the need and associated impacts of new construction access tracks. Brechfa Forest West Wind Farm Consultation Report 138

Siting of infrastructure Access infrastructure should be shared with the existing Alltwalis Wind RWE NRL have investigated in some detail the possibility of utilising the existing Farm. access for the Alltwalis Wind Farm. Unfortunately it has not been possible to reach a commercial agreement with the landowner. In order to mitigate the issues raised by a Lack of information regarding the grid connection route. Brechfa range of groups and individuals who have responded to the consultation, screening is Forest West Wind Farm should use the existing grid connection to the proposed to mitigate landscape and ecological impacts associated with the new access Alltwalis Wind Farm. track.

Concerns that the Company will not pay for cable if television signals The grid connection does not form part of this application for consent and therefore are affected. only a high level assessment of an indicative route has been provided. There is not sufficient capacity remaining in the local area for connection of a project of the size of Brechfa Forest West Wind Farm, hence the proposed connection to Swansea North substation.

A requirement is included attached the Development Consent Order that required RWE NRL to conduct a TV survey and to mitigate (at its cost) any impacts caused by the wind farm on television reception.

Surveys that have been The company has not been in touch with residents about surveys, It is likely that this question was misinterpreted and many respondents thought they undertaken photomontages are deceptive, and information has been presented had not been included in a door knocking exercise, when the question meant to refer to with a positive spin and concerns that studies are going to be biased as the surveys within the ES. they have been paid for by the RWE NRL. Too much uncertainty exists within the survey results.

Most conclusions are based on wind farm experience elsewhere; there is no comparable experience for the cumulative impacts that will be seen here.

Information about number, size, and location of tourist and equestrian businesses is missing.

Brechfa Forest West Wind Farm Consultation Report 139

Proposed mitigation Council tax should be reduced, no measures can redress the potential Reducing council tax is not something that RWE NRL have any power over. measures problems, mitigation is inadequate, communication has been poor. There is no peer reviewed evidence linking long term health effects with wind farms, Long term heath effects have not been considered. and there is no reason to expect that Brechfa Forest West Wind Farm would give rise to long term health effects. Mitigation does not take account of tourists in the forest, or safety guidance for equestrians published by the BHS. There are no bridleways within Brechfa Forest West therefore stand off distances from bridleways are not considered to be relevant. The mitigation does not consider how tourists use the forest. In response to recreational concerns raised, a Public Access Management Plan has How can you mitigate against a displaced avian population. been produced which outlines both mitigation and gain relating to public access and recreation within the forest. Further comments Varied concerns including, emergency access, cumulative impacts, In general, these concerns are addressed within the ES. As such RWE NRL has not impact on property values, noise, the impact on people flying eagles sought specific changes be made to the application to address these comments. in the Forest, impact on visitors who walk and ride in the Forest. These visitors support other businesses such as pubs etc. However, with respect to public Rights of Way, additional information and extra proposals have been made in the ES relating to providing diversions to public Rights of The alternative Rights of Way are inadequate. There is already a Way. This is set out in the Public Access Management Plan. shortage of public Rights of Way that can be used by horse riders. Horses will be affected by noise and blade flicker from the turbines. It is not correct to state that wind turbines cause more emissions than they will ever cut. The economic impact of the local equestrian economy is critical. This is demonstrated in the carbon balance report appended to the ES.

Concerns about the safety of visitors to the Forest. In terms of the consultation process, this was undertaken in accordance with the Brechfa Forest West Wind Farm SOCC. In response to demands for an exhibition in Wind turbines cause more emissions that they will ever cut. Gwyddgrug (where there wasn’t a venue big enough) an additional exhibition was held Alltwalis. It is claimed that the consultation was inadequate and there should have been consultation event in Gwyddgrug. It is not considered appropriate that the developer should provide funding to the community to employ consultants. Oil, nuclear, coal and gas are not the way forward.

Developer should provide funding to the community to employ consultants.

The CLG meetings have not been productive.

The site is within the Cambrian Mountain Initiative which seeks to develop the economy of the area based on its attractive landscape.

Proposal does not comply with EN1. Brechfa Forest West Wind Farm Consultation Report 140

letter summaries and responses

3.14 Letter summaries and responses

Letter Reference Number Summary of Letter RWE NRL response

BFW/IPC/S47/001 Will the wind farm access be decided by the IPC or CCC planning committee? This query was responded to and it was confirmed that it was expected that it would be determined by the IPC. BFW/IPC/S47/002 Uses forest regularly for recreational purposes, feels there is potential for more This query is noted and was taken into consideration when reviewing the turbines, urges RWE to consider placing more turbines within the development. alternative viewpoint that turbines should be deleted and the scale of the proposal reduced. BFW/IPC/S47/003 Disappointed that there are no public exhibitions in Alltwalis or Pencader. Following this feedback, a further exhibition was arranged by RWE NRL to be held in Alltwalis. BFW/IPC/S47/004 Requested exhibition within Llanfihangel-ar-Arth Community Council area. Following this feedback, a further exhibition was arranged by RWE NRL to be held in Alltwalis. BFW/IPC/S47/005 Request for ES This request was received by email. RWE NRL directed this person to the ES on the project website and advised the locations where the hard copy document could be viewed. BFW/IPC/S47/006 Request for a more detailed reply to letter dated 23rd May 2010. A more detailed reply enclosing information from the draft ES was provided. Brechfa Forest West Wind Farm Consultation Report 141

BFW/IPC/S47/007 Do not object to the scheme per se but specific elements. Cumulative visual Cumulative landscape impacts are assessed in the ES. impact resulting in a change of landscape character. Believes height of turbine should match Alltwalis Wind Farm. Concerns over noise. Suggests a distance Tall turbines are required at Brechfa Forest West due to the need to elevate the from homes of 1 mile. Concern that the ES has not taken into account noise blades above the forest canopy. Elevating the blades above the trees serves to complaints from Alltwalis Wind Farm. Concern over the weather conditions avoid major turbulence impacts on the turbines. Further explanatory information when background noise was measured. Objection to the height of the turbines about this is included in the revised ES in chapter 15. and proximity to homes. Objection to turbines 17,18,19,23 and 24, especially 17 and 23. There is no justification for the inclusion of an arbitrary buffer of 1mile. The Brechfa Forest West Wind Farm consultation included a draft ES that fully examined the potential effects arising from the proposed development and whether these effects are acceptable. The consultation response does not explain or identify the evidence base that underpins this requested buffer distance restriction in order to clearly demonstrate that large scale wind farms have an unacceptable impact upon residential amenity within a distance of 1 mile of residential properties. When taken at face value, this proposition seems unjustifiable on the basis that there are many operational wind farms in Wales and the UK that have turbines within this separation distance that have not given rise to any complaints or indeed may not be visible from properties within that buffer.

The 1 mile buffer distance request further fails to accord with TAN8, Annex D, paragraph 3.4 which sets out the methodology for Local Planning Authorities to refine their Strategic Search Area’s. In assessing the capacity of refined areas, para 3.4 states that a buffer of 500m radius should be drawn as it is considered a typical separation distance between a wind turbine and a residential property in order to avoid unacceptable noise impacts. Furthermore, para. 3.4 states that a 500m buffer should not be applied rigidly as it can lead to conservative results and flexibility is advised.

Noise complaints relating to Alltwalis Wind Farm are not something that RWE NRL can comment on as the full information is not available to us.

Weather conditions during background noise monitoring are described in the ES and the length of the monitoring period was extended at a number of properties to reflect the poor weather conditions.

No clear justification is provided for the objection to the specific named turbines. BFW/IPC/S47/008 Would not want Turbines W7, W12 and W16 to move any further East or South, This is noted. would like them to be moved West and/or North. Brechfa Forest West Wind Farm Consultation Report 142

BFW/IPC/S47/009 Request for an upgrade/creation of vehicular access across the Forest. Request The requested access through the Forest is not something that RWE NRL are able for a grant for the local development fund for ‘treadlightly trust’. to grant. There is restrictive guidance on extensions to vehicular rights.

The respondent may make an application to the Community Benefit Fund at the appropriate time if they so wish. BFW/IPC/S47/025 Queried which turbines fell within which community council boundary Provided this respondent with a plan showing the wind farm site boundary overlaid onto the Llanllawddog Community Council boundary BFW/IPC/S47/045 Complaints about the lack of exhibition in Gwyddgrug/ New Inn. Complaint The exhibition in Alltwalis was advertised locally and letters sent to postal that the exhibition held in Alltwalis was too low key. Complaint that there was addresses in Alltwalis and Gwyddgrug. In order for transparency, all comments no means of recording feedback provided orally at the exhibition (nor RWE NRL must be provided in writing and it was clearly stated at exhibitions that responses). comments made orally would need to be provided either on a feedback form, by Issues raised about creation of a new access track and states that insufficient email or in a letter. information was made available. Comments made about activities on land where the proposed access track is RWE NRL have investigated in some detail the possibility of utilising the existing situated. access for the Alltwalis Wind Farm. Unfortunately it has not been possible to Comments on the location of the Gwyddgrug viewpoint. reach a commercial agreement with the landowner. In order to mitigate the issues raised by a range of groups and individuals who have responded to the consultation, screening is proposed to mitigate landscape and ecological impacts associated with the new access track. The activities mentioned that occur on private farmland are not associated with RWE NRL or the proposed Brechfa Forest West Wind Farm.

RWE NRL gained agreement from the CCC and CCW on viewpoint locations ahead of this work being undertaken. Brechfa Forest West Wind Farm Consultation Report 143

BFW/IPC/S47/051 Concerns raised about the way in which the proposed access was It was not considered appropriate by RWE NRL to communicate the proposed communicated. access route until the landowners had decided that they wished to be involved in Complaint that one map was on top of another at the Alltwalis exhibition- the scheme. confusing. Should have held an exhibition in Gwyddgrug. The public exhibition held at Alltwalis was in a smaller venue and this did mean Objections over the access route chosen- suggest either existing Alltwalis Wind that RWE NRL was unable to spread the exhibition materials out as much. The Farm access track or minor road from New Inn. plan referred to by the respondent is frequently requested- the plan is a zoomed Concerns raised about the removal of trees and hedgerows. out plan showing the site within the context of the wider area. Concerns over the impact on emergency services using the A485. Queries how local residents will be protected from dust, noise etc during Due to the amount of exhibition materials, it was considered that the construction. Gwyddgrug vestry, being even smaller than the Alltwalis venue, was too small Queries regarding off-site access works to accommodate a public exhibition. A copy of the consultation materials was instead held in the Gwyddgrug Post Office for the residents of Gwyddgrug (and elsewhere) to view. Additionally residents in Gwyddgrug were invited to the Alltwalis public exhibition.

RWE NRL have investigated in some detail the possibility of utilising the existing access for the Alltwalis Wind Farm. Unfortunately it has not been possible to reach a commercial agreement with the landowner. In order to mitigate the issues raised by a range of groups and individuals who have responded to the consultation, screening is proposed to mitigate landscape and ecological impacts associated with the new access track. The removal of trees and hedgerows has been considered within the ES and post- consultation, further mitigation has been proposed. Consultation has and will continue to take place with the emergency services with regard to the proposal, including construction traffic. A detailed Traffic Management Plan (TMP) put in place prior to the commencement of construction. A detailed Construction Method Statement (CMS) will be produced in advance of construction in order to minimise impacts associated with construction. Further to the consultation on the draft application for Brechfa Forest West Wind Farm, a ‘dry run’ of the access route has taken place. This access route assessment has concluded that no off-site works on the road network will be required. BFW/IPC/S47/061 Strong objection to scheme. Concern over bird (Buzzards, Red Kite, Sparrow These issues have been considered in the ES in detail and Habitat Management Hawk, Kestrel, Goshawk) collisions. Concern over the affect on badgers and Plan (HMP) has been revised to include additional mitigation particularly with bats as a result of the development and operational phase. States that reptiles regard to habitats are protected and found in local watercourses. BFW/IPC/S47/063 Strong objection to scheme. Concern over bird (Buzzards, Red Kite, Sparrow As above Hawk, Kestrel, Goshawk) collisions. Concern over the affect on badgers and bats as a result of the development and operational phase. States that reptiles are protected and found in local watercourses. Brechfa Forest West Wind Farm Consultation Report 144

BFW/IPC/S47/066 Summary of Revised Draft Overarching National Policy Statement for Energy This feedback will be summarised in the Consultation Report and provided to the (EN-1) provided. Request that the IPC should not grant Development Consent IPC. on existing open space, sports and recreational buildings unless it has been assessed by the local authority. In addition, it is stated that applicant should consult their local community in response to development on open access land.

BFW/IPC/S47/067 Query as to whether information is available as to the location of proposed A high level commentary on an indicative grid connection route from Brechfa grid connection for the new wind farms at Bryn Llywelyn, Brechfa Forest East Forest West (and Brechfa Forest East) to Swansea North substation is provided in and Brechfa Forest West. Concerns raised that there are a number of overhead the ES and was available during consultation. The respondent was directed to this cables and they would not want anymore. Request for location of information document. with regard to the proposed grid connection. RWE NRL is not able to comment on more detailed aspects of the grid connection as it does not form part of this application and is the responsibility of Western Power Distribution. BFW/IPC/S47/067 Further request for information with regard to Bryn Llywelyn Wind Farm and As above. Second letter Brechfa Forest East Wind Farm. In addition a request is made whether the route of cables has been revealed or discussed with the landowners affected by the proposals. BFW/IPC/S47/068 Letter from Grwp Blaengwen The specific concerns raised with regard the proposed wind farm are not Provision of general feedback in relation to existing proposals for adequately substantiated. developments of wind farms in the Brechfa area. Specific concerns raised with regard to the proposed wind farm would alter further and irreparably the RWE NRL defend the way that information has been provided to the CLG. In character of the area, its land use, ecology, water flow, social and community some cases it is not possible to provide information at an early stage as it may be realities and prospects. unavailable or commercially sensitive.

Comments with regard to Community Liaison Group (CLG) Meetings are The draft ES was placed at the Gwyddgrug Post Office because it is a local venue made, with particular reference to concerns raised in reference to access that is open for long hours so access to the ES was maximised. Availability of proposals and lack of provision of information in 2009 as information was other regularly open venues in the area was limited. commercially sensitive. Criticism is made with regard to lack of consultation with the local community. Criticism is also made that the draft ES was placed RWE NRL’s specialist landscape consultants are confident in their assessment. at the Gwyddgrug Post Office where it isn’t possible to sit down; there are Photomontages are designed to be indicative only to give the viewer an idea of discrepancies over the accuracy of the viewpoints from certain properties, the the potential impact from this location. A Residential AmenityAssessment has photomontage from Gwyddgrug bridge is misleading, little consideration has been completed specifically for properties in close proximity to the wind farm. been given to properties within close proximity of the proposed wind farm, Additionally nearby properties are specifically considered in noise and shadow and there has been no consultation over local visual impact. flicker chapters of the ESl.

Particular focus is made to three aspects of the draft ES raising concerns The ES is a technical document and scientific terminology is used where with regard to Access Traffic and Transportation, Land use and Forestry and appropriate. The non-technical summary is intended to be a more accessible Noise and Vibration. Further criticism is made with regard to the difficulty in document. The non-technical summary has been made available in both English interpreting scientific jargon within the ES. and Welsh. Brechfa Forest West Wind Farm Consultation Report 145

BFW/IPC/S47/070 Explanation made that it is very difficult to keep emotion out of the letter The Strategic Search Area (SSA) approach adopted by the Welsh Government given that it will be considered by the developer or the IPC. Comments made in its TAN 8 document inevitably leads to cumulative impacts as it focuses the that most people in the area are confused about which development is which development of large scale wind farms in seven areas in Wales. Notwithstanding and there is an overwhelming feeling that the community in Brechfa are being this, cumulative impacts have been assessed throughout the ES and this singled out to have its beautiful environment impacted upon by a wind farm. information is available for people to consider. Additional concerns are raised with regard to the layout of the proposed development focusing on the size of the proposed wind turbines. Furthermore Tall turbines are required at Brechfa Forest West due to the need to elevate concerns are raised with regard to noise that the proposed wind farm will the blades above the forest canopy to avoid major turbulence impacts on the produce referencing the issues that have occurred in terms of noise nuisance at turbines. Further explanatory information about this is included in the revised ES. the neighbouring Alltwalis Wind Farm. It is not appropriate for RWE NRL to comment on noise issues experienced at another developer’s wind farm. Chapter 16 of the ES concludes that the Brechfa Forest West Wind Farm will comply with noise limits set out in ETSU-R-97 both in its own right and cumulatively. BFW/IPC/S47/071 Email received from local Councillor for the Llanfihangel ar Arth ward. The 1. RWE NRL have investigated in some detail the possibility of utilising the covering email thanks RWE NRL for its cooperation during the consultation existing access for the Alltwalis Wind Farm. Unfortunately it has not been period. possible to reach a commercial agreement with the landowner. In order to The attached letter objects to the proposed wind farm for a number of reasons: mitigate the issues raised by a range of groups and individuals who have 1. Proposed new access- the response states that this is unnecessary responded to the consultation, screening is proposed to mitigate landscape and and that the existing Alltwalis Wind Farm access track should be ecological impacts associated with the new access track. Further information used. It notes that the farm on which the access track is located about the proposed access track as well as the consideration of alternatives that is for sale. Concerns are raised about visual impact of the track took place is provided in the revised ES. and possible increased noise issues from the Alltwalis Wind Farm 2. A full review of the viewpoint assessment has taken place post-consultation for those living opposite the proposed access. It is stated that in the light of the comments made by both the CCC and Countryside Council for there is insufficient information about the proposed access or the Wales (CCW). It should be stated, however, that whilst the CCC may consider consideration of the Alltwalis access. that 13 of the viewpoints have been understated, either in terms of sensitivity or 2. Visual impact- the response states that Carmarthenshire County magnitude, the significance level is not different to that described in the ES (i.e. Council (CCC) have reviewed the viewpoints and consider that 13 those that are considered ‘significant’ are also considered ‘significant’ by CCC of the viewpoints have been understated and will have a significant and those that are considered ‘not significant’ are considered ‘not significant’ by impact. CCC). 3. Siting of the turbines- concerns raised on the height of the proposed 3. An explanation for the height of the turbines is provided in the revised ES. No turbines, the cumulative impact with the existing Alltwalis turbines, changes have been made to the location of turbines as no material reasons have and the siting of turbines near to properties that are already affected been provided for doing so. by the Alltwalis Wind Farm. 4. Further work has been done on PWS since the consultation closed. This 4. Private Water Supplies (PWS)- raises concerns that the developers includes the PWS highlighted by CCC in their response. do not have full knowledge of private water supplies in the area and 5. Noise has been carefully considered in the ES and further work has been done therefore cannot provide mitigation details. on cumulative noise following the detailed comments received from CCC. 5. Noise- raises serious concerns about cumulative noise impacts with the existing Alltwalis Wind Farm Brechfa Forest West Wind Farm Consultation Report 146

BFW/IPC/S47/076 Letter received from Carmarthenshire East and Dinefwr MP. It is not for RWE NRL to comment on the role of elected members in the IPC Concerns raised as to unhappiness that the democratic process once a project process. Efforts have been made to keep elected members updated about project goes to the IPC for consideration does not allow contribution for elected progress throughout the development of the wind farm. members, given members are often seen as a point of contact for constituents. The Strategic Search Area (SSA) approach adopted by the Welsh Government Concerns are raised with regard to the following issues: potential cumulative in its TAN 8 document inevitably leads to cumulative impacts as it focuses the effect on the Brechfa Forest area as there are a number of other wind farm development of large scale wind farms in seven areas in Wales. Notwithstanding applications; The three applications would add to 61 turbines within the area; this, cumulative impacts have been assessed throughout the ES for the Brechfa concerns are raised with regard to local infrastructure of the roads to cater for Forest West Wind Farm and this information is available for people to consider. the developments; negative impacts on tourism; visual impact of the proposed development. There is no justification for the inclusion of an arbitrary buffer of 2km. The Brechfa Forest West Wind Farm consultation included a draft ES that fully Suggestions are made that large commercial wind farms should be offshore, examined the potential effects arising from the proposed development and not simply to address public amenity but with regard to the efficiency of whether these effects are acceptable. offshore wind farms. Reference is made to TAN 8 and that when it was first adopted in 2005 the average height of wind turbines was in the region of 90 The consultation response does not explain or identify the evidence base that metres tall. In addition, a 2KM buffer is suggested. underpins this requested restriction to clearly demonstrate that large scale wind farms have an unacceptable impact upon residential amenity within a distance of 2km of residential properties. When taken at face value, this proposition seems unjustifiable on the basis that there are many operational wind farms in Wales and the UK that have turbines within this separation distance that have not given rise to any complaints or indeed may not be visible from properties within that buffer.

The request further fails to accord with TAN8, Annex D, paragraph 3.4 which sets out the methodology for Local Planning Authorities to refine their SSAs. In assessing the capacity of refined areas, para 3.4 states that a buffer of 500m radius should be drawn as it is considered a typical separation distance between a wind turbine and a residential property to avoid unacceptable noise impacts. Furthermore, para. 3.4 states that a 500m buffer should not be applied rigidly as it can lead to conservative results and flexibility is advised. Brechfa Forest West Wind Farm Consultation Report 147

BFW/IPC/S47/077 Response received on behalf of the Carmarthenshire Riders. EN-1 quote is not correct. Section 5.10 of EN-1 refers to Land Use including open space, green infrastructure and Green Belt. It does not refer specifically to open Concerned that EN1 specifically states that if a development is on open access access land and states only that the applicant should consider providing new or land then exchange land has to be provided. This application does not include additional open space. It goes on to further give guidance for exchange land. any information on the exchange land to be provided. Concerns over safety Given that restrictions to open access are temporary only, it is not considered that of local riders during the construction phase and operational phase. Concerns exchange land is necessary. over noise and compliance with ETSU R97. Concerns over the community consultation. Concerns that information provided by Carmarthenshire riders Access will be restricted to areas of the Forest where construction is taking place has not been incorporated into the ES in order to protect public safety. During operation, the Forest will be open to users as normal. Warning signs will be erected for horseriders.

The noise chapter of the ES demonstrates that the proposed wind farm will comply with ETSU-R-97

Information provided by Carmarthenshire Riders has been incorporated in chapter 11 of the ES. BFW/IPC/S47/078 Response received on behalf of the Brechfa Forest Tourism Cluster Group. EN-1 quote is not correct. Section 5.10 of EN-1 refers to Land Use including open space, green infrastructure and Green Belt. It does not refer specifically to open Concerns over a lack of research into tourism and proposed mitigation. access land and states only that the applicant should consider providing new or Failed to apply formulae relating to tourism stated in ES. Concerned that EN1 additional open space. It goes on to further give guidance for exchange land. specifically states that if a development is on open access land then exchange Given that restrictions to open access are temporary only, it is not considered that land has to be provided. This application does not include any information exchange land is necessary. on the exchange land to be provided. Concerns over noise and compliance with ETSU-R-97. Concerns that the design of the wind farm does not comply Information has been provided on previous research into tourism and wind farms. with guidelines for both the general public and employees of the wind farm It is not expected that further research would alter the impact assessment already company. Concerns over the community consultation specifically that Brechfa undertaken on the wind farm. Forest tourism cluster group have not been approached. The noise chapter of the ES demonstrates that the proposed wind farm will comply with ETSU-R-97.

RWE NRL were not aware of the existence of the Brechfa Forest Tourism Cluster group until the end of consultation. BFW/IPC/S47/080 A short letter received from one of the nearest properties to the proposed RWE NRL will engage with the property owner about the provision of tree wind farm. It states concerns about visual and audio intrusion and requests a screening. tree screen as mitigation. It states that the private water supply survey has not The draft ES did identify the water supply for the property in question and identified the properties’ water supply. concluded that there would be no impacts. Brechfa Forest West Wind Farm Consultation Report 148

BFW/IPC/S47/084 Letter received from RSPB. Further work has been done on the Habitat Management Plan (HMP) since the Explanation given that while the ES acknowledges that the development will consultation period. Further mitigation has been proposed and more information impact on the nationally important population of nightjar (Annex 1 species provided on nightjar both within the ES ornithology chapter and in the HMP. – Bird Directive) - no compensation is proposed. In addition, the mitigation offered is limited. The HMP (with the exception of 187ha of PAWS restoration), is a mitigation document and does not address the significant opportunities for large scale habitat enhancement / restoration of open areas, heathland, etc.

BFW/IPC/S47/085 A comments form and additional information received from the Brechfa Forest Further information has been provided about the site access within the ES. Energy Action Group. The additional information offers comments on the draft A peat survey has been conducted since the consultation, the results of which are Environmental Statement. included within the revised ES. The consultation process and community engagement are criticised. No meeting has taken place between RWE and the Graziers Association so it is It is stated that more information should be provided about the site access. assumed that this refers to a different site. It is considered that flood risks and water pollution are inadequately covered RWE NRL have investigated in some detail the possibility of utilising the existing in the draft ES and the response states that ‘there may well be more peat on access for the Alltwalis Wind Farm. Unfortunately it has not been possible to the site than RWE expect’. The letter refers to a RWE exhibition for the Graziers reach a commercial agreement with the landowner. In order to mitigate the Association and that the hydrologist present did not appear to have walked issues raised by a range of groups and individuals who have responded to the the site. consultation, screening is proposed to mitigate landscape and ecological impacts The letter considers that analysis of impacts on access, traffic and associated with the new access track. Further information about the proposed transportation is insufficient and queries why it is necessary to create a new access track as well as the consideration of alternatives that took place is access track when the Alltwalis road is already in situ. provided in the revised ES. Regarding infrastructure, the letter states that the new initiative to connect The two transmitters being utilised for the not-spot project (Carmarthenshire “Not-Spots” on the mountain wirelessly from Swansea has not been considered Community Broadband Partnership)- Garn Big at Carmel and Crychan at in the ES. Cynghordy are very remote from the site. The system will use several small radio The letter states that the draft ES is dismissive and poorly researched on the aerials strategically placed throughout the community, typically one for each 20 impact on access, recreational usage and the economy of the area. properties. A small receiver (box) is mounted on the outside of each property It states that sections of the non-avian ecology chapter are poorly thought which receives the Wi-Fi signal. It is considered unlikely that the wind farm would through and superficial. Regarding ornithology, it states that impacts on impact on the broadband signal and the system’s use of a number of locally various breeds of birds have been minimised. It suggests that increased flood situated aerials should provide in-built mitigation for any interference. risk could impact on nesting sites. Further information has been added to the ES regarding access and recreational Regarding landscape and visual impacts, it states that the montages are usage, including further detail on mitigation and gain. ‘masterful in their minimisation’ and misleading. It states that a montage from Some further changes have been made to the two ecology chapters of the Gwyddgrug was missing. ES however in general terms, RWE NRL’s specialist consultants stand by their On the subject of noise, the letter raises questions about methodology and assessments. equipment used to conduct the noise survey and requests information about The landscape and visual section has been reviewed following consultation. The frequency bands. It highlights the experience of residents affected by noise montage from Gwyddgrug that was identified as being missing was in the ES, from the existing turbines at Alltwalis. although incorrectly labelled. This error has been corrected. Information about the methodology and equipment used to conduct the noise survey is contained within the ES. Brechfa Forest West Wind Farm Consultation Report 149

BFW/IPC/S47/086 A comments form and additional information was received from the No action- the concerns raised are very general and difficult to respond to Llanfihangel Rhos-y-Corn/ Brechfa Community Association. The appended specifically. The potential effects identified have been addressed appropriately information outlines the concerns of local residents. within the ES. Firstly, it is stated that the consultation process was confusing with different exhibitions and leaflets. Secondly, concerns are raised about the quality of residents’ lives being affected, by visual impact, construction, access, grid connections, noise including infrasound, rivers, wildlife etc. They are also highly concerned about the impact on the local economy, guest houses, hotels, letting accommodation as the development will affect the enjoyment of landscape that most visitors come for. They feel that such matters have not been closely taken account of or researched in the draft ES. BFW/IPC/S47/087 Letter from Candidate for Carmarthen East and Dinefwr. Whilst RWE NRL have considerable concern for Mr and Mrs Harris and the impacts Details meeting with Bethan Thomas (RWE NRL) and Dr Wayne Cranstone (RWE that they have identified they are currently experiencing from the Alltwalis NRL) with regard to Mr and Mr James (sic) (Mr and Ms Harris), Gellifelen which Wind Farm, however the request to purchase their farm is not considered to be discusses the visual impact of the Statkraft Wind Farm since it was developed. reasonable. Further statement is made that Mr and Mrs James (sic) would be surrounded by wind turbines and the access road would be directly in front of them should RWE NRL have made efforts to assess fully all aspects of the potential impacts Brechfa Forest West Wind Farm get consented. Comment is made that their on Mr and Mrs Harris’ property resulting from the proposed Brechfa Forest home would be “blighted” and it would be impossible for them to continue West Wind Farm. Whilst it has not been possible to reach agreement with the to live there. Request is made for discussions with Statkraft regarding the landowners of the Alltwalis Wind Farm access track, we have proposed mitigation possibility of buying the farm and thus allow Mr and Mrs Harris to get on with to screen the new access track in the direction of Mr and Mrs Harris’ property to their lives in peace. reduce the potential visual impact from their property.

With regard to noise, specific additional work has been undertaken by RWE NRL’s specialist consultants looking into the noise impacts at Gellifelen. These have been presented to Carmarthenshire County Council. Compliance with ETSU-R-97 is still predicted. Brechfa Forest West Wind Farm Consultation Report 150

BFW/IPC/S47/092 This respondent included a comments form and supporting information. It is Four main points are raised in this response: stated that the property has a private water supply (PWS) and queries work 1. No clear justification is provided for the objection to the specific named done to date. It is stated that turbines 17, 18 & 23 are too close and should turbines- the noise assessment conducted (and supplemented following be removed. The respondent also states that the proposed access track consultation) concludes that there should be no significant adverse noise effects would be a blight on the property. Queries are raised in the accompanying associated with the Brechfa Forest West Wind Farm. letter regarding apparent work that has been taking place on the proposed 2.Noise- the property in question has been the particular focus of work access track. It is highlighted that noise problems from Alltwalis Wind Farm undertaken by RWE NRL’s specialist noise consultants. As the Alltwalis Wind Farm are ongoing and that problems need to be rectified prior to any further is operated by another company, RWE NRL have no control over the noise emitted applications. Further supporting information is provided on this issue. The from the wind farm and is unable to comment on the nature of the noise effects. respondent states that they would require a legal binding contract to protect However, efforts have been made to ensure that the Brechfa Forest West Wind their house from further noise problems and devaluation of property. Farm does not have a significant adverse impact on residences in general, and this property in particular. 3. Access track- RWE NRL have investigated in some detail the possibility of utilising the existing access for the Alltwalis Wind Farm. Unfortunately it has not been possible to reach a commercial agreement with the landowner. In order to mitigate the issues raised by this resident, screening is proposed to mitigate landscape and ecological impacts associated with the new access track. 4. Private Water Supply- RWE NRL has committed to undertaking a full survey of PWS’s prior to construction commencing. In the case of PWS’s that could be affected, the residents will be contacted to explain the potential issues. Actions to be implemented in the event that the supply was affected would be discussed with the residents. BFW/IPC/S47/098 Letter from Gwirfoddolwyr Abergorlech Llansawel A Rhydcymerau The interests of this group are noted. Details that Galar is a group of volunteers formed to make known the feelings of our community with respect to the industrialisation of rural landscape, the attack on biodiversity and the change in nature of rural surroundings. Galar also seek to promote tourism associated with outdoor pursuits, sport and cooperate in the development of the area for the amenity and leisure of people in Carmarthen. Details are provided should further information be required with regard to the group. Brechfa Forest West Wind Farm Consultation Report 151

4. section 48

Section 48 Duty to publicise

(1) The applicant must publicise the proposed application in the prescribed manner.

(2) regulations made for the purposes of subsection (1) must, in particular, make provision for publicity under subsection (1) to include a deadline for receipt by the applicant of responses to the publicity.

4.1 In accordance with section 48 of the planning act 2008, rwe nrl provided notices informing people of the proposed application for development consent. These notices were published in the carmarthen journal on february 9th, february 16th and on march 2nd 2011 (the march 2nd notice provided information on the additional exhibition in alltwalis). Notices were also placed in the guardian and the london gazette on wednesday 9th february 2011.

4.2 The Section 48 notice was published bilingually in the Carmarthen Journal and in English in the Guardian and London Gazette.

4.3 The notice contained nine sections: 1. Gave notice of RWE npower renewables’ intention to make an application for development consent for the Brechfa Forest West Wind Farm 2. Provided summary information about the size and location of the proposal, including a explanation of why the application for development consent is required to be made to the IPC 3. Detailed the components of the proposed development 4. Advised that the proposed application is EIA development 5. Explained that the preliminary environmental information is available for download from the RWE npower renewables Brechfa Forest West Wind Farm project website 6. Set out where the documents were available for viewing free of charge during the consultation period 7. Set out the dates, locations and times of the public exhibitions 8. Explained that copies of the preliminary environmental information could be obtained from RWE npower renewables 9. Provided advice on the methods of responding to the consultation

4.4 No feedback was received specifically in response to the Section 48 notice although 15% of the respondents who filled in feedback forms stated that they learned about the consultation exercise via the press notice.

4.5 Copies of these notices form Application Document 14 accompanying this application (BFW/AppDoc14/S48) and the text of the notice is provided at Appendix N. Brechfa Forest West Wind Farm Consultation Report 152

5. section 49 the relevant response

Section 49 Duty to take account of responses to consultation and publicity

(1) Subsection (2) applies where the applicant- (a) has complied with sections 42, 47 and 48, and (b) proposes to go ahead with making an the application for an order granting development consent (whether or not in the same terms as the proposed application)

(2) the applicant must, when deciding whether the application that the applicant is actually to make should be in the same terms as the proposed application, have regard to any relevant responses.

(3) in subsection (2) ‘relevant response’ means – (a) a response from a person consulted under section 42 that is received by the applicant before the deadline imposed by section 45 in that person’s case; (b) a response to consultation under section 47 (7) that is received by the applicant before any applicable deadline imposed in accordance with the statement prepared under section 47, or (c) a response to publicity under section 48 that is received by the applicant before the deadline imposed in accordance with section 48(2) in relation to that publicity.

5.1 The relevant responses for both section 42 and section 47 are summarised in this report along with RWE NRL’s response to the comments made with respect to the Preliminary Environmental Information released on the project. Brechfa Forest West Wind Farm Consultation Report 153

list of changes made to the application

5.2 A list of changes made to the application for the Brechfa Forest West Wind Farm following consultation on the Preliminary Environmental Information is shown below:

– A Public Access Management Plan (PAMP) was produced, including detailed plans for minimising impacts. The PAMP also incorporates additional mitigation and gain that was not previously proposed. – A more detailed habitat management plan has been produced. – A more specific commitment to Plantation on Ancient Woodland Site restoration. – Commitment to eradication of Japanese Knotweed within the development area. – A peat survey has been undertaken to confirm the conclusions of the desk based work. – Production of stand alone report on health issues. – Design and access statement has been produced. – Inclusion of information about access alternatives. – “Dry run” transport assessment has been completed. – Re-alignment of access track to avoid impacts on private water supplies. – Additional information, including more detailed design work, has been provided on main site entrance. – Additional Sustainable Drainage Systems work- outline designs. – Incorporation of additional ecological data provided by CCW. – Screening mitigation for access track (for L&V and ecological benefit) is now proposed by RWE NRL. – Residential Amenity Study has been completed for properties near to the access track. – Confirmation that the borrow pit area will be kept clear of trees. – Where not already included, the addition of cumulative impact assessment with Bryn Llywelyn Wind Farm. – Commitment to compensatory replanting to ensure no net loss of trees due to the wind farm. – Commitment that no turbine will be micro-sited to an attitude higher than the maximum for any turbine (i.e. 494mAOD) assessed in the ES. – Noise – reduced limits for some properties for extra reassurance for the landowner. – Provision of partial limits for cumulative noise. Brechfa Forest West Wind Farm Consultation Report 154

6. conclusions

6.1 In this report, RWE NRL has demonstrated compliance with the relevant sections of the Planning Act 2008, including its advice and guidance notes. RWE NRL has also undertaken consultation in line with the feedback provided by Carmarthenshire County Council.

6.2 RWE NRL has demonstrated, in detail, that comments received have been considered and taken into account where this has been possible. This Consultation Report sets out why changes have not been made (where changes have not been possible) or where changes were not considered appropriate.

6.3 Practically, given the number and size of the “in full” consultation responses, summarised responses have been provided within this document. A full set of consultation responses has been provided to Carmarthenshire County Council and can be provided upon request. Brechfa Forest West Wind Farm Consultation Report 155

7. glossary

Glossary

AA Appropriate Assessment AMP Access Management Plan AIL Abnormal Indivisible Loads AOD Above Ordnance Datum ATC Automatic Traffic Counters BAP Biodiversity Action Plan BBNP Brecon Beacons National Park BFW Brechfa Forest West BGS British Geological Society BHS British Horse Society BOAT Bridleway Open to All Traffic CCC Carmarthenshire Country Council CCW Countryside Council for Wales CEMP Construction Environmental Management Plan CIRIA Construction Industry Research & Information Association CLG Community Liaison Group CLVIA Cumulative Landscape And Visual Impact CMS Construction Method Statement

CO2 Carbon Dioxide CuMS Countryside Management System DAS Design and Access Statement DCO Development Consent Order DECC Department of Energy & Climate Change DMRB Design Manual for Roads and Bridges DNO Distribution Network Operator DPPA Dyfed-Powys Police Authority DPTAC Disabled Persons Transport Advisory Committee DTM Digital Terrain Model EAW Environment Agency Wales EIA Environmental Impact Assessment EPS European Protected Species ES Environmental Statement FCW Forestry Commission Wales FEH Something to do with rain FTE Full Time Equivalents GCR Geological Conservation Review GIS Geographical Information System GQA General Quality Assessment HCoW Hydrological Clerk of Works HGV Heavy Goods Vehicle HMP Habitat Management Plan HPA Health Protection Agency HRA Habitat Regulations Assessment ICNIRP International Commission Non-Ionising Radiation Protection IEMA Institute Environmental Management & Assessment IPC Infrastructure Planning Commission IPCC Intergovernmental Panel on Climate Change IROPI Imperative Reasons Of Overriding Public Interest Brechfa Forest West Wind Farm Consultation Report 156

LCA Landscape Character Area LCC Llanllawddog Community Council LFN Low Frequency Noise LHB Hywel Dda Local Health Board LPA Local Planning Authority LUC Land Use Consultants LVIA Landscape & Visual Impact Assessment MW Mega Watts MWTRA Mid Wales Trunk Road Agency NERC Natural Environment Rural Communities NSIP Nationally Significant Infrastructure Project NPS National Policy Statement NTS Non-Technical Summary OFGEM Office of the Gas and Electricity Markets OFWAT The Water Services Regulation Authority ORPA Other Routes with Public Access PAMP Public Access Management Plan PAWS Plantation on Ancient Woodland sites PDA Potential Development Area PIA Personal Injury Accidents PPG Pollution Prevention guidance PPM Pollution Prevention Measures PRoW Public Right-of-Way PWS Private Water Supplies RIGS Regionally Important Geological Sites ROWIP Right of Way Improvement Plan RS Restoration Statement RWE NRL RWE npower renewables SAC Special Area of Conservation SNH Scottish Natural Heritage SOCC Statement of Community Consultation SSA Strategic Search Area SSSI Site of Special Scientific Interest STEAM Scarborough Tourism Economic Activity Monitor SUDS Sustainable Drainage Systems SWEBREC South East Wales Biodiversity Records Centre SWTRA South Wales Trunk Road Agency TAN8 Technical Advice Note 8 (2005) TEMPRO Something to do with traffic TLSE Test Of Likely Significant Effects TMP Transport Management Plan UDP Unitary Development Plan WAG Welsh Assembly Government WCA Wildlife & Countryside Act 1981 WFD Water Framework Directive WMP Water Management Plan WPD Western Power Distribution WWBIC West Wales Biodiversity Information Centre ZTVs Zone Thereotical Visual Impact Brechfa Forest West Wind Farm Consultation Report 157

appendices appendix a

Summary of Comments from Feedback Forms Archaeology – A bronze age axe head found (Rhoswen) locally. Now in the museum. Many of the names (e.g. Tre Beddau) are evidence of the archaeological importance of the whole area. – Archaeological evidence should not be disturbed. Care should be given to the listerian way. – I think this is very important and I don’t’ see how some damage can be avoided. – Not respected – The existing planting hides many sites – It is important that no archaeological remains are damaged. – Very historical area - archaeological remains not been taken into account. – Adjacent to Llanllwni mountain steeped in history - too close to ancient monuments. – Desecrating our heritage is not a good way to ensure public support. – Full study to ensure any archaeology is not destroyed. – the draft ES appears to ignore some important features that are currently covered by forest growth. – There are some sites of antiquity within the proposed construction area. No mention has been made of these. The old ‘gold mine’ is also of interest to local people. Part of Brechfa’s history would be affected. – Legal issues - The proposed development appears to contravene the 1967 Forestry Act and its later amendments. Chapter 39, Section 8A of the 1981 Forestry Act states “In performing their functions under this Act the Minsters shall have regard to the national interest in maintaining and expanding the forestry resources of Great Britain” Since 2001, the area of land under forest cover has fallen - partly due to wind farm development on forestry land - so the relevant minsters have failed, and are continuing to fail the nation in their collective legal obligations. This proposed development will only add to the amount of deforestation on land managed by the Forestry Commission. – Archaeological sites should not be disturbed for the financial benefits of wind farm developers

Combating Climate Change – Enormous pollution created in manufacture, transportation, installation and dismantling, so…

– they will produce more CO2 in production than ever recouped in use. Useless – Wind power too unpredictable to be relied on – The claim that climate trends will be changed by this wind farm does not stand up to scrutiny. – No details given of carbon footprint of development or how it was assessed and how long it will take to offset. Impossible to state either positive or negative effects on climate change – Will not combat climate change. More fossil intermittency & unreliability of wind farms. Please provide us with report & figures of the anticipated release of carbon emissions during the production of concrete, emissions from HGVs, machinery & component transportation etc. – There is very little evidence of this at present & this development, also, will have a minimal impact. So there is no mention of the release of carbon. The need for back up from conventional power stations. Brechfa Forest West Wind Farm Consultation Report 158

appendix a (cont…)

– A more holistic approach would be beneficial. You should encourage the use of your resources for wider energy creation e.g. together with your landlord the FC/Welsh Assembly, you should consider the construction of a local wood burning plant to use forest waste, top and top such a plant would reduce to impact of transporting to a distant plant & provide local jobs. – This is vital but this large scale industrial approach is the wrong way. – I’m sure tidal energy would be the best way with less impact on visual + noise from people lives. – Most well informed people know that wind power is of little value in combating climate change – Could we be given a report on the amount of electricity which was actually generated in the first year of full production. – This project has little to do with ‘climate change’. Its is all about making large profits from. Subsidies provided out of hidden levies in electricity bills. – Keep the trees as a carbon sink - they also produce oxygen. – Wind turbines are ineffective - they are fickle and unreliable. – We should be adapting to climate change, not combating it. – Do not believe it will make a lot of difference against the damage it will cause and release of carbon etc. – our group has produced a report on the impact we feel this installation will have, we would prefer to submit it to the IPC, at the appropriate time, if RWE npower renewables would like to see a copy, please apply to GALAR Technical Officer see details at end of this questionnaire. – Wind turbines in this country are far too inefficient to have any impact on climate change. As shown by many recent studies, to provide 1/6 of UK’s energy needs, the whole of Wales would need to be covered in turbines. Set against construction, use of concrete, access roads, distance travelled by turbines + parts, no net gain - probably the reverse. – We should be driving forward individual self sufficiency with solar panels power on each + every home, thereby vastly reducing the need for large scale power generation. – Wind farms us vs. efficient systems i.e. PuP’s – Useless technology - intermittency means that standard power stations will have to kept/built to keep a spinning reserve. – Data from Denmark proves that wind farms do not contribute to combating climate change. There is no mention of the Read Report http://www.forestry.gov.uk/website/ forestry.nsf/byunigue/infd-7y4gn9 This independent report - “Combating Climate Change - A Role For UK Forests” - launched in Nov 2009, was commissioned by the Forestry Commission to examine the potential of the UK’s woodlands to mitigate and adapt to our changing climate - it forms part of the UK response to the Intergovernmental Panel on Climate Change (IPCC) 4th Assessment Report published in 2007. The key recommendations in the report are: - Plant more woodlands - Manage our country’s woodlands wisely - Plan strategically long term to increase area of forestry land - Harvest wood for fuel and use more wood products - Use trees to play an important role in helping people adapt to climate change – The forestry commission’s strategy for Wales of managing the forests for carbon capture and as a tourist attraction, with minimal impact on the soil would be far better for the climate and community and economy than building wind farms. – Do not believe in climate change. Brechfa Forest West Wind Farm Consultation Report 159

appendix a (cont…)

– I have asked for and not received from Npower the carbon inputs of the scheme so that an intelligent assessment of the payback can be made against the embedded carbon loss from construction – The efficacy of on shore wind farms as an effective tool against climate change is no doubt. Hydro turbines, especially the newest generation of small scale turbines, are 1.5 times more efficient than the equivalent size wind turbine, are proven to be plant and wildlife friendly and have less of an impact on the environment, habitats, visual amenity and property values. – Data from Denmark proves that wind farms do not contribute to combating climate change. There is no mention of the Read Report. http://www.forestry.gov.uk/website/forestry.nsf/byunique/infd-7y4gn9 This independent report - “Combating Climate Change - A Role For UK Forests” - launched in Nov 2009, was commissioned by the Forestry Commission to examine the potential of the UK’s woodlands to mitigate and adapt to our changing climate - it forms part of the UK response to the Intergovernmental Panel on Climate Change (IPCC) 4th Assessment Report published in 2007. The key recommendations in the report are: – Plant more woodlands – Manage our country’s woodlands wisely – Plan strategically long term to increase area of forestry land – Harvest wood for fuel and use more wood products. – Use trees to play an important role in helping people adapt to climate change.

Jobs – a very transitory creation of a few new jobs – 90% of jobs will be given to people from away – How many jobs will it bring to the area and how long for? – It is claimed that 4 or 5 permanent jobs will be created. Where will these be located? – The inevitable adverse effect on tourism, will lead to more job losses than gains – Where will these jobs be raised? 150 jobs are mentioned, how many of these will be for local people? During the operational period 4-5 jobs maintenance work, will these be specialist jobs? – Temporary jobs during construction phase for local people/contractors? (not the case then Alltwallis wind farm was constructed). Very few but specialised maintenance jobs in the long term - for locals? – I do not think that any local companies will benefit from construction of site, are turbines built in UK? – Many more jobs would be created by small scale energy generation. – Jobs will be created by tidal and biomass energy. – A managed forestry would provide a lot more jobs. – As in the case of the Alltwallis development, most of the jobs created will require specialist skills and will go to people from outside the area. – Apparently wind farms are managed by a minimum of staff - no local jobs created or at least only single figures. – It is a myth that on balance there will be a creation of jobs - while short term there will be additional jobs during construction the overall development will result on less employment by removing land which is currently grazed on farmed. – Destruction of tourism loss of local jobs Brechfa Forest West Wind Farm Consultation Report 160

appendix a (cont…)

– Unlikely any permanent jobs created - specialist construction staff are brought in from outside the area - no permanent jobs created by the Blaen Bowi, , Cefn Croes, Allwallis or Ffynnon Oer developments so this development is highly unlikely to provide jobs for any local residents. – Securing the existing jobs in the tourism and equestrian industry. Carmarthenshire County Council have been doing an excellent job in regeneration in the area based on the attractive landscape. RWE Npower have failed to carry out a full evaluation of the economic importance of the forest, and have failed to apply the formulas identified in the research listed in the planning applications to come up with an accurate result on impact this planning application would have on the local community both socially and economically.

Effects on the Forest – Recreational use - walking, cycling in forest must be restricted, depreciated. – Wildlife forced out of forest as there are not trees for shelter – loss of trees - therefore loss of wildlife and rare flowers – potentially ruined permanently – The claim that no peat would be affected is disputed (see prof pearsall) The destruction of rare habitats, and the peace and tranquillity which should reign in the forest, will be detrimental inhabitants of the locality. How will this be mitigated/compensated. What about the increased likelihood of ‘wind-blow’ – The beauty, tranquillity and continuity of the forest will be destroyed. No entomological survey has been undertaken, which along with the destruction of habitats raises a serious threat to sensitive eco-systems and bio-diversity. – Loss of carbon absorbing trees; will have impact on stability of trees, during the operational period: loss of habitat for more birds & mammals. – Besides the obvious felling of trees, the creation of tracks, crane pads. Turbine bases etc will damage or destroy fragile & scarce habitats with the extra hazards of noise disturbance & pollution affecting the wildlife population. – There has to be effects on wildlife. – Loss of carbon absorbing trees. – There is insufficient justification for imposing massive industrial plant on a valued natural landscape. – I would like access to the forestry land to be maintained including during installation. – All the necessary tree felling and excavation/spoil spreading will devastate large areas. – The impact on the forest needs to be lessened, by constructing fewer turbines – The large number of turbines with all the other developments will turn the forest into an industrial landscape and will have a very detrimental affect on the wildlife especially birds. – Pine marten have been seen trees - not turbines. – Keyhole clearing will decimate most of it.

– Trees absorb CO2 and are a habitat for rare animals and birds. – Destruction of forest - replacement with a wind factory not acceptable. – Devastating effect on forest, esp. soil erosion - felling seems to be outside of management plan esp. permanent felling. – Will devastate parts of the forest - I know its ‘managed’ but this is permanent felling and not only of mature trees! Selling off England’s forests and industrialising Welsh ones! – Far too many trees will have to be felled. Danger of fire from turbines. Forestry Commission ……….publicly owned and should not be used for this purpose. Brechfa Forest West Wind Farm Consultation Report 161

appendix a (cont…)

– our Welsh forests are vastly important to our economy - to both the forestry commission & to the recreation/leisure industry. Now the forestry commission has embarked on a planting programme to replace with indigenous fees, the forests add to the natural beauty of the landscape. – Devastation - I counted over twenty types of fungi in the forest last autumn. The flora and fauna of the area will be lost. – Devastating for the forest, the wildlife and for local people According to the Forestry Commission’s web page http://www.forestry.gov.uk/forestry/infd-7m8ml6 deforestation for change of land use accounts for almost 20 per cent of global carbon dioxide (CO2) emissions. The proposed wind farm development will reduce the area of land available for reforestation and perhaps contribute to this appalling statistic. Over 360 acres (146 ha) of land will be deforested to facilitate construction of the proposed wind farm. 49.5 ha (122acres) will remain deforested for the duration of the wind farm. 2) Risk of spreading Phythophera ramorum to the Brechfa Forest area. P ramorum is a quarantine organism under European Union Law - it is a fungal-like pathogen that kills many of the trees it infects, including Japanese larc, rhododendron, and other tree species). As a forest owner myself, I am concerned about spreading this disease to the Brechfa Forest area. Further information on this disease can be found on the forestry Commissions website www.forestry.gov.uk/pramorum – The wind farm will create both visual and noise pollution in the forest. – The forest is not ancient forest. Its is managed, fast growth and almost entirely commercial. Whilst this does not, arguably, make for a habitat to be protected, there is, nonetheless, evidence that the forest and surroundings area are increasingly important to avian species, some of which are rare. To dismiss the impact on these species as negligible is fallacious – 1) Devastating for the forest, the wildlife and for local people According to the Forestry Commission’s web page http://www.forestry.gov.uk/forestry/infd-7m8ml6 deforestation for change of land use accounts for almost 20 per cent of global carbon

dioxide (CO2) emissions. The proposed wind farm development will reduce the area of land available for reforestation and perhaps contribute to this appalling statistic. Over 360 acres (146 ha) of land will be deforested to facilitate construction of the proposed wind farm. 49.5 ha (122 acres) will remain deforested for the duration of the wind farm. 2) Risk of spreading Phythophera ramorum to the Brechfa Forest area. P ramorum is a quarantine organism under European Union law – it is a fungal-like pathogen that kills many of the trees it infects, including Japanese larch, rhododendron, and other tree species). As a forest owner myself, I am concerned about spreading this disease to the Brechfa Forest area. Further information on this disease can be found on the forestry Commission’s website: www.forestry.gov.uk/pramorum – Welsh Assembly will fell forest anyway.

Water Supplies – Increase run off will have an effect on rivers with possibility of flooding downstream - local villages at risk. – Possible flooding. – Concerned about effects on pollution of neighbours water supply during construction and also contamination of watercourses from concrete perishing. – Planned access road very close to our farm water supply (well) – Danger of pollutants entering water supplies during construction concrete perishes\ deteriorates and chemicals will leech into water supplies. Brechfa Forest West Wind Farm Consultation Report 162

appendix a (cont…)

– We would prefer the environment Agency to produce a SuDs report, as per TAN15 on which we would like to be consulted. This is regarding Hydrology and impact on run off. We have no concerns with regard to drinking water. – Far too little study of hydrology effects - not only water supply but effect on flooding in the area. Concrete will remain in ground after decommissioning. – our spring water comes from the forestry we are dependant on it for the last four generations. – We have our own water supply, although are not included on the list of residents under the private water supply section of the environmental statement. What investigations have been made to date? We would need a legal binding agreement that if we lost our water supply this would be rectified at no cost to us. – There can be no way the effects of the development proposed will leave the water supply unaffected. The water courses will be diverted & the potential flooding & cutting off of many individual dwellings is very heal. – I do not believe you are capable of knowing how much damage you will cause until too late. – Unknown but surely such massive construction will feed contaminated water into the Cothi. – Not even experts know how the this proposed development would affect water supplies. Therefore if should not be allowed to go ahead. – As our well which feeds the whole farm is less than 400 metres from the forest, I am deeply concerned about the disturbance of the water table. – I am very concerned by the risk of major flood events downstream from the significant civil engineering works – The proposed development lies in an area of high rainfall. The local area already suffers from significant rain run off problems. The wind farm will remove some 64 hectares of land from the locality for 25 years plus. Existing drainage measures do not cope. Whilst the company promises mitigation, how is this proposed to be maintained by the 4 or 5 permanent staff, over 25 years + life of the wind farm? – Effect on homes with private water “bore holes”

Energy Security – Do they produce anymore than they use in installation. – will never produce enough consistent supply of energy to be a security – The vast expenditure and destruction for the minimal end result in energy terms is not viable in real terms. – Wind is variable and unpredictable. Wind turbines are inefficient (23% capacity 2010) with considerable transmission losses. They can never secure energy supplies. – Wind energy is unpredictable, unreliable & insufficient. The industry is fully dependant on huge subsides paid for in our electricity bills. – Can never be relied upon as was demonstrated last winter when output from wind farms nationwide was minimal. – So that cities can leave the lights on and neither know nor care that wind farms exist. – Wind power intermittent and requires solid fuel or nuclear back up. Turbines were almost non-productive completely over Christmas/new year 2010. – Wind turbines unlikely to help. Micro generation better. Hydro obvious choice for Wales. – Building hydro power generation using the water sources in the forest would provide Brechfa Forest West Wind Farm Consultation Report 163

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much more security of energy supply than a wind farm and wouldn’t be harmful to the community in the same manner as a wind farm would be. If the security of energy supply then we all know that we will not get that from wind farms. We see how often the turbines adjacent to Brechfa Forest are not turning. – In the light of recent data showing that wind turbines are significantly undershooting production targets, I am very concerned that the nation becomes even more reliant on such technology. I am a passionate believer in micro generation as being a more rational way to go particularly in rural areas. I have had personal battles with Npower in trying to get full payments under the FIT scheme for micro generation, which has resulted in me switching supplier, since the company was completely intransigent on my complaint – onshore wind farms are inefficient and unreliable. The existing wind farm at Alltwallis comprises 10 turbines. Of these, most days only 9 are turning and those very, very slowly. One is turned off overnight due to excessive noise that it generates. During the long, cold snap of winter, none of the turbines turned at all. Alltwallis therefore is a staggering 21.4% efficient. Biomass, ground/air source heat pumps and hydro are better.

Distance from Homes – The 7500m distance is not so far adhered to when ‘as the crow flies’ is measured. – they are too close to the homes in Gwyddgrug. Noise is a great problem. – 17,18,23 need to be moved back more in to the forest – move them back from peoples homes – 17,18, 23 should be kept back more into the forest and not in peoples faces. – Too near homes consider the noise peoples are experiencing with existing wind farm. – they should not interfere with residential areas by being built too close – The need to move turbines away from people’s home – Need to consider residents who live near the turbines. Can you move them back further? – Peripheral turbines too close to the houses – No turbine should be less than 2km from the nearest dwelling – International medical research advises a minimum buffer zone of 2 kames. – The layout of this development is too near homes. From our experiences during the construction & operational periods of the Alltwallis wind farm a 2kl buffer area is inadequate to protect homes from noise nuisance & visual impacts and shadow flicker & glare. Turbines 17,18 + 23 should not be included. – Scotland & other EU countries require turbines to be at least 2000km from habitations. This site will have homes within 1000m (nearest being 817m) No 17 & 23 are far to close to homes and Gwyddgrug village. – I have tenants living at Foel Farm complaining about the noise of No 17 18 + 23 turbines will be closer to my farm than them. I have heard them turbines need to be moved or not built at all. – Buffer zones of at least 2km. Noise considerations must also address the fact that tolerance to noise varies from person to person - the human element is ignored and we are left with some nebulous “within limits” – Turbines 17, 18, 23 to be withdrawn or sited no less than 900m further into the forest – This scheme is far too near to residential communities. – As far as possible from homes. – 1.5km distance from homes is now consulted at CCC. No 17, 18 + 23 should be reviewed to go further back from the village. Brechfa Forest West Wind Farm Consultation Report 164

appendix a (cont…)

– Proposed 1.5km distant from homes as being consulted in May by Carmarthenshire County Council. No17, 18 + 23 turbine should be relocated further back into the forest. For 16 months we are experiencing high level of noise from the existing Alltwallis Farm turbines. – No home should be disturbed by visible or audible change from the present. Minimum distance should be 2000 metres. – 10km minimum including farms and all animals. – Affect on homes from noise of the turbines has to be a priority to get right. – There are already 10 wind turbines within area and next to my farm. Should you build more I feel my farm will be strangled. – Health persons, effect on house price. – The existing distances are far enough. Never hear the existing ones or any other problems. – Should be a minimum 2000m separation to prevent noise disturbance. Ask the people who live near the Alltwallis wind farm. – I feel no turbines should be constructed within 2 miles of homes. – I believe no turbine should be built with in 3km of houses due to health issues. – Put them in Antartica. – Noise + visual impact should be considered both for residents + paying visitor accommodation. – 800m is not far enough from homes. From the experience of the Alltwallis development, a number of people in Gwyddgrug suffer noise nuisance from the wind turbines. – Important turbines should not be near than 1.5km to any homes. – Whole development too close to residential properties but especially turbines 7,18,23 - far too close. – The minimum distance at present is insufficient. – We are satisfied with the 1500 metres required by Carmarthenshire County Council. – Should be at least new studies show the impact on the 2km health of those living close to turbines - low vibration + noise. – Unsightly in lovely village setting far too close to people’s homes in Gwyddgrug village. – Need to maximise the distance away from peoples homes. Turbines are very close here already to homes causing noise problems. – We have 10 turbines within 800 metres from our house, they should be sited further away. – Turbines 17/18/23 are too close we ask you to remove them from the proposal plan (further information enclosed on this) – Turbines 11,18&23 need to be moved back as they are too close to my home & the village of Gwyddgrug. – There is now a growing body of evidence to support the contention that people living close to turbines suffer much increased medical problems. Turbines should be sited a min of 10 miles from any habitable dwelling. – 3km of compensating for noise. – Rather irrelevant when the pylons are so large. I can already see ten from my house. – No distance is far enough since low frequency noise produced by wind farms appears to be able to travel very many miles. Ever since a wind farm as commissioned in Autumn 2006. I started hearing low frequency (LFN). I even had LFN recorded at home by an environmental health officer, and I am in a very quiet rural location. I live 25 miles away Brechfa Forest West Wind Farm Consultation Report 165

appendix a (cont…)

as the crow files from the suspect wind farm, but I don’t have the equipment or the resources to carry out or commission a study myself. Wind farm developers and government scientists insist that LFN is not a problem associated with wind farms, yet they are all unwilling to conduct studies on the subject..... Why not? – Wind farms should be built out to sea, not near peoples homes and particularly not on a tourist attraction. – The positioning of turbines 7/8 and 23 just proves that RWE have no more thought for the local residents than the existing wind farm company. They should be removed Gwyddgrug residents have suffered enough. – The WHO apparently recommends a 3 km buffer zone. I do not see why local residents should potentially suffer ill effects by placing turbines close to homes than this – Turbines 17, 23, 18 are too close to the local population centres of Gwyddgrug and New Inn. Turbines 13, 19 and 24 are borderline. Turbines 1, 2, 3 & 4 are too close to Alltwallis. Of these turbines 1, 3, 17, 18 and 23 should be taken out altogether. Turbines 13, 19, 24, 2 and 4 should be moved back. This will give a 2 mile/3km separation from main housing centres. – No distance is far enough since low frequency noise produced by wind farms appears to be able to travel very many miles. Ever since a wind farm was commissioned in Autumn 2006. I started hearing low frequency noise (LFN). I even had LFN recorded at home by an environmental health officer, and I am in a very quiet rural location. I live 25 miles away as the crow flies from the suspect wind farm, but I don’t have the equipment or the resources to carry out or commission a study myself. Wind farm developers and government scientists insist that LFN is not a problem associated with wind farms, yet they are all unwilling to conduct studies on the subject… Why not? – Per Carmarthen Council’s latest directive based on local experience, for any new wind farm the Council wants the minimum turbine distance from any dwelling to be 1.5 kilometres. It is only right that to protect people in their homes, this ruling should now be given serious consideration by both the IPC and RWE. As turbines get even bigger, surely it cannot be right to approve a lesser distance now in the full knowledge that problems caused by this in the past will certainly mean ongoing problems in the future, leading to the mandated introduction of the bigger 1.5k buffer within the next couple of years anyway. – 17, 18 and 23 far to close to people’s homes.

Ecology – they will interfere with a lot of birds in the forestry – Rare plants and animals will disappear – essential that wildlife is protected e.g. red kites and red squirrels – Rare plants, flowers, animals and birds will go out of circulation – This industrial development should not be permitted in such an environmentally sensitive spot – Habitats will inevitably be destroyed during the construction period the noise & destruction will affect many protected species. – Don’t infringe on protected species seen so regularly around this area. – I often see red kites up towards this part and I farm the land at Foel Farm. Leave them alone. – These will be considerable collateral damage driving the construction phase. Some of this will be irreversible bulldozers, JCBs and heavy machinery with insensitive handling will only magnify the problem. Brechfa Forest West Wind Farm Consultation Report 166

appendix a (cont…)

– Avoid moving hedges. – I have not seen an environment (habitat) report I wonder what effect the turbines have on barn owls. I have lived within the forest edge for over 40 years & have not seen red squirrels since 1975. Although many of the grey’s have a red tinge at times of the year. – What affect is it going to be to the red squirrels that have lived in the forest for many years, because off all the trees that will be cut down to make way for turbines. – Red squirrels are seen at Brechfa Forest. Red kites are nesting in the woods. Protected species are important in this area. – Replacing any natural surfaces with concrete can never be good. – Rare birds. – Both will be affected with clearing of trees and big concrete bases and access roads. – It is not possible to minimise such a larger operation. It will be an ecological disaster zone for wildlife. – The effect of these habitats will be severe & cannot be mitigated adequately. – The habitats of rare species such as the red squirrel, polecat and pine marten must be safeguarded. – Will be an effect on flora + Fauna rare species are rare because of human intervention. – Minimise to what extent? Needs to negligible esp. for rarer species and habitats. – Minimising - how? And by how much? Will have a detrimental effect on wildlife which will be displaced. – Most important. Also - birds are killed, and bats lungs explode. Insufficient study of local flora + fauna. – our flora & fauna are huge contributions & preferably not at all to the balance of nature. If we disrupt that balance, we’ll pay a price. This is evidenced by CO2 emissions & climate change. – you will be destroying large amounts of habitat and for many years. – This proposed wind farm would negatively impact a number rare species of animals and birds. Yet in the ES, the developer concludes, that in each case, the wind farm would not have a significant impact on the protected wildlife species. What studies did they carry out to reach these conclusions? – Ripping up our countryside for useless, noisy turbines will destroy our wildlife including the red squirrel. – There is ultimately, nothing the local people can do about this development. We are, effectively, disenfranchised in this matter. Therefore, the only thing that can be done to minimise the effects on habitats is reduce the number of turbines going up. – This proposed wind farm would negatively impact a number rare species of animals and birds. Yet in the ES, the developer concludes, that in each case, the wind farm would not have a significant impact on the protected wildlife species. What studies did they carry out to reach these conclusions? – “going across land digging great holes filling with concrete” (don’t do it) that’s how.

Visual Impact – They will dominate the skyline and tower over the village – We can see 10 existing turbines from our property – Turbines near homes should be moved further away from homes i.e. 17, 18, 23 – Speaking from experience they are an eyesore to the countryside – Move turbines further back into forest – Use smaller height turbines Brechfa Forest West Wind Farm Consultation Report 167

appendix a (cont…)

– The only way to help visual effects are to keep the trees especially the mature beech trees at the side of the A485 – Impossible. Visually intrusive over much of South & West Wales – Impossible. Turbines 17,18,23,24 & others should not be included as at least relocated to protect the residents of Gwyddgrug, Alltwallis & New Inn area who have already suffered greatly following the construction of Alltwallis wind farm. Chapter 15 (figure 15.16) the properties within the yellow area who see between 11-16 turbines are hardly affected. – visual effects already seen from Alltwallis wind farm is far worse than what anyone expected owing to the height of the turbines. These are even higher and people are already worrying about their effect. No 17 18 & 23 need to be moved further back into the forest or totally deleted. – The ones already built by Alltwallis wind farm look so close and they are huge. 17 18 + 23 will look on top of our farm as they are so big. Get rid of them before starting would make sense or take them back into the forest. – Impossible to achieve with 28 turbines located near door on hilltops: screening is not an option (vital that they have seen from afar) – Against the skyline siting so they do not stand out, lowering the height of the turbines especially those nearest to the village. – Alltwallis wind farm is far more visible than originally shown on plans. – Could the height of the turbines by lower, so not to spoil the lovely skyline and countryside. – Because these are much higher, the visual impact will be very destructive, smaller turbines would be better closer to peoples homes. – Relocated further back to minimise the visual effect on so many homes in the Gwyddgrug village. Immediate areas seems to be ignored more so than the outer and historical places. – For most of us turbines will be ugly aspects of industry at any range and associated power lines will be unsightly. – 1) By putting them underground! 2) Leave them as computer visualisations. – Nobody wants to be faced with turbines when looking from your windows. – Who wants to walk near these machines? – It is not possible to hide 28 420ft turbines amongst 40ft trees. – Keep a minimum turbine height of 321! - not 476! – Build less turbines. – Make turbines lower than the trees. – It would be impossible to minimise the visual effects as the turbines will be 35m taller than those in the Alltwallis development OR as the 35m turbines will be taller than those in the Alltwallis development. – These turbines are bound to have a visual effect. Trees are acceptable turbines are not. – Average height of a tree = 20 ft. Turbines 400ft plus - so how do you purpose to do this? – Paying more attention to contours rather than building on ridge lines – View from the house where I stay will be further destroyed - has already been split. Plus do a lot of walking when here on holiday - will destroy our walks. – These are so high they will be seen from Brecon Beacons + all way to coast. How can that be “minimised”? – Shorter turbines should be used + No 17,18 +23 that will cause visual effect for homes in this village. Can move further back. Brechfa Forest West Wind Farm Consultation Report 168

appendix a (cont…)

– We can see them all the time on the yard from the bedroom windows. – Again, turbines 17/18+23 need to be removed from the proposed plan. Turbines from the Alltwallis wind farm are already totally dominating our home (further info enclosed) – As these are so high they will be visually intrusive hence the need for moving turbines 17,18&23. – In Wales generally, our economy struggles to compete with the rest of the UK. One thing we have in our favour is our wild, beautiful landscape. Destroy that & you destroy our tourist industry. – The pylons are massive. It will totally ruin the appearance of the Cothi Valley. Yet another below to the tourism on which we depend. – only invisible paint on the turbines would minimise the visual impact of the proposed wind turbines. – The developers have made no attempt to take into account the responses from the community during the consultation process on the visual impact of this development. – The turbines can be reduced in number and those that are then remaining on the periphery of the development moved back to a minimum distance of 2 miles from the local population centres. Evergreen tree planting schemes further down the hillsides, closer to the local villages, will help to screen the wind farm.

Recreation and Access – Ramblers and Walkers forced out of the countryside. – Tourism and leisure. People will not feel safe to roam in case blades will fall off – Killing tourism and leisure from the countryside of Wales. – Likely to reduce tourist/visitor/holiday maker numbers - A good thing – I can see no beneficial effects on access resulting from this vandalism. – The recreational amenity will be destroyed. Who wants to work in the grounds of noisy factory? Greater car use to access for more desirable areas will result. – Destroying amenity of residents & visitors. Confronted with at the Alltwallis wind farm. No gates for pedestrians alongside cattle grids. Inadequate stiles. Locked gates etc. (F.P.13.11) the long distance listeran way (dating back to the middle ages) runs through the site. the proximity of turbines 14 & 21 to the footpath could present a hazard of ice throw. – The A485 is not adequate to take all the transport increase as we have only just experienced. Two entrances for access within A485 is totally a danger waiting to happen. No one thought of local people when they were planning this access. Everyone in the village is angry, stressed, knowing what the suffering will be once more. – I always see people walking on this part. Leave them walk. – Access to public footpaths must be retained with provision of styles, gates etc disabled persons. The North Carmarthenshire hills are a valuable amenity for local residents, visitors & tourists. – During walks in the forest visual effects of existing turbines destroy the view. – I will no longer want to go for walks through the forest due to visual impact. – During walks in the forest visual effects of existing turbines destroy the view. – Public would rather stay as far away as possible from area. – Loss of access while work is in progress. – The overwhelming concentration of turbines will destroy recreation and existing tourism Brechfa Forest West Wind Farm Consultation Report 169

appendix a (cont…)

– The periphery of the forest provides access to walkers, dog walkers (with needs so one provides these on dog bags) tracking likes the occasional illicit quad bike on trail bike. Due to long term cut backs in road maintenance the ‘c’ classified & unclassified roads are in poor condition. I fear that when heavy wagons are used to extract timber during & prior to turbine construction some of these roads will be messy & unsafe. At the end of construction RWE & the Council should commit for remedial works. – There is a pleasant hedgerow with 150year old beech trees situated at intervals giving pleasure to myself and my neighbours and undoubtedly the local wildlife and helping to keep the noise levels away from the homes along the main road. – Local residence and ramblers will be affected as they walk here regularly. – No one should be stopped from walking in this beautiful part. Local residents have walked here regularly for years. – Who would want walk or ride through a wind factory as a leisure pursuit. – This wind farm (not to mention all the others) are running out open spaces for everything we value them for. – I hope it will not affect our weekly walks through the forestry of Brechfa by noise from the turbines and no access to certain areas. – Brechfa Forest is one of the areas major assets. It should not be ruined for financial gain. – Recreation amenity will be ruined. – Disruption during construction & people will not enjoy access with giant turbines there. – The paths must be safeguarded. In the Alltwallis development there are two turbines within 40m of the paths - which is much too close. – The Brechfa Forest is popular for walkers + horse riders - horse + owners will not enjoy riding amongst massive turbines - there is also a safety issue with turbines. – Huge negative effect on tourism/use of forest for development of recreation which CCC and forestry commission say they are promoting! – I holiday here, as do my parents and my brothers family and my nephews family - we are all looking for somewhere else to go if this goes ahead. – no one should be stopped from walking in this beautiful part. Local residents have walked here regularly for years. – Noise impact when people are out walking/relaxing. – Too much loss of public amenities and for such a long time. – Noise interferes with leisure time. – Loss of public amenity. – Loss of amenity - would not be a pleasure to walk around this area. – This issue is inextricably linked to the tourist industry, which makes a huge contribution to the Welsh economy. – The forest will become a no-go area for the many bikers, dog walkers and horse riders who use it daily. – Brechfa Forest is open access land - a huge wind farm development would pose a severe health and safety risk to members of the public who use the forestry. Brechfa Forest was brought using tax payers money. It therefore belongs to the Welsh people. NOT to the Welsh Assembly Govt. The Welsh people were not asked by the govt if the national forests could be used for wind farm development. – This development will put the lives of local people in danger, the developers have ignored the responses from user groups on the issues of building a wind farm in the forest. The developers have failed to comply with EN1, which requires them to demonstrate that open access land is not needed for recreation, or to provide replacement land adjacent to the site, with the same level of amenity benefit as the land taken for the development. Brechfa Forest West Wind Farm Consultation Report 170

appendix a (cont…)

– The forestry commission belongs to the people and the building of a wind farm will affect our rights of public access for a very long time. You have even said you will be closing PUBLIC foot paths. – The forest is, effectively, going to be out of bounds during the entire construction period, The development area is so large, that in addition to normal forestry activity, it will become a NO GO area. The forest is the ONLY local area where dog walkers can exercise their dogs off the lead. How do you intend to mitigate this? ALL local fields are sheep and cow grazing and the local farmers shoot dogs on sight.

Transportation and Access – The pre-existing inadequacy of A485 for present heavy traffic must be emphasized to disruption during wind farm construction – will cause chaos on the small roads during development – Use existing track it has been used in the last few weeks due to repair of Turbine 9. – No need for new access. Why cant they use the same access as before – Why cant you use the same track as previous turbines 150 yards down the road – Simple no need to look further access already there 150 yards from your proposed plan. Think of the environment. – Waste of resources with an access 150-170 yds down the road – No need for second access as Alltwalis wind farm is 170 meters down the road – no need for second access as there is already an entrance for Alltwalis wind farm 1070m down the road – How many loads of components? How many loads of concrete? How many loads of Hardcore? Needed to complete wind farm – Think of the environment and use existing Alltwalis wind farm which is suitable. – There is no indication that a bell mouth will be constructed to facilitate visibility. Why? Should this not be part of planning? – access inaccurately marked on map. No mention of fell entrance or felling of trees to achieve this. 2 entrances 150mts apart. No consultation with local residents. A485 is unsuitable, the only visible road to hospital A&E maternity services. – Cumulative effect of two other proposed developments could occur simultaneously causing complete chaos on an already busy road. How can a traffic management plan be drawn up without specific details (where hardcore will be sourced & the quantity available on site). On the map the proposed access track from the A485 is shown tutoring in at right angles. Details plans needed here. The exact length of hedge to be removed & the mature trees should be noted. I question the need for a new track - this is in contradiction to 3.72 (land-take) No consultation with local residents. – Don’t push any more accesses on a small village doesn’t make sense to anyone. There are plenty of options - keep away from the main mead by another entrance being so close. – Another nightmare scenario with thousands of road traffic journeys, often hearing and slow moving with no alternative viable route in the case of emergencies (access to the site remains a mystery). – No need for further road as existing one already provides access. Life threatening delays may occur during construction, my father has a bad heart and may need urgent medical care. – No need for further road as existing one already provides access. Life threatening delays may occur during construction of new road as I may need medical help due to heart attacks I have suffered. Brechfa Forest West Wind Farm Consultation Report 171

appendix a (cont…)

– yes I remember the chaos last lot of lorries caused on road transporting turbines. – Inconvenience for local people during construction. – Why is there a need for a new access road when there is a access road for the stockraft turbines 150yds away which runs parallel with the new access road. – The access is far to close to the Alltwalis Wind Farm entrance. If people living close had been informed as they should, it would have been clear that no one was prepared to suffer for the second time. – No consultation declared with any of the nearest homes, even though people asked months ahead whilst this was in process. The access is only 170 metres from the Alltwallis wind farm entrance. Why have two access so close, and the same people being affected. – We have hardly any of our legal rights of why in this locality. I cant see how this will make it better. – Effect on the beautiful landscape of Carmarthenshire. – Disruption during building process e.g. ………. petrol tanks, deliveries to public & business, emergency vehicles e.g. fire service & ambulance service. – The roads around here are already of poor standard. Another 30000 or so large lorry movements will make matters much worse. – No vehicles to go through or use the little roads around Gwernogle. – The road network will not cope with the large number of lorries. – Disruption on main roads - construction roads used as race tracks by 4x4s. – The main road from Carmarthen to is already extremely busy. – Heavy traffic causing disruption during construction small roads not suitable for heavy traffic not acceptable for locals. – Main route to hospital major disruption during development. Major damage to road by heavy plant etc. Who pays for this? - Council tax payers! – Will be huge amount of disruption for local residents and damage to road - who pays? – We do not understand this question. – Roads are totally inadequate for transporting ……….. large turbines. The cost involved in creating suitable access would be enormous. – Additional in roads required for further turbines. I access road should be sufficient especially for small village. – No more than one access for village should never be considered for approval. – No additional roads should be required. – The access track will be a total blight - directly in front of our property! No consultation was carried out with neighbouring properties (further information enclosed on this). – The access track will be a total blight on our property. Have suffered enough from the construction of Alltwallis wind farm. Now you want to bring the access even closer! We will not be able to continue living at Gellifelen if permission is granted for this access track. This will destroy our home. – An access track running parallel with an existing track (150yards) is not acceptable environmentally. – Much of the Welsh countryside has been sensitively developed with small roads, single tracks. If you destroy the network, you destroy not only the areas biodiversity but also its recreation appeal. Brechfa Forest West Wind Farm Consultation Report 172

appendix a (cont…)

– Local people encountered significant delays and inconveniences when the adjacent Allwallis wind farm was being constructed. There were only 10 wind turbines erected on that site. 28 wind turbines are proposed for Brechfa Forest West, plus another 33 wind turbines for 2 more proposed wind farms in the same vicinity. The cumulative impact on transportation and access would place too much burden and stress on the local people and would greatly hinder access by the emergency services during the construction phase, unless it was by helicopter. – The developers have failed to consider the danger they will be placing local residents in when they have to walk, cycle or ride on routes that will also be carrying large numbers of heavy vehicles. – The proposed new access of the A485 will cut through one and half miles of countryside landscape and will cut through designated Habitat Land which was imposed to enable planning permission to be granted for Blaengwen wind farm. There is currently no track there, although it has been noted that someone has already been digging a track on the designated habitat area. This new track will be right on the boundary of our farm and as owners of the Blaengwen Access Track we have already experienced the dust pollution, slit run off and introduction of Japanese Knotweed brought in with road building materials. We do not wish to have this disturbance all over again. – The effects of the construction traffic on rural roads already in a poor state of repair after 3 hard winters and budgetary repair constraints will be massive – We get one turbine entrance at Bedw Hiron Farm we don’t want another just along the road. – This will cause absolute chaos on these roads, especially around the entry road. – on a already busy road, it will cause delays and possible accidents.

Is there anything else that you think should be considered? – Wind Farms are not the way forward for our energy crisis. They are inefficient, expensive and have a dreadful carbon footprint during construction – We are already losing sleep due to existing turbines and hope you can guarantee us the same will not happen with next turbines. – yes, ask the people already suffering from the existing wind farm. Can you guarantee that no noise, no vibration will be heard when you will erecting this wind farm? What are you going to do differently? – Turbines in this development are much bigger making it more of an eyesore – The community close by the development will be affected by height and power – Unable to understand why company has considered another entrance as existing one is more than adequate. This was proven mid February 2011 when it was operational for repair. Think green and save raping the countryside. – Preserve the mature trees beside the A485 they are needed for the households nearby. Do not rip the countryside apart through making another road parallel with the existing one. THINK GREEN! – What effects on health have been studied? E.G. Infrasound and light flicker. – Cumulative effects of noise affects on residents. No mention in the EIA about mitigating stroboscopic effects of reflected sunlight on local residents. Why? This is not shadow flicker but is a real safety hazard. – Noise - our experience suggests ETSU97 guidelines are not suitable for large turbines and the cumulative effect will have serious adverse effects on the physical mental & financial well being of many local residents. Glare - sunlight & bright moonlight reflecting off rotating blades cause an effect similar to constant, very bright flash photography. Unbearable. Brechfa Forest West Wind Farm Consultation Report 173

appendix a (cont…)

– As myself & family are still suffering from the noise problem of Alltwallis wind farm No 17 18 + 23 should be taken back into the forest. These are much higher again than Alltwallis turbines. Therefore common sense prevails that these will carry noise much further. There is plenty of space to take them back. Think about the people in Gwyddgrug village. – The words ‘minimise’ and ‘mitigate’ appear often in the non technical summary hinting that problems remain unresolved. Whether this can be achieved remains to be seen. Habitats & eco systems are averse to this kind of disturbance/interference having taken thousands of years to evolve and flourish. – The proposal has resulted in stress to our family and the village as a whole many suffer stress in the village the proposed new road will effect urgent medical help getting to people like myself or my husband. – The proposal has resulted in stress to me and my family and the village as a whole, many suffer stress in the village, the new road will effect urgent medical help getting to heart attack victims like myself. – As there is no doubt the scheme will go ahead, turbine sizes should be reduced to 110m. – No poster outside the old school Alltwallis to advertise the RWE exhibition there. Was no leaflet to sign to oppose the development. – Geology seems to have been based on existing surveys + occasional inspections. I am concerned with noise transmission through rock. 1 I have little confidence this survey as I am very aware of the local geology and have never co-efficient of most transmission on each rock type and likely low frequency noise levels at points outside the area of the wind farm. – I live on the western edge of the wind farm. This area is a wide spread rural community, economically relatively poor on heavily dependant on central authority support. Little industry other than agriculture (mainly below average m…..)a thrive garage & little else, pub and school) my opinion only RWE should consider helping the local community & individuals access micro generation. – 49 properties are within 2km of this development. May of these homes are experiencing high level of noise from the existing Alltwallis turbines i.e. awake for hours at night. Very loud noise on their farmyard especially when weather conditions changes. Etsu guidelines do not give the needed protection for homes as they are years out of date i.e. (1997). With recent higher turbines developed they carry noise much further than predicted. Cos we are already experiencing). Please think of people in their homes. – Human greed versus quality of life. – The construction of giant wind turbines in this area is only possible because ordinary people not have the knowledge skills time & money to offer opposition to this autocratic imposition. – Hopefully there will still be access to the forestry from the Llanllawddog side of the forestry. – This will be third development of turbines in this area of Allwallis, Gwyddgrug & New Inn, as community it is expecting people’s health of live hoods for the present & future year ahead. – The following Carmarthen County Council Planning Policies: CUDP-GDC7, GDC8, REC7, REC11, GDC19. CUDP - UTS, UT6, EN20. CUDP10, CUDP11. I hope these will be taken seriously. – To erect signs prohibiting vehicles as above at the junctions with the B roads, these signs should be for the life of the wind farm! Permanent. Brechfa Forest West Wind Farm Consultation Report 174

appendix a (cont…)

– Limit the number constructed. Potentially, over 100 turbines could be built within the Brechfa Forest & surrounding areas. – I have used Brechfa Forest for the last 10 years for falconry purposes, but this will now be to dangerous for the birds to play within the forest with this development. – Don’t put up the wind farm. – I shudder to think how this development and the other two proposed developments will affect the area where I was brought up. Gwyddgrug and the nearby villages have been destroyed visually as a result of the ten turbines. This development will add another 28 with 12 at Rhydcymerau and 21 at Llanllwni, thus changing the landscape of the whole area forever. – The effect of Brechfa West Wind Farm on the local tourism industry - many B+Bs and holiday lets will suffer from being surrounded by wind turbines - tourists are not going to choose this area when there are other areas that do not have wind farms. – Property values - our house already depreciated beyond what expected due to recession. Cumulative effects of visual impact, noise and traffic disruption. – Noise. The 10 wind turbines at Alltwallis Wind Farm are creating far more noise than we were lead to believe by the developers. Constant monitoring and adjusting has not improved the situation. – Cumulative effect of this with development already in existence plus further 2 major developments planned. Will devastate the beauty and tranquillity of this area, change it forever - tourist publications all call Carmarthenshire ‘the garden of Wales’ - wont be able to call it that anymore! – We believe the impact on local communities due to traffic impact when three to four wind farm installations could be occurring concurrently needs to be addressed. A report on this and the standards required for vehicle cleanliness, waste disposal and animal security pertaining to the installations has been written by our Technical Officer, which we would like to put before the IPC at the appropriate time, if RWE npower Renewables would like to see a copy of this report please contact us as per the details at the end of this questionnaire. – New evidence is coming to light all the time. Until we have more knowledge of the long term affects of putting up developments such as this, and look thoroughly at the actual efficiency of wind turbines in the UK, there should be no more such developments. Too much being sacrificed for life of only 25 years. – I believe that in Scotland there are laws which state the large scale turbines should be a minimum of 2km from residential property. – More investigations into noise problems. Why the bigger turbines are carrying such noise. Buffers area needs to move the distance to 1.5-2km. – Small village location does not warrant further roads to be built to accommodate anymore turbines. – Noise problems from Alltwallis wind farm are ongoing. The situation is unbearable at times resulting in sleep deprivation etc (further information enclosed) The noise problems from Alltwallis wind farm need to be rectified prior to any further applications. – The noise problems from Alltwallis wind farm have to be rectified before any further applications are submitted. – Noise levels from the Alltwallis wind farm remains a problem in this village. The prospect of another 28 wind turbines would be detrimental to this area. Brechfa Forest West Wind Farm Consultation Report 175

appendix a (cont…)

– Wind turbines are an inefficient & expensive way to generate power. Germany, Denmark & Holland are all withdrawing from this form of energy production precisely because it has cost every country more in real terms. While we must continue to try & find alternatives to fossil fuels, it would make more sense to make each house self sufficient - it wouldn’t cost more than the current proposals & would make better economic sense. – your questions are deliberately misleading so you can massage the statistics and responses. Is tourism important to this area? – only one access route to all the sites should be made since all are contiguous. The Blaengwen access should be used. More thought should be given to the ravens in the Pib valley. – Ruining the beautiful Cothi Valley. It is hard keeping a small community like ours together will all the pressure of modern life. This project will just serve to drive more people away. – 1) Flooding: The proposed developments contravene TAN15(2004) - Development and Flood Risk. There are flood risks in low lying areas downstream from the proposed wind farm development 20 out of 28 proposed wind turbines are on land that drains into tributaries of the River Cothi. There is already an Category 1 flood risk at Nantgaredig. 2) Dropping the proposed development - the area is not suitable for wind farm development for both environmental and wildlife protection reasons. – Noise pollution within the forest. The developers have ignored the outcome of the two community consultation meetings held with community representatives. The developers were informed during those meetings that the community would expect to see noise level readings taken on the forest tracks. The community representatives also informed RWE Npower that they expected funding to be provided by the developers so that the community could hire an expert in noise to advise the community on the accuracy of the noise impact statement that Npower produced for this development. The community has suffered badly due to the inaccuracy of the noise impact statement for the wind farm which has since been constructed in this area. Npower has failed to carry out noise level readings within the forest. Effects on the community, it is very telling that the contents of this survey matches the attitude with which RWE Npower has approached local community. They do not include in the survey points any questions on tourism, despite knowing that the local economy is heavily dependant on tourists visiting Brechfa Forest. Failure to comply with the UK governments planning policy for energy projects. EN1. - The developers have not shown that the open access land is not needed, and have failed to provide information on the replacement land they intend to provide. Given the level of disturbance during the development, we expect the replacement land to be the same area as the whole site, including the quarries and routes from those to each wind farm site. Not just the area taken up by the turbines. – Compliance with EN1. Minimising noise pollution within the forest. The impact on the local equestrian economy. The safety of the local equestrians, both horses and riders/ drivers travelling to the forest, as well as while in the forest. The impact on the health and wellbeing of the users of the forest. The impact on the Cambrian Mountain Initiative. – The forestry commission has always managed to haul their timber out on artic lorry’s and the same roads should be used, upgraded if necessary. There will be enough damage done to the countryside without building new roads and massive visibility splays. Brechfa Forest West Wind Farm Consultation Report 176

appendix a (cont…)

– There is no mention in the above lists of “receptor” concerns, i.e. the plight of local residents, and possible long-term health effects from noise, flicker, amplitude modulation , etc It is absurd that this information is not sent directly to an independent authority rather than the firm planning the scheme. There has been minimal public consultation with residents from the very creation of the TAN 8 areas through to this fiasco of a consultation If as a company you were serious about engaging with residents you would have mailshotted/held information gathering exercises at an earlier date and genuinely responded to resident’s concerns – This proposed development is in addition to the 10 turbines already at Alltwallis, the 12 due to go up at Brechfa Forest East, the 21 due to go up on Mynydd Llanlwni, the potential 40+ turbines at . This gives 71 turbines within an approx 4.5 mile radius of Gwernogle and 110 or more within an approx 5.5 mile radius of Bryn Llewelyn. Studies into the effect of wind farms to date have been conducted on developments of 10-16 turbines in total. Larger studies have been done in America, but these are generally of 20 turbines. The cumulative impact and effect of these turbines in such a small area MUST BE DONE PRIOR TO THE GRANTING OF ANY FURTHER APPLICATIONS. – Wind turbines will not guarantee our energy supply.

If you think the project will have positive effects, how could these be enhanced or maximised? – They have no positive effects – The company needs to be honest with local people. – Why did you not disclose where the entrance was proposed? Surely it is in the interest of the local residents. – Questions unanswered re site entrance very negative effects so far. – The public were not given the true facts regarding entrances etc – At present nothing positive has come to light. – Until you recognise the noise issues as you should and involve local people this project will not have any positive effects. – Stop this project the whole village is in revolt over your company and directors who seek to degrade our property values while making large profits for their company. – Avoiding having the local county council managing community based payments – Although I see many positive effects for the wider community, I do not see these benefits translating for the local disparate community – Install gigantic fans (driven by nuclear energy) to make sure they don’t slow down when there is no wind. – Can’t think of any positive effects, accept jobs - but that won’t be for many local people. – Access to the windmills after construction will be an interesting extra while using the forest for recreation. – By requiring the developers to comply with EN1. – I cannot see any positive effects.

Concerns And Mitigation – listening to local residents’ concerns about proximity, noise, ‘planning blight’ for house values and responding with specific solutions. – By not building the wind farm – 1) Devaluation of property. 2)Noise Compensation Both above should be a legal signed document by the company to pay compensation if either of the above happens Brechfa Forest West Wind Farm Consultation Report 177

appendix a (cont…)

– Reduce the scale of the development and move its extremities further from dwellings – The cumulative effect, if all proposals go forward will result in approximately 40 turbines being visible from my property. This could be avoided by building them elsewhere or not at all. – Project will not continue much towards contributing climate change, it will provide electricity from time to time but the developers will …..rich harvest. Is all this worth it? The impact on this area will be significant. – Planning refused. – I wish they were not built in the first place. – I am very concerned that despite £millions are to be spent few if any local jobs for local people will be created. – I would like legally binding contracts, so both party’s know what is happening and that there will not be any forgotten promise. – By abandoning it. – To reroute transport of turbines on a safer route. – I am concerned about access to forestry and minor roads getting excessively restricted during installation, decommissioning or any unforeseen circumstances. – Projects such as this should be located way offshore or on remote areas. – one wind farm consisting of a maximum of 20 turbines - any more constitutes industrialisation. – This development will make Carmarthenshire very unattractive to tourists and will have a very bad effect on the immediate area. – Smaller turbines. Further away from residential properties and far more understanding of noise nuisance in hills and valleys and in moist conditions. – My concerns are listed on this form. Its your job to find ways to avoid\minimise! At least set up a system for local residents to be fully compensated - that is not a community benefit fund! – By supporting problems adequately i.e. noise problems, visual effects and shadow flickers. – By moving turbines 17/18+23 from the proposed plan & the new proposed access track. There are other options available which would be less harmful to the environment. – Power companies have access to huge financial reserves. They should be promoting truly sustainable forms of energy production (like for example hydro). If the government withdrew the subsides the power companies would quickly withdraw from this type of development. – yes. Offshore farms. – By requiring the developers to comply with EN1 and the BHS advisory statement on wind farms. – Planning permission should NOT be given. – The sheer scale of the project is a concern, combined with the size of the turbines and the cumulative effects and impacts of the expected 110+ turbines in an approx 5 mile radius of Gwernogle/Bryn Llewlyn. The proximity to local villages is of concern, especially given the height of the turbines. Reducing the number of turbines and the height of those that do go up is an option. A public enquiry into the overall cumulative impact of these turbines in such a small area should be carried out. Brechfa Forest West Wind Farm Consultation Report 178

appendix a (cont…)

Turbine Layout – They are too close to Gwyddgrug – Turbines to be moved back to the forestry – 17,18, 23 take them back more into the forest. – move back to minimise noise and visual effect – need to be moved back to minimise visual and noise impact – Think of people already losing sleep through noise. Move away from properties. – look at the surrounding properties and move turbines to suit. – Much to close to peoples homes. Too visually intrusive, 17 visible from the property (39 in total) 10-stathraft. 12-RES – Alltwallis village is approximately 2.2kl from the nearest turbine. Gwyddgrug village is approximately 2.3kl from the nearest turbine. New Inn village is approximately 2.8kl from the nearest turbine. The layout is far too close to these villages & the surrounding forms & homesteads - the nearest turbines should not be included in the development or relocated. This development scheme shares boundaries with two other developments making it into one huge proposed Power Station of 59 turbines. – Far too near the villages of New Inn, Gwyddgrug & Alltwallis a request to relocate a few turbines further from dwellings was refused. – Will have a visually cluttering appearance on the landscape. – It covers exactly the areas we have been using for our community walks, nice! – Wherever you place 28 x 125m turbines they will ruin the scenery along the Teifi Valley. – Turbines on the highest, most prominent points so maximising visual impact. – The turbines are too close to the village and nearby farms. – Development too close to properties already affected by Blaengwen development. Delete 7,8,23 from plans. – By RWE npowers own admission at the public exhibition, the turbines are not in the best place for electricity generation but constrained & determined by their efforts to mitigate their effects. – The turbine layout sites the turbines adjacent to forest tracks used by tourists. – The turbine layout does not comply with the safety guidance for equestrians published by the British Horse Society for the benefit of developers, councils and horse riders and carriage drivers. – It is absurd that the precise turbine spec is not included. – No positive comments – the wind turbines should not be built in existing forestry land. Under European and Wales Policies, Europe has signed up to the Kyoto Protocol which states that, in developing renewable energy, existing carbon sinks should NOT be disturbed. Deforestation for wind farm development would directly contravene Wales’s commitment to the Kyoto Protocol.

Infrastructure – Don’t know anything about it – Loss of agricultural land to create a new access track (as the existing Alltwallis Power Station track is just 170 metres to the South & runs parallel with the proposed track to the forest) – Another scar on the landscape – Noise levels will destroy our health people living near the existing turbines already suffering health problems. Brechfa Forest West Wind Farm Consultation Report 179

appendix a (cont…)

– Noise levels will destroy our health people living more nearer the existing turbines have had health problems and high blood pressure due to the noise. – Too near to good agriculture land, village communities. – I fail to see why the infrastructure could not be shared with nearby wind farms; especially as you should be reducing carbon footprint across your operations. Why hasn’t the Assembly/County Council answered this. – Creating a new route parallel to the Alltwallis route will affect more pasture and wildlife habitats. – Grid connection infrastructure not defined on plan. – It should not be sited in publicity owned woodlands without the public’s consent. The Welsh Assembly Govt never asked the people who they are supposed to represent. This is not my idea of democracy. – The company should be using the same power lines that take the power away from the existing wind farm in the area, not creating more damage to the landscape by connecting to a different part of the National Grid. – The developers have chosen to not consider the implications on the tourism industry when sitting infrastructure. – The line out all the way to Swansea will cause untold damage to the appearance of the countryside not to mention the distress to land owners who will have to accommodate the poles. It is fact that some landowners have still not been compensated for damage on the line from Allwallis to Rhos. – The connection of all these turbines to the grid is to be the subject of a separate application process. This is potentially hugely disruptive of itself, but we have no details yet. Television and mobile phone signals in the area are unreliable presently, even digital & satellite TV is poor. Are we really to believe that you’re going to pay for cable to be installed and subsidise local people for the cost of switching? – It should not be sited in publicly owned woodlands without the public’s consent. The Welsh Assembly Govt never asked the people who they are supposed to represent. This is not my idea of democracy. – More turbines to ruin this beautiful countryside.

Surveys – Not heard of any surveys. Would be interested to see what surveys have been undertaken – Insufficient consultation & frequently misleading as they attempt to minimise adverse affects. Photomontages are deceptive & do not accurately reflect the true nature of the visual impact from our property & surrounding area. – Information given was uncertain & inconclusive words used maybe, might, where possible, unlikely, could. More transparency is required. Will the elusive tests/surveys be carried out before requesting planning permission e.g. private water supply. A full survey of PWS...... will be conducted prior to the start of construction. Grid connection 3.78 it is likely....overhead line on wooden poles. – Presented with positive spin with adverse effects to be minimised or mitigated with ease. – No one can say the effect of these wind turbines at present. – No details of access entrance from the main road. – Local people have been totally forgotten in this survey. Brechfa Forest West Wind Farm Consultation Report 180

appendix a (cont…)

– I believe in global warming and climate change. I want a stable economy and environment that does not further harm our planet. We haven’t yet done a fraction of the things we need to do to economise on power consumption or generate energy on a small scale. Please invest in all the alternatives to these gross eyesores. 50 years ago hardly anyone round here even had electricity. – Hydrology, insufficient + bird species incorrect. – Impact on wildlife, habitats, soil erosion, hydrology, archaeology etc and noise impacts all insufficient. – only seen ‘short’ verision of ES - but seem to be lacking in detail especially wildlife, noise and hydrology. – Forestry consultants would have been the appropriate people to request information from. – In each case where rare and protected species were observed, the conclusions were that construction and operation of the proposed wind farm would not adversely impact on the protected species. How were these conclusions arrived at? – Npower have failed to include in the planning application any information on the number, size and location of tourist businesses or equestrian business in the area. – otters and red squirrels have not been considered enough. They are only a token gesture anyway, just bits of paper. – Many of the assessments have been desk based and comparisons have been made with existing wind farms in the drawing of conclusions. Existing wind farm studies are mainly for 10-16 turbines developments, considered singly. The proposed wind farms for this area will be potentially 110+ turbines. Data does not exist for such a cumulative development. The turbines on Eaglesham Moor wind farm are smaller. – In each case where rare and protected species were observed, the conclusions were that construction and operation of the proposed wind farm would not adversely impact on the protected species. How were these conclusions arrived at?

Mitigation – Council tax cut – No measures can redress the potential problems/ ruination of the area – These are completely inadequate if you do not make a contractual undertaking to compensate all who are adversely affected by loss of value to their homes. – Very inadequate – Local people should not have been treated in this manner. Communication with the closest homes to these turbines should have been done at every level. From access/ entrance planning to process and not hidden from the people. Very badly done. – Existing residents already have bad health problems due to the noise level of the existing turbines resulting in bad health issues i.e. high blood pressure. – White appears a reasonable colour but have multi coloured milsl been tried? – There is no way to mitigate the serious damage that this project will do to the character and appearance of the area. – Consideration must be given to the long term effects not only of the turbines but also to the concrete bases and the access roads which will have a permanent effect on the landscape. – No one listens to local voices. – The effect on hydrology, on plants, birds, insects etc has not been adequately studied. The desktop exercises & the inexperienced consultants findings need to be much more vigorously challenged. Brechfa Forest West Wind Farm Consultation Report 181

appendix a (cont…)

– No amount of measures can mitigate the destruction of large areas of fragile sensitive upland habitat. – The mitigation measures take no account of the way in which tourists use the forest, or the way in which the forest is marketed as a tourist attraction. – The mitigation measures do not comply with the safety guidance for equestrians published by the British Horse Society for the benefit of developers, councils and horse riders and carriage drivers. – How, for example, is it proposed to maintain the additional drainage needed to cope with the increased rain run off? Existing drainage is insufficient and poorly maintained. How do you propose to mitigate the displacement of the avian population? Or mitigate for the loss of breeding habitat? Red kites breed in the area and it is offence to intentionally or recklessly disturb the birds close to their nest during the breeding season. I expect your company is so huge that you’ll just shrug off the fines and not worry about the impact on the breeding population of this protected bird.

Other – Wind farms are USELESS, NOISY, POLLUTING and can NEVER provide enough energy to justify their construction. – Visual impact can distract us from our daily work and also we suffer from shadow flicker from the existing turbines. Use existing road to save on carbon footprint – These turbines are going to be bigger and how are you going to control the noise we suffer . From visual impact how many more turbines are we going to see. Can we expect shadow flicker as we now suffer. – Visual impact and shadow flicker and we also suffered excessive noise during the construction of the road. How are you going to protect the row of beech tress along the A485 – Another access on a busy A485 - Do you think that is needed?? Be honest with us and the environment. What do you intend doing about the row of mature oak trees at the side of the A485?? Talk to the local, find out their views. – Re. Site access. A fair place to start is to be honest in your answer. Instead saying - ‘We don’t know yet- must speak to the landowner first. Does not matter about us “Jo Public”. What is going to happen to the trees, they do protect us from visual and noise problems? – We have experienced noise at times in the night and we should receive compensation for this – Access is the main concern as I feel that being environment friendly should be high priority with the company so use the existing road which has proven viable during the last few weeks. No extra disturbance for residents, habitat and cost effective for the company. Very concerned in the way the company (RWE) have been so negative in giving information about the proposed access. As it has been mentioned to people including myself “It would not be fair or appropriate to highlight their (the landowners that is) land in the public domain until they have decided that they wish to be involved in the scheme”. When I attended the exhibition at Alltwalis school it was very deceiving as the map that was on the table was of the Bryn llewelyn, Rhydcymerau and Brechfa West. I had to ask if I could seen a map of Brechfa west only and it was underneath the other map. Other people in the exhibition could then see more clearly where the proposed entrance was and could see that its only 170 meters approximately up the road from Alltwalis Wind farm entrance. It was confusing for people on the other map. Brechfa Forest West Wind Farm Consultation Report 182

appendix a (cont…)

Keep it simple for people to see an understand. This is the way forward to work with the community and not to hide the important issues of the development from the people concerned. It would have been advisable that the company would have had an exhibition at the village of Gwyddgrug seeing that this village is going to be the most at risk with transportation, construction noise etc. I have heard that the company’s comments were that the vestry is too small but surely a member of the company could have arranged something. Why the need for 2 entrances so near to each other on such a busy road? I thought that environmental friendly issues should be the top priority to the company. We hear so much about carbon footprint. Now is your chance to use Alltwalis Wind farm access. Why do you want to rip the countryside apart with another entrance? Why do you want to disturb the wild habitat through making another track? The Alltwalis wind farm access was used on the 17 and 18th February 2011 to transport parts up to the wind farm for repairs. That is the “proof of the pudding” for you. Less expense, Less transportation of hardcore etc. Another route you should consider (or you have considered) is New Inn as this is a council road and is being used at present with lorries carting trees out of the forestry. Same again less expense, less transportation of hardcore etc. What do you think? Trees and hedgerows are going to be cut. Do you realise that these mature oaks protect residents on the A485 from the weather elements. How are you going to deal with this? Very concerned about emergency services on the A485 as this road is the main road from to Glangwili Hospital at Carmarthen. Have you an emergency plan? – No figures seem to give the true gain in energy. i.e. when one takes into account the total energy needed for manufacture, transportation/construction/ maintenance/ decommissioning against anticipated mean energy generated by turbines. – The consultation has been extremely cursory and inadequate. The photomontages are misleading, and seem designed to throw dust in the eyes of those who do not know the area. We are already beset by problems of noise and visual intrusion from one small development and the cumulative effects of these proposals are horrendous to contemplate causing nuisance and loss of property value. – Noise problems - I am concerned that three wind farms are being built so close to each other. The accumulative noise effect of (3) will be a major problem to the nearest homes & the people in Gwyddgrug village. There will be many homes that will find it unbearable to live there as they are already experiencing oise from inside their homes and are awake at night. Also the proposed access point is ludicuous a danger to road users. Both need serious consultation reviewing before allowing this planning to be granted. – More needs to be done to protect the people living close to the turbines. My farm will be affected like many others. Stop 17 18 + 23 so go on or take them to the forest. Use New Inn road for the access road on th Alltwallis wind farm road. It is already done. That will stop anymore disturbance in Gwyddgrug village. Start working with the local people. At this moment this is not happening. – I doubt whether the proposals would confirm with Carmarthenshire UDP section UT6 - wind energy. These have been drawn up to protect the well being. Quality of life & environment of its residents. – 1. Fall in property value of my house becoming unsaleable (I would expect the company to pay for any fall in property value due to the project (within a time period) 2. Visual impact on the property due to turbines 17, 18, 23 and the height of them. 3. Noise levels effects on health. – I am concerned that the liaison group has been poorly organised and so has become polarised for the benefit of single issue lobbies led by concerned incomers, the reticent locals subordinate. I am therefore concerned that the local benefits will go to larger coordinated groups/communities rather than more local disparate needs. Brechfa Forest West Wind Farm Consultation Report 183

appendix a (cont…)

– To induce the visual affect and help the noise problems. No17, 18 + 23 should be moved back before allowing this development to happen, no doubt the accumulative effect of 3 Wind Farm in the same area will cause a serious problem to the nearest locality being (GWYDDGRUG) village. Another priority would be reviewing the access. 170 metres distance from one access to the other on the same main road is only a destruction land danger to road users and local people. – 1) Carmarthenshire County Council Unitary Development Plan Policy quotes (vi) No turbine should cause demonstrable harm to the amenity of any residents. Therefore bearing in mind the accumulative noise effect of building possibly three wind farms in the same area. It is vital that No 17, 18 & 23 should be reviewed before allowing this development application to happen. Reasons being 1) They will add to the noise problem already existing and unresolved totally. 2) There are plenty of area to move them further back into the forest. 3) They could induce the visual effect and shadow flicker problem that many homes are bothered that are not in the mentioned category by the previous wind farm. 2) Access problem:- There is no logic for having two accesses so close to one another (170 metres from one to the other) These local people are still suffering from the Alltwallis wind farm construction and now are deeply worried that they are the ones that will have to endure more disturbances. The suffering from the first wind farm construction process have been 1) very loud vibration noise inside homes e.g. crockery & cutlery dropping onto the floor from dining room table. b) vibration noise inside sheds disturbing cattle and sheep. 2) Months of daily heavy lorries, machinery causing traffic disturbances 3) The A485 is not adequate to take such heavy load of traffic 4) Why should the same people have to endure this sort of nightmare again 5) It is totally absurd to have two accesses so close. This does not portray anything like a green project climate 6) Also a main road to the general hospital. Consideration to move the access should be given a high priority. – Go for it. We need to evolve as humans & oil, nuclear, gas, coal is not the way. – Which turbines will within each community council boundary? – 1) The most important matter is the noise from the turbines as the ones with stakraft turbines are affecting peoples lives at present. 2) Properties are much slower in selling and having to reduce prices to be able to sell properties. 3) Listen to local people as they are the ones who have to live with the turbines every day that they are up and running. – In a world of fast diminishing material resources it is obvious that there is a need for all farms of renewable energy including wind farms. However, this does not leave licence to destroy important landscape assets such as Brechfa Forest. These projects should be way offshore or in remote & sparcely populated areas. – No access signs for construction and service vehicles on all minor roads to and from site for the life time of the wind farm. Access road plan to made clear to all operators! – As a direct result of this proposal, I have withdrawn from purchasing a farm at Brechfa (Gwarallt). Also, I will be unable to continue flying my golden eagle within the forest. I have been flying her there for 10 years - but it will be too dangerous to continue to do so with the turbines. – I feel that the Brechfa Forest will be turned into a industrial waste land, where all bird life will be threatened, surrounding residences will suffer from the cumulative noise of 71 turbines in total. A blight on the landscape for a mere 25 years of operational life - which only works when its windy! – Question: Please Answer! In NTS point 29 (page5) - please identify which archaeological/historic side is the one exception where there WILL be significant direct impact……..Thank you! – Why a different access route then that of RES Bryn Llewellyn development - why not share access/borrow pits to reduce some of the physical impact. (on 2nd form - viewpoint4 Gwyddgrug - view c is missing (view B is duplicated) Brechfa Forest West Wind Farm Consultation Report 184

appendix a (cont…)

– Consultation on your proposed development has been an improvement on the attempts made by the developers of the Alltwallis wind farm who were less than economic with the truth and paid lip service to local concerns. We hope that RWE will listen. – RWE npower will receive more in subsidies than the output of turbines, justifies. In very cold weather (Jan + Dec 2010) wind produced miniscule amounts of energy - in fact turbines had to be kept turning to stop icing, so used energy - often imported from France! Many European countries are withdrawing subsidies because of inefficiency and decommissioned turbines are not being replaced. – 1. No exhibition of meeting held at Gwyddgrug village. Noise problems are still a problem here form Alltwallis wind farm why start on another wind farm so close to one another. Furthermore two accesses only 150yards from one to the other should not be in the same village. – Carmarthenshire County Council are looking at adopting a 1.5km buffer area in their local development plan (LDP). Having had the experience of living next to Alltwallis wind farm with turbines (110 metres) towering over us, the proposed turbines at 145 metres would be far too close. This is why we urge you to remove turbines 17,18+23 from the proposed plan. – onshore wind farms have not lived up to their promise. At most optimistic, they operate at 25% of capacity - the reality is closer to 8-10%. Considering their cost & their impact on an area, they cannot be justified & should not be allowed. – Having exhibitions for 3 wind farm proposals ongoing in very close succession was very confusing for local people, most of whom could not distinguish one proposed development and another. There should have been a bigger time separation between submission of these proposed developments to avoid confusion. – I have diversified to have a 4 star bunkhouse providing accommodation for groups of up to 32 people. Most of my guests come to the area to spend time in Brechfa Forest West. The area Npower plan to build this wind farm is the area of the forest my guests spend time on gentle walks or rides on their horses. I have three different businesses who book regularly book the accommodation to run boot camps, fitness training breaks, or triathlete training camps which include long walks, runs and cycle rides in Brechfa Forest West. Many of my guests book meals out at local pubs and purchase food from the community stores. Npowers claim that visitors to the area will simply go to other attractions is inaccurate. Tourists book accommodation based on how close it is to the activities they want to undertake during their stay. Many of my guests book my accommodation because they want to walk, cycle or ride in peaceful safety in Brechfa Forest West. I have put in a lot of time and effort to promote the property linked to the easy access into Brechfa Forest. Npowers assessment of the impact of the wind farm on the local economy is completely inaccurate. My business would not be viable should planning permission be granted and there are 4 other businesses in this area heavily dependant on my guests for their success. Npower claims that visitors to the area will simply go on RoW in the area instead. There are three footpaths near my property and no bridleways. Of the three footpaths, one is completely obstructed, one involves climbing over a barbed wire fence and struggling through an area of bog. Two different groups of guests have tried to use the third in the last month, both groups got lost even through they had a map with them. I moved to this area because I have horses and wanted to purchase a property with access to safe off road riding. I regularly ride in Brechfa Forest West, the siting of the turbines adjacent to the forest tracks means that the impact the wind farm would have on my personal life is high. I wish to make it clear that I have been disgusted by the way in which RWE Npower have failed to consult with the community. I have attended the community liaison Brechfa Forest West Wind Farm Consultation Report 185

appendix a (cont…)

group. I was amazed that RWE Npower considered it to be appropriate to open its consultation with the community by announcing that they had purchased the rights to build wind farms in Brechfa Forest and there was nothing the community could do to stop them. Having witnessed the farce RWE Npower turned the community liaison meetings into. Producing minutes so inaccurate that the first 90 minutes of the second meeting were taken up with community groups objecting to the way in which RWE Npower had tried to misrepresent them as supporting the development, I do not trust RWE Npower to accurately include the contents of this comments form in their planning application and have sent a copy directly to the IPC. I very strongly feel, that given the inaccuracy of the sections of the planning application I am knowledgeable about, tourism and recreation use of the forest. I whole heartedly support the community representatives who have insisted throughout the community liaison meetings that Npower should be required to provide funding for experts to advise the community on the accuracy of the technical impact assessments produced by Npower to support their planning application. I strongly recommend that the IPC reject this planning application until Npower have undertaken an level of consultation that is acceptable to the community and have corrected the planning application appropriately. RWE Npower consultation involves a 2 way dialog, and RWE Npower have treated the local community with such contempt that they have refused to listen to a word we have said. – RWE npower claim that users of the forest can simply use rights of way in the area instead. They were made aware that this is not the case for horse riders and cyclists from the start of the community consultation process. In the Rights of Way Improvement Plan (2007 – 2017) developed by the Local Access Forum and Carmarthenshire County Council under the CROW act, the lack of safe off road riding in Carmarthenshire was highlighted as a problem . Within Carmarthenshire 93.8% of the public Right of Way network are merely footpaths, available only to walkers. Where there is no safe off road riding, horse riders are forced to use sealed roads and routes where vehicles can create serious danger. In other counties in Wales this problem has been resolved through investment in the creation of networks of bridleways. However in the case of Carmarthenshire, the solution developed by Carmarthenshire County Council and documented in the Rights of Way Improvement Plan has been to focus equestrian use on the areas of open access land available to equestrians in the county, Brechfa Forest and Llanllwni Mountain form the principle area for off road riding in Carmarthenshire. The Rights of Way improvement plan also acknowledges that there has been a build up of obstruction problems on the ground. The performance Indicator Survey Results carried out by the National Assembly for Wales identified that only 30.6% of the Rights of Way network in Carmarthenshire was both open and signposted from the road. – The Government and Welsh Assembly’s obsession with wind power is very misleading and they do not consider the affects it has on the local residents’ quality of life. Wales should cease to be the dumping ground to provide electric across the border. Wales already produces enough electric for itself and we do not deserve to have our beautiful countryside ruined any more. I suggest RWE should build wind farms on politicians land NOT OURS. – Covered above. This form of planning process for such a massive project in a rural area makes a mockery of local resident consultation_. If the government feels this is the right way to steamroller through such developments, there is perhaps little local people can do, but long term resentment and the potential for legal actions if health issues arise , will be more likely after such a fiasco – Is our energy supply going to be free for all living in this area? – There will be more emissions caused by erecting these turbines than they ever hope to cut. White elephant springs to mind. Brechfa Forest West Wind Farm Consultation Report 186

appendix B

List of Prescribed Bodies

Consultee Contact Organisation The Welsh Ministers Welsh Assembly Government The relevant Regional Planning Body Welsh Assembly Government

The Health and Safety Executive HSE Inspector The Health and Safety Executive The relevant Strategic Health Authority Director of Estates and Hywel Dda Health Board Capital Planning

The relevant fire and rescue authority Station Manager Mid & West Wales Fire & Rescue Service

The relevant Police authority Deputy Head of Estates Dyfed-Powys Police The relevant parish council, or, where the Llanegwad Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Llanfihangel-ar-Arth Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Llanfihangel Rhos-Y-Corn Community application relates to land in Wales or Scotland Council the relevant community council

The relevant parish council, or, where the Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Llanllawddog Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Llanllwni Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Llanpumsaint Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Llansawel Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Llanybydder Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Community Council application relates to land in Wales or Scotland the relevant community council

The Environment Agency The Environment Agency The relevant Regional Development Agency Department of Economy and Transport Brechfa Forest West Wind Farm Consultation Report 187

appendix B (cont…)

The Equality and Human Rights Commission Head of Legal The Equality and Human Rights Commission

The Commission for Sustainable Development Sustainable Development Commission

Royal Commission of Ancient and Historical Emergency Recording Officer The Royal Commission on the Ancient Monuments of Wales and Historical Monuments of Wales

The Countryside Council for Wales The Countryside Council for Wales

The Civil Aviation Authority The Civil Aviation Authority The Highways Agency Area Manager South Wales Trunk Road Agency

The relevant Highways Authority Traffic Management & Carmarthenshire County Council Parking Services Manager

The Coal Authority Planning Manager The Coal Authority The Gas and Electricity Markets Authority Renewables Generation OFGEM Manager

The Water Service Regulation Authority Head of Climate Change OFWAT Policy The relevant waste regulation authority The Environment Agency

The relevant internal Drainage Board Welsh Water

The relevant local resilience forum Dyfed LRF Partnership Team The Forestry Commission Grants & Regulations Forestry Commission Wales S42(b) Local Authority within which site lies Development Control Officer Carmarthenshire County Council

Adjoining LPAs Head of Planning Pembrokeshire County Council Development Control Officer Ceredigion County Council

Specialist Services Manager Powys County Council

Head of Planning City & County of Swansea North Team Leader Neath Port Talbot County Borough Council Head of Planning Brecon Beacons National Park Authority

Development Management Pembrokeshire Coast National Park Authority

Additional from IPC Reg 9 list The relevant parish council, or, where the Clerk Llandysul Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Clerk Community Council application relates to land in Wales or Scotland the relevant community council Brechfa Forest West Wind Farm Consultation Report 188

appendix B (cont…)

The relevant parish council, or, where the Clerk Cynwyl Elfed Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Clerk Community Council application relates to land in Wales or Scotland the relevant community council

The relevant parish council, or, where the Clerk Abergwili Community Council application relates to land in Wales or Scotland the relevant community council

The Disabled Persons Transport Advisory DPTAC Committee

The British Waterways Board The British Waterways Board Health Protection Agency Health Protection Agency The Crown Estate Commissioners The Crown Estate Relevant Statutory Undertakers Ambulance Trusts Welsh Ambulance Service NHS Trust

Trusts in Wales Public Health Wales Mid and West Wales Region- Swansea Office

Water Transport British Waterways Board Civil Aviation Authority Civil Aviation Authority Licence Holder (Chapter 1 of Part 1 of Transport NATS En-route (NERL) Safeguarding Act 2000) Universal Service Provider Royal Mail Group Water and Sewage Undertakers Dwr Cymru Relevant Regional Development Agency Welsh Assembly Government Relevant Environment Agency The Environment Agency (South West Wales Office) Public Gas Transporter British Gas Pipelines Ltd Public Gas Transporter Energetics Electricity Ltd Public Gas Transporter Energetics Gas Ltd Public Gas Transporter ES Pipelines Ltd Public Gas Transporter ESP Connections Ltd Public Gas Transporter ESP Networks Ltd Public Gas Transporter Fulcrum Pipelines Ltd Public Gas Transporter GTC Pipelines Ltd Public Gas Transporter Independent Pipelines Ltd Public Gas Transporter Intoto Utilities Ltd Public Gas Transporter National Grid Gas Plc (NTS) Public Gas Transporter National Grid Gas Plc (RDN) Public Gas Transporter Quadrant Pipelines Ltd Public Gas Transporter Scotland Gas Networks Plc Brechfa Forest West Wind Farm Consultation Report 189

appendix B (cont…)

Public Gas Transporter Southern Gas Networks Plc Public Gas Transporter SP Gas Ltd Public Gas Transporter SSE Pipelines Ltd Public Gas Transporter The Gas Transportation Company Ltd Public Gas Transporter Utility Grid Installations Ltd Public Gas Transporter Wales & West Utilities Ltd Electricity Generators with CPO Powers Statkraft Wind UK Ltd Electricity Distributors with CPO Powers ECG (Distribution) Ltd Electricity Distributors with CPO Powers EDF Energy (IDNO) Ltd Electricity Distributors with CPO Powers Energetics Electricity Ltd Electricity Distributors with CPO Powers ESP Electricity Ltd Electricity Distributors with CPO Powers Independent Power Networds Ltd Electricity Distributors with CPO Powers The Electricity Network Company Ltd Electricity Distributors with CPO Powers Western Power Distribution (South Wales) plc

Electricity Transmitters with CPO Powers National Grid Non Prescribed Consultees Welsh Language Board Welsh Language Board CADW CADW SWWITCH SWWITCH Different addresses The Health & Safety Executive Hywel Dda Local Health Board Environment Agency The Equality and Human Rights Commission

The Sustainable Development Commission

Countryside Council for Wales Countryside Council for Wales Wales Resilience Form (pan-Wales Forum)

Forestry Commission (Wales) Brechfa Forest West Wind Farm Consultation Report 190

appendix C

Consultation letter - Section 42 consultees (sent 9th February 2011) Appendix C- Consultation letter- Section 42 consultees (sent 9th February 2011)

Your ref Our ref NRL/GW/007 Name Bethan Thomas Phone (01639) 816180 Fax (01639) 816051 E-Mail [email protected]

9th February 2011

Dear

Re: Proposed Brechfa Forest West Wind Farm

Proposed Application for development consent to construct and operate and wind farm within Brechfa Forest, Carmarthenshire. Planning Act 2008 (“the Act”)

The Infrastructure Planning (Applications: Prescribed Forms and Procedures) Regulations 2009 (“the APFP Regulations”)

The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (“the EIA Regulations”)

RWE Npower Renewables Limited constructs and operates wind farms in the UK and is proposing to build a wind farm comprising 28 wind turbines with a generating capacity of between 56 and 84 megawatts (MW). The proposed wind farm (to be known as Brechfa Forest West Wind Farm) is located within Brechfa Forest in Carmarthenshire. Because the generating capacity of the wind farm is over 50MW, an application for development consent is required to be made to the Infrastructure Planning Commission (“IPC”) under the provisions of the Act.

Under section 42 of the Act, and regulation 3 of and Schedule 1 to the APFP Regulations, RWE npower renewables is required to undertake consultation with a prescribed list of bodies, with host and neighbouring local authorities, and with those who have an interest in the land affected by the application.

The proposed application is “EIA development for the purposes of the EIA Regulations. This means that the proposed works constitute development for which an Environmental Impact Assessment is required, and the proposed application will therefore by accompanied by an Environmental Statement.

This also imposes additional consultation requirements, Firstly, regulation 11 of the EIA Regulations requires that RWE npower renewables must send to consultees a copy of the notice publicising the proposed application (that notice being a requirement of section 48 of the Act and regulation 4 of the APFP Regulations). Secondly, regulation 10 of the EIA regulations requires that RWE npower renewables must consult on “preliminary environmental information” about the proposed works.

250 Brechfa Forest West Wind Farm Consultation Report 191

appendix C (cont…)

Therefore in accordance with the requirement of the above process, RWE npower renewables is writing to consult on the proposed application. We enclose with this letter:

• A newsletter summarising the proposals (as sent to local homes and businesses in vicinity of the proposal); • A DVD containing the “preliminary environmental information” which, for the purposes of this consultation, is a full Draft Environmental Statement; • A non-technical summary of the Draft Environmental Statement (English and Welsh); • A Planning Statement setting out the planning policy context for the proposals (English and Welsh); and • A copy of the notice published in accordance with the requirements of Section 48 of the APFP Regulations, appearing in the Guardian, the London Gazette and Carmarthen Journal on Wednesday 9th February and in the Carmarthen Journal on Wednesday 16th February.

The documents listed above are available for download from our website: www.npower-renewables.com/brechfaforest. Nb, in the interest of the environment, we are attempting to minimise unnecessary use of paper, hence the full draft Environmental Statement is being provided in DVD format only.

Your comments on the proposed application are invited. These should be made in writing to: Post: Brechfa Forest West consultation RWE npower renewables Unit 22 Technium Sustainable Technologies Central Avenue Baglan Energy Park Port Talbot SA12 7AX Email: [email protected]

All responses must be received by 5pm on Wednesday 6th April.

RWE npower renewables requests that any response which you wish to make indicates who is making the response and provides an address to which any correspondence relating to the response may be sent. Please note that responses will be made public.

Please contact RWE npower renewables at the postal or email address above, or on the telephone number at the top of this letter if any of the documentation is not included with this letter, if you otherwise have any difficulties accessing it, or if you have any queries.

Yours sincerely Bethan Thomas Renewables Developer

251 Brechfa Forest West Wind Farm Consultation Report 192

appendix C (cont…)

Your ref Our ref NRL/GW/007 Name Bethan Thomas Phone (01639) 816180 Fax (01639) 816051 E-Mail [email protected]

9th Chwefror 2011

Annwyl ,

Yngylch: Fferm Wynt Arfaethedig Gorllewin Coedwig Brechfa

Cais Arfaethedig am ganiatâd ddatblygu i adeiladu a gweithredu fferm wynt o fewn Coedwig Brechfa, Sir Gaerfyrddin. Deddf Cynllunio 2008 ("y Ddeddf")

Cynllunio Seilwaith (Ceisiadau: Ffurfiau Rhagnodedig a Gweithdrefn) 2009 ("y Rheoliadau APFP")

Cynllunio Seilwaith (Asesu Effeithiau Amgylcheddol) 2009 ("Rheoliadau AEA")

Mae RWE npower renewables yn adeiladu a gweithredu ffermydd gwynt yn y DU ac yn bwriadu adeiladu fferm wynt yn cynnwys 28 tyrbin gwynt sy’n gallu gynhyrchu rhwng 56 a 84 megawat (MW). Bydd y fferm wynt arfaethedig (i’w hadnabod fel Fferm Wynt Gorllewin Coedwig Brechfa) yn cael ei leoli o fewn Coedwig Brechfa yn Sir Gaerfyrddin. Gan fydd y fferm gwynt y gallu gynhyrchu y dros 50 MW mae’n ofynnol bod y cais am ganiatâd datblygu yn cael ei wneud i’r Comisiwn Cynllunio Seilwaith (“CCS”) dan ddarpariaethau y Deddf 2008.

O dan adran 42 o'r Ddeddf, rheoliad 3 o, ac Atodlen 1 o'r Rheoliadau APFP, mae'n ofynnol bod RWE npower Renewables i ymgymryd ag ymgynghoriad gyda; rhestr rhagnodedig o gyrff ymgymghori, gyda awdurdodau lleol cyfagos, a chyda'r rheini sydd â diddordeb yn y tir a chaiff ei effeithio gan y cais.

Mae’r cais arfaethedig yn ‘ddatblygiad EIA’ at ddibenion Deddf Cynllunio Seilwaith (Asesu Effeithiau Amgylcheddol) 2009. Mae hyn yn golygu bod Asesiad o’r Effaith Amgylcheddol o effiathiau y cais arfaethedig yn ofynnol. Bydd y cais arfaethedig felly yn dod gyda Datganiad Amgylcheddol. Mae hyn hefyd yn gosod gofynion ymgynghori ychwanegol, Yn gyntaf, mae rheoliad 11 o Reoliadau AEA yn mynnu bod yn rhaid i RWE npower renewables anfon copi o hysbysiad sy’n rhoi cyhoeddusrwydd i'r cais arfaethedig at ymgyngoreion (mae’r hysbysiad hwn yn un o ofynion adran 48 o'r Ddeddf a rheoliad 4 o Reoliadau APFP). Yn ail, mae rheoliad 10 o'r rheoliadau AEA yn mynnu bod yn rhaid i RWE npower renewables yn ymgynghori ar "gwybodaeth ragarweiniol amgylcheddol" ynglyn a’r gwaith arfaethedig.

Felly, yn unol â gofynion y broses uchod, mae RWE npower renewables yn ysgrifennu atoch chi i ymgynghori ar y cais arfaethedig. Rydym yn amgáu gyda'r llythyr hwn:

253 Brechfa Forest West Wind Farm Consultation Report 193

appendix C (cont…)

• Cylchlythyr sydd yn crynhoi'r cynnig (sydd wedi ei hanfon i gartrefi a busnesau lleol yng nghyffiniau'r cynnig); • DVD sy'n cynnwys y "wybodaeth ragarweiniol amgylcheddol"sydd, sef Datganiad Amgylcheddol (drafft) at ddibenion yr ymgynghoriad hwn; • Crynodeb annhechnegol o'r Datganiad Amgylcheddol (Drafft) (Cymraeg a Saesneg); • Datganiad Cynllunio sy'n nodi'r cyd-destun polisi cynllunio ar gyfer y cynigion (Cymraeg a Saesneg); a • Copi o'r hysbysiad a gyhoeddir yn unol â gofynion Adran 48 o Reoliadau APFP, yn ymddangos yn y Guardian, y London Gazette ar Carmarthen Journal ar ddydd Mercher 9 Chwefror ac yn y Carmarthen Journal ar ddydd Mercher 16 Chwefror.

Mae’r dogfennau a restrir uchod ar gael i'w lawrlwytho oddi ar ein gwefan: www.npower-renewables.com/brechfaforest. Ds, er budd yr amgylchedd, yr ydym yn ceisio lleihau'r defnydd diangen o bapur, a dyna pam darprur y Datganiad Amgylcheddol (drafft) mewn ffurf DVD yn unig.

Rydym yn gwahodd eich sylwadau ar y cais arfaethedig. Dylai’r rhain gael eu gwneud yn ysgrifenedig at:

Post: Ymgynghoriad Coedwig Gorllewin Brechfa RWE npower renewables Uned 22 Technium Technolegau Cynaliadwy Central Avenue Parc Ynni Baglan Port Talbot SA12 7AX E-bost: [email protected]

Rhaid i’r holl ymatebion cael ei dderbyn erbyn 5yh ddydd Mercher 6ed o Ebrill 2011.

Mae RWE npower renewables yn gofyn bod unrhyw ymateb yr ydych yn dymuno gwneud yn nodi pwy sy’n gwneud yr ymateb ac yn rhoi manylion cyfeiriad lle mae unrhyw ohebiaeth sy’n ymwneud â’r ymateb yn cael ei anfon. Nodwch y bydd yr ymatebion ar gael i’r cyhoedd.

Cysylltwch â RWE npower renewables yn y cyfeiriad post, e-bost uchod, neu ar y rhif ffôn ar ben y llythyr hwn os; nad yw unrhyw un o'r ddogfennau wedi cael ei gynnwys gyda'r llythyr hwn, os ydych fel arall yn cael unrhyw anawsterau cael mynediad iddo, neu, os oes gennych unrhyw ymholiadau.

Yr eiddoch yn gywir

Bethan Thomas Datblyggydd Ynni Adnewyddadwy

254 Brechfa Forest West Wind Farm Consultation Report 194

appendix d

Appendix D- Consultation letter- Section 42 consultees (sent 16th ConsultationF eletterbruary 2- 011Secti) on 42 consultees (sent 16th February 2011)

Your ref Our ref NRL/GW/010 Name Bethan Thomas Phone (01639) 816180 Fax (01639) 816051 E-Mail [email protected]

16th February 2011

Dear

Re: Proposed Brechfa Forest West Wind Farm

Proposed Application for development consent to construct and operate and wind farm within Brechfa Forest, Carmarthenshire. Planning Act 2008 (“the Act”)

The Infrastructure Planning (Applications: Prescribed Forms and Procedures) Regulations 2009 (“the APFP Regulations”)

The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (“the EIA Regulations”)

RWE Npower Renewables Limited constructs and operates wind farms in the UK and is proposing to build a wind farm comprising 28 wind turbines with a generating capacity of between 56 and 84 megawatts (MW). The proposed wind farm (to be known as Brechfa Forest West Wind Farm) is located within Brechfa Forest in Carmarthenshire. Because the generating capacity of the wind farm is over 50MW, an application for development consent is required to be made to the Infrastructure Planning Commission (“IPC”) under the provisions of the Act.

Under section 42 of the Act, and regulation 3 of and Schedule 1 to the APFP Regulations, RWE npower renewables is required to undertake consultation with a prescribed list of bodies, with host and neighbouring local authorities, and with those who have an interest in the land affected by the application.

I understand that you have recently received correspondence from the IPC under Regulation 9 (1)(a) of the EIA Regulations. Please note that I have previously written to your colleague regarding this consultation. I am writing additionally to you as this is the address that has been provided to me by the IPC

The proposed application is “EIA development for the purposes of the EIA Regulations. This means that the proposed works constitute development for which an Environmental Impact Assessment is required, and the proposed application will therefore by accompanied by an Environmental Statement.

255 Brechfa Forest West Wind Farm Consultation Report 195

appendix d (CONT…)

This also imposes additional consultation requirements, Firstly, regulation 11 of the EIA Regulations requires that RWE npower renewables must send to consultees a copy of the notice publicising the proposed application (that notice being a requirement of section 48 of the Act and regulation 4 of the APFP Regulations). Secondly, regulation 10 of the EIA regulations requires that RWE npower renewables must consult on “preliminary environmental information” about the proposed works.

Therefore in accordance with the requirement of the above process, RWE npower renewables is writing to consult on the proposed application. We enclose with this letter:

• A copy of the notice published in accordance with the requirements of Section 48 of the APFP Regulations, appearing in the Guardian, the London Gazette and Carmarthen Journal on Wednesday 9th February and in the Carmarthen Journal on Wednesday 16th February.

A full set of consultation documents, including the ‘Preliminary Environmental Information’ are available for download from our website: www.npower- renewables.com/brechfaforest.

Your comments on the proposed application are invited. These should be made in writing to: Post: Brechfa Forest West consultation RWE npower renewables Unit 22 Technium Sustainable Technologies Central Avenue Baglan Energy Park Port Talbot SA12 7AX Email: [email protected]

All responses must be received by 5pm on Wednesday 6th April.

RWE npower renewables requests that any response which you wish to make indicates who is making the response and provides an address to which any correspondence relating to the response may be sent. Please note that responses will be made public.

Please contact RWE npower renewables at the postal or email address above, or on the telephone number at the top of this letter if any of the documentation is not included with this letter, if you otherwise have any difficulties accessing it, or if you have any queries.

Yours sincerely

Bethan Thomas Renewables Developer

256 Brechfa Forest West Wind Farm Consultation Report 196

APPENDIX E

Chaser letterAppendix - Secti oE-n Chaser 42 co letternsultees- Section 42 consultees

Your ref Our ref NRL/GW/014 Name Bethan Thomas Phone (01639) 816180 Fax (01639) 816051 E-Mail [email protected]

21 March 2011

Dear,

Re: Proposed Brechfa Forest West Wind Farm

Proposed Application for development consent to construct and operate a wind farm within Brechfa Forest, Carmarthenshire. Planning Act 2008 (“the Act”)

I am writing to remind you that further to my earlier letter (reference NRL/GW/007), you are invited to provide comments on the proposed application for the Brechfa Forest West Wind Farm.

These should be made in writing to: Post: Brechfa Forest West consultation RWE npower renewables Unit 22 Technium Sustainable Technologies Central Avenue Baglan Energy Park Port Talbot SA12 7AX Email: [email protected]

All responses must be received by 5pm on Wednesday 6 April. Please note that, in accordance with Section 49 of the Act, a response that is not received by the deadline will not be considered a ‘relevant response’.

RWE npower renewables requests that any response which you wish to make indicates who is making the response and provides an address to which any correspondence relating to the response may be sent. Please note that responses will be made public.

Yours sincerely

Bethan Thomas Renewables Developer

257 Brechfa Forest West Wind Farm Consultation Report 197

Appendix E (cont…)

Eich cyf Ein cyf NRL/GW/014 Enw Bethan Thomas Ffôn (01639) 816180 Ffacs (01639) 816051 E-bost [email protected]

21 Mawrth 2011

Annwyl,

Yngylch: Fferm Wynt Arfaethedig Gorllewin Coedwig Brechfa

Cais y bwriedir ei wneud am gydsyniad datblygu i adeiladu a gweithredu fferm wynt yng Nghoedwig Brechfa, Sir Gaerfyrddin. Deddf Cynllunio 2008 ("y Ddeddf")

Rwy’n ysgrifennu i’ch atgoffa, yn dilyn y llythyr a anfonais atoch o’r blaen (cyfeirnod NRL/GW/007), bod gwahoddiad i chi gynnig sylwadau ar y cais y bwriedir ei wneud i ddatblygu Fferm Wynt Gorllewin Coedwig Brechfa.

Dylai’r sylwadau gael eu gwneud yn ysgrifenedig:

Post: Ymgynghoriad Gorllewin Coedwig Brechfa RWE npower renewables Uned 22 Technium Technolegau Cynaliadwy Central Avenue Parc Ynni Baglan Port Talbot SA12 7AX E-bost: [email protected]

Rhaid i bob ymateb gyrraedd erbyn 5pm ar ddydd Mercher 6 Ebrill. Sylwch: yn unol ag Adran 49 o’r Ddeddf, os na fydd ymateb yn cyrraedd erbyn yr amser hwnnw, ni fydd yn cael ei gyfrif yn ‘ymateb perthnasol’.

Mae RWE npower renewables yn gofyn bod unrhyw ymateb yr ydych yn dymuno’i wneud yn nodi pwy sy’n gwneud yr ymateb ac yn rhoi cyfeiriad lle gellir anfon gohebiaeth yn ymwneud â’r ymateb. Bydd yr ymatebion ar gael i’r cyhoedd.

Yr eiddoch yn gywir

Bethan Thomas Datblygwr Prosiectau Ynni Adnewyddadwy

258 Brechfa Forest West Wind Farm Consultation Report 198

APPENDIX F

Noise letter sent to Carmarthenshire County Council in response to comments

Direct: 01454 889 120

Email: [email protected]

110810-LET-1004014-MMC-2.doc

10 August 2011

Bethan Thomas RWE Npower Renewables Limited Auckland House, Lydiard Fields Business Park Great Western Way, Swindon, Wiltshire, SN5 8ZT

Dear Bethan,

RE: Brechfa Forest West Wind Farm – operational noise

The potential impacts of noise resulting from the construction and operation of the Brechfa Forest West Wind Farm were assessed in Chapter 16 of the Environmental Statement (ES) for the Development, which was prepared by Hoare Lea Acoustics on behalf of RWE Npower Renewables Ltd (RWE NRL).

In a meeting on the 20th May 2011 at Carmarthenshire County Council’s (CCC) offices, the comments from CCC and their appointed noise consultant, as stated in CCC’s Section 42 consultation response, were discussed. The present letter provides additional information as requested in this meeting.

Sample calculations

CCC requested that example details of the calculation of predicted noise levels be presented. Appendix A of this letter presents the details of the calculation for the property of Cerbynau identified in the ES. Appendix A details the calculated attenuation factors according to the ISO 9613-2 standard and using the parameters specified in section 16.32, and with the screening parameters indicated in Appendix 16.7, of the ES. These results can be compared with the predictions of Table 16.8 of the ES. Some example ground contours used to determine the terrain screening parameters are also shown. More information can be provided to CCC on request.

Site wind masts

The baseline noise surveys presented in the ES were related to wind speeds measured on a 70m high anemometer mast located slightly towards the south of the site (Easting / Northing 248442 / 231079): mast “A”. This mast was installed in June 2009. Another mast was present on site, having been installed further North (Easting / Northing 249149 / 234183) in early 2006: mast “G1”. Although mast G1 had been refurbished in 2009, we were advised that it would be preferable to rely on the more recently installed mast (A), as it was likely to be more reliable.

A subsequent analysis was undertaken by a specialist consultant of 10 months of data at mast A and several years for mast G1, and found an excellent correlation between the two. This can be illustrated by the resulting wind roses for each mast shown in Figure 1 below, which are very similar. This wind rose analysis shows a clear dominance of south-westerly winds at the area of Brechfa Forest West, which is typical of most sites in the UK.

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APPENDIX F (CONT…)

Figure 1 – wind rose derived on two met masts located on the Brechfa West site

Partial noise limits – general considerations.

The aim of ETSU-R-97 when dealing with cumulative noise impacts is that the limits derived for a noise sensitive receptor should apply to all wind farm noise:

‘The Noise Working Group is of the opinion that absolute noise limits and margins above background should relate to the cumulative effect of all wind turbines in the area which contribute to the noise received at the properties in question.’

Therefore, the noise limits which were considered in the ES for the Brechfa Forest West Wind Farm, as applicable at each receptor when considering the total predicted cumulative noise from all turbines. But it does not necessarily follow that these are the limits that should apply to the Brechfa Forest West development alone, and when considering this development in isolation, lower “partial” limits may be more appropriate in some cases where cumulative operational noise becomes a significant consideration.

Partial noise limits – Bryn Llywelyn (developed by RES Ltd)

For the locations situated in relative proximity to both the proposed Brechfa Forest West and Bryn Llywelyn wind farms, similar individual limits can be derived. The proposed approach is to undertake an apportionment process: separating the noise limit between the two developments in proportion to the predicted contribution of each wind farm. Brechfa Forest West Wind Farm Consultation Report 200

APPENDIX F (CONT…)

Figure 1 – apportioned noise limits – Ffynnon Las – day-time periods

This is illustrated in Figure 1 above for the property of Ffynnon Las. At this property, the energy proportion of the predicted noise levels is 53% and 47% for the RES scheme (Bryn Llywelyn) and the RWE NRL scheme (Brechfa Forest West) respectively, at 8m/s. The total noise limit (shown in red) can therefore be apportioned between the two developments in relation to these proportions, with reductions of 2 to 4 dB(A) from the total ETSU-R-97 limit derived. The resulting partial noise limits for the Brechfa Forest West Wind farm, at Ffynnon Las and other locations closest to the Bryn Llywelyn development, are presented in Appendix B to this letter.

By controlling the noise emissions from the Brechfa Forest West Wind Farm to the proposed partial limits at these locations will mean that the total noise from all wind turbines would not exceed the derived total noise limits, assuming that the Bryn Llywelyn controls its noise emissions similarly and that both developments be consented and built. In addition, directional effects, which are considered below, will provide a further margin of conservatism. At other locations situated further away, the influence of the Bryn Llywelyn is unlikely to be significant and the limits derived are considered relevant.

Partial noise limits – Alltwalis

For the assessment locations closest to the Alltwalis Wind Farm, similar considerations apply as for Bryn Llywelyn, but with some differences. These locations were assessed as part of the impact study for the Alltwalis Wind Farm, and following consent for this development, noise limits were set at these locations, which apply to the total noise from all wind farms, and this will include the contribution from Brechfa Forest West Wind Farm. Similar

The wind speed reference used to derive the limits specified in the consent for the Alltwalis Wind Farm was queried, and CCC highlighted the importance of the consistence of wind speed references when considering consent conditions. We understand that the wind speeds against which the background noise data in the original survey were correlated were derived from wind speeds at 30 m height and “standardised” to 10 m height assuming reference conditions. The consent conditions for Alltwalis also make reference to a site wind speed measured at 10m height. Either approach would be inconsistent with the one used in the assessment for Brechfa Forest West, where site wind speeds were derived at hub height on the wind farm site and “standardised” at 10m height using reference corrections.

With the appropriate data, it may be possible to derive alternative limits for Alltwalis Wind Farm using this alternative (and preferred) method. Such a change to a “standardised” wind speed reference would not change the measured noise levels, but the corresponding wind speed (for each measurement point) would tend to be higher in conditions of higher than standard wind shear. This would mean that the increase of noise levels with wind speed would occur at higher wind speeds, and such a change would effectively “shift” the

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APPENDIX F (CONT…)

measured baseline levels curve (and therefore the limits) to higher wind speeds by a certain amount (say 1 to 2 m/s). Figures 21 to 26 of Appendix 16.5 of the ES illustrate the results of these measurements around Alltwalis. By examining these figures, the effect of such a shift to the noise limits can be estimated, and this suggests the overall conclusions of the cumulative assessment would not be affected. CCC was queried on whether the operator of Alltwalis could provide this revised information, with no success at present. CCC or their appointed consultant may be able to provide confirmation in this regard.

When considering partial limits for Brechfa Forest West only, at the locations closest to Alltwalis, using limits derived from the Brechfa Forest West Wind Farm surveys, at suitably representative locations, may be more appropriate. As they were derived using tall height measurements, this would remove a potential inconsistency in consent conditions. In fact, the measurements undertaken at the location of Cerbynau, which was situated in a relatively sheltered valley and further filtered for a particular range of wind directions, resulted in a derived noise limit of 40dB(A) and 43dB(A) respectively for day-time and night-time periods.

For example, Figure 2 below shows predicted noise levels for both developments at the location of Gellifelen, which was highlighted in CCC’s response. This illustrates, as shown in the ES for the Brechfa Forest West Wind Farm, that the Alltwalis Wind Farm would represent the dominant contribution to noise levels at these locations. The imposition of such a more conservative limit is therefore likely to control the noise emissions from Brechfa Forest West in such a way that the latter would be unlikely to cause the total noise at these locations to increase beyond the consented (cumulative) limits, particularly as the noise emissions from Brechfa Forest West could not increase significantly above the predicted levels shown without a risk of exceeding the applicable at other, closer properties. Notwithstanding these considerations, CCC may wish to impose limits 3dB lower than those derived at Cerbynau, 37dB(A) and 40dB(A) respectively for day-time and night-time periods, as this would impose further stricter control which Brechfa Forest West is also likely to comply with: this is also illustrated in Figure 2, and detailed in Appendix C.

Figure 2 – Predicted noise levels and limits – Gellifelen – day-time periods

A summary of the noise limits applicable to Brechfa Forest West as proposed in this letter is outline in Appendix C for ease of reference.

Directional analysis

As noted in the ES, although all predictions assumed simultaneous downwind propagation from all turbines, many locations are unlikely to be downwind of all of them simultaneously. For these locations, the contribution to overall levels would be smaller for turbines which are downwind of the property compared to those turbines which are upwind, for a given wind direction. To illustrate expected directional effects in such situations, further detailed modelling was undertaken to include assumed directivity effects for the noise radiation from each turbine: ranging from 0dB downwind of a turbine to -10dB upwind. The assumed directivity effects are Brechfa Forest West Wind Farm Consultation Report 202

APPENDIX F (CONT…)

considered conservative. The results of these calculations are shown below for a key wind speed of 8m/. These charts indicate how noise immission levels from the different groups of turbines at a specified receptor will change as the wind direction changes.

Figure 3 – Directional analysis – Ffynnon Las – prediction at 8m/s (standardised wind speed)

Figure 3 shows predicted noise levels for Ffynnon Las, including these estimated directional effects, as a function of wind direction but at a fixed wind speed of 8m/s. This shows that, for most wind directions, and particularly in the dominant south-westerly winds, the levels at this location would be 2 to 5dB(A) lower than the level of 39.6dB(A) predicted assuming simultaneous downwind propagation from all turbines.

The same analysis is presented in Figure 4 for the location of Gellifelen. This shows that the predicted contribution of the Alltwalis wind farm would be dominant in most cases, with a contribution from Brechfa Forest West becoming apparent mainly in easterly winds, which are not dominant at the site (see Figure 1).

Similar results are obtained at nearby locations, and results could be supplied to CCC on their request. Reference was made by CCC that the consideration of the cumulative impact of several wind farms be considered when considering in particular the derivation of the fixed part of the limit during the daytime within the range from 35 dB(A) to 40 dB(A), for which duration of exposure is one of the relevant criteria. Based on the results above and the assessment presented in the ES and represented graphically in Appendix 16.5: for the properties where the application of the chosen 40dBA limit is most relevant to the predicted compliance with the noise limits, the Brechfa Forest West Wind Farm was dominant and the locations were not exposed to significant additional cumulative noise from the other developments considered.

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APPENDIX F (CONT…)

Figure 4 – Directional analysis – Gellifelen – prediction at 8m/s (standardised wind speed)

Amplitude modulation

ETSU-R-97 suggests that a certain level of amplitude/aerodynamic modulation (AM) should be considered typical of the characteristics of wind turbine noise. The methodology formulated in ETSU-R-97 therefore does not propose any additional penalty for the presence of AM. The mechanisms/circumstances that may give rise to increased levels of AM is not well understood and the potential for increased levels of AM to be present cannot be predicted, but the likelihood is low based on the experience of other operating wind farms.

Based on the current state of knowledge, it is not appropriate to formulate a sufficiently precise condition which objectively applies a penalty to control the potential for increased levels of AM. The most appropriate way of dealing with the potential for increased levels of AM, should it occur, is by way of nuisance action.

RWE NRL have indicated that they will not apply for immunity from Statutory Nuisance relating to operational noise in their application.

I trust the above is sufficiently clear, but if you have any queries regarding this letter please do not hesitate to contact me.

Yours sincerely,

For and on behalf of Hoare Lea Acoustics

Matthew Cand Executive Engineer

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APPENDIX F (CONT…)

APPENDIX A – CALCULATION EXAMPLE

Location 26 – Cerbynau

Calc. Ground Name Easting Northing height Height Cerbynau 249953 230245 4 164

Hub Ground Terrain Partial level, Turbine Easting Northing Height Height correction LA90 at 8m/s 1 246753 231322 100 288 2 15.0 2 247319 231337 100 305 2 16.9 3 247049 232133 100 315 2 14.7 4 247347 231780 100 322 2 16.2 5 247865 231357 100 310 2 19.3 6 248004 231019 100 298 2 20.7 7 248209 230683 100 285 2 22.6 8 247780 232510 100 328 2 15.7 9 247885 232140 100 318 2 17.1 10 247986 231773 100 299 2 18.6 11 248456 231506 100 289 2 21.6 12 248684 231065 100 289 2 24.6* 13 248261 233094 100 349 2 15.2 14 248524 232673 100 321 2 17.1 15 248695 232320 100 304 -3 23.9 16 249110 231992 100 306 -3 26.7 17 248322 234134 100 341 0 14.5 18 248210 233713 100 342 0 15.4 19 248638 233537 100 324 0 16.4 20 248899 233213 100 322 0 17.7 21 249096 232723 100 320 0 20.0 22 249331 232414 100 309 0 21.8 23 248909 234382 100 341 2 12.4 24 249274 234198 100 323 2 13.1 25 249460 233566 100 314 2 15.0 26 249424 233163 100 311 0 18.5 27 249734 232835 100 307 0 20.1 28 249974 233494 100 300 2 15.4

Total LA90 at 8m/s 34.2

*See worked example below

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APPENDIX F (CONT…)

ISO 9613-2 attenuation factors: Adiv+Aatm+Agnd Turbine 63Hz 125Hz 250Hz 500Hz 1kHz 2kHz 4kHz 8kHz 1 78.8 83.4 84.5 86.5 92.4 112.7 190.8 475.3 2 77.5 81.8 82.6 84.2 89.1 106.3 172.4 412.9 3 78.9 83.6 84.8 86.9 92.9 113.7 193.9 485.9 4 78.0 82.4 83.3 85.0 90.2 108.5 178.6 433.7 5 75.8 80.0 80.5 81.6 85.7 100.0 154.9 354.9 6 74.7 78.9 79.2 80.1 83.7 96.4 145.1 322.5 7 73.4 77.4 77.6 78.2 81.3 92.2 134.0 286.3 8 78.3 82.8 83.8 85.5 91.0 109.9 182.6 447.4 9 77.3 81.7 82.5 83.9 88.8 105.7 170.7 407.5 10 76.3 80.5 81.1 82.3 86.6 101.6 159.4 369.7 11 74.1 78.2 78.5 79.2 82.6 94.4 139.9 305.5 12 71.9 75.8 75.8 76.1 78.8 87.9 123.2 251.6 13 78.7 83.2 84.3 86.3 92.0 112.0 188.8 468.4 14 77.4 81.7 82.5 84.0 88.9 105.9 171.2 409.0 15 76.0 80.3 80.8 81.9 86.2 100.8 157.1 362.1 16 74.1 78.1 78.4 79.1 82.5 94.2 139.3 303.6 17 80.3 85.4 87.1 89.8 97.1 122.5 220.1 575.4 18 79.7 84.6 86.1 88.5 95.2 118.6 208.5 535.6 19 79.1 83.8 85.1 87.2 93.3 114.7 196.7 495.6 20 78.3 82.8 83.8 85.6 91.0 110.0 183.0 448.6 21 76.7 81.0 81.7 83.0 87.6 103.4 164.2 385.7 22 75.4 79.6 80.0 81.0 84.9 98.5 151.0 341.7 23 80.3 85.5 87.2 90.0 97.4 123.0 221.8 581.2 24 79.9 84.9 86.5 89.0 96.0 120.1 212.9 550.8 25 78.7 83.3 84.5 86.4 92.2 112.5 190.2 473.2 26 77.8 82.2 83.1 84.7 89.9 107.7 176.4 426.6 27 76.7 80.9 81.6 82.9 87.4 103.1 163.3 382.8 28 78.5 83.1 84.1 86.0 91.6 111.2 186.4 460.3

Worked example – turbine 12 at Cerbynau Turbine 12 63Hz 125Hz 250Hz 500Hz 1kHz 2kHz 4kHz 8kHz dB(A) Reference spectra 91.1 93.1 95.8 98.1 100.6 99.8 95.9 85.6 105.9 Spectra at 8m/s 92.2 94.2 96.9 99.2 101.7 100.9 97.0 86.7 107.0 ISO 9613 attenuation -71.9 -75.8 -75.8 -76.1 -78.8 -87.9 -123.2 -251.6 Terrain attenuation -2 -2 -2 -2 -2 -2 -2 -2

LAeq level 18.3 16.4 19.1 21.1 20.9 11.0 -28.2 -166.9 26.6

LA90 level 16.3 14.4 17.1 19.1 18.9 9.0 -30.2 -168.9 24.6

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APPENDIX F (CONT…)

Ground contour plot example: between turbine 16 and Cerbynau

Ground contour plot example: between turbine 16 and Cerbynau

In the above, the blue line is the line of sight to the turbine hub and the green one is the line of sight to the tip.

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APPENDIX F (CONT…)

APPENDIX B – PARTIAL NOISE LIMITS APPLICABLE TO THE BRECHFA FOREST WEST WIND FARM FOR LOCATIONS SITUATED CLOSE TO THE PROPOSED BRYN LLYWELYN WIND FARM

Between 07:00 and 23:00 - Noise level dB LA90, 10-minute Standardised wind speed at 10 meter height (m/s) Location 1 2 3 4 5 6 7 8 9 10 11 12 Ffynnon-Las 36.4 36.4 36.4 36.4 36.4 36.3 37.1 41.1 45.9 49.4 49.4 49.5 Blaen-nant-gwyn 34.1 34.1 34.1 34.1 34.1 35.1 37.7 40.6 43.6 45.3 45.2 45.4 Salach 37.9 37.9 37.9 37.9 37.9 37.9 38.6 42.6 47.4 51.2 51.2 51.3 Hafod 35.9 35.9 35.9 35.9 35.9 35.8 36.1 37.6 40.7 42.5 44.2 44.9 Tirlan 34.2 34.2 34.2 34.2 34.2 34.1 34.5 36.0 39.1 40.7 42.4 43.0

Between 23:00 and 07:00 - Noise level dB LA90, 10-minute Standardised wind speed at 10 meter height (m/s) Location 1 2 3 4 5 6 7 8 9 10 11 12 Ffynnon-Las 39.4 39.4 39.4 39.4 39.4 39.3 39.6 39.7 45.2 50.6 50.5 50.6 Blaen-nant-gwyn 37.1 37.1 37.1 37.1 37.1 37.0 37.4 39.8 44.0 45.7 45.6 45.7 Salach 40.9 40.9 40.9 40.9 40.9 40.9 41.1 41.1 46.7 52.3 52.3 52.4 Hafod 38.9 38.9 38.9 38.9 38.9 38.8 39.1 39.2 39.0 41.1 44.3 47.6 Tirlan 37.2 37.2 37.2 37.2 37.2 37.1 37.5 37.6 37.4 39.2 42.5 45.8

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APPENDIX F (CONT…)

APPENDIX C – SUMMARY OF DERIVED PARTIAL NOISE LIMITS APPLICABLE TO THE BRECHFA FOREST WEST WIND FARM

Between 07:00 and 23:00 - Noise level dB LA90, 10-minute Standardised wind speed at 10 meter height (m/s) Location 1 2 3 4 5 6 7 8 9 10 11 12 Lan-Clyn-Adda 40.0 40.0 40.0 40.0 40.0 40.0 40.8 43.0 45.6 47.8 47.8 47.8 Bryngwili 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 42.1 45.2 45.2 45.2 Cwm Llydan Ganol 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 42.1 45.2 45.2 45.2 Cwmllydan Isaf 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 42.1 45.2 45.2 45.2 Tyllwyd 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 42.1 45.2 45.2 45.2 Cwmere 40.0 40.0 40.0 40.0 40.0 40.0 40.8 43.0 45.6 47.8 47.8 47.8 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 Gilfach Meredydd 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 Cae'r-blaidd 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.1 44.9 49.1 49.1 49.1 Ffynnon-Las 36.4 36.4 36.4 36.4 36.4 36.3 37.1 41.1 45.9 49.4 49.4 53.8 Blaen-nant-gwyn 34.1 34.1 34.1 34.1 34.1 35.1 37.7 40.6 43.6 45.3 45.2 52.1 Blaen-Gwyddgrug 40.0 40.0 40.0 40.0 40.0 40.0 40.8 43.9 47.0 48.6 48.6 48.6 Gellifelen 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* Pen 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* Salach 37.9 37.9 37.9 37.9 37.9 37.9 38.6 42.6 47.4 51.2 51.2 53.8 Hafod 35.9 35.9 35.9 35.9 35.9 35.8 36.1 37.6 40.7 42.5 44.2 49.7 Tirlan 34.2 34.2 34.2 34.2 34.2 34.1 34.5 36.0 39.1 40.7 42.4 49.7 Cwmyronnen Uchaf 40.0 40.0 40.0 40.0 40.0 40.0 40.8 43.0 45.6 47.8 47.8 47.8 Llwynteg 40.0 40.0 40.0 40.0 40.0 40.0 40.8 43.0 45.6 47.8 47.8 47.8 Lan Farm 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* Blaengwen Farm 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* Foel-y-ddafad-ddu 40.0 40.0 40.0 40.0 40.0 40.0 40.8 43.9 47.0 48.6 48.6 48.6 Coedlannnau Fawr 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* 40* Lan-ddu 40.0 40.0 40.0 40.0 40.0 40.0 40.8 43.9 47.0 48.6 48.6 48.6 Clyn Mawr 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 Cerbynau 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 40.0 Bryngolau 40.0 40.0 40.0 40.0 40.0 40.0 40.8 43.9 47.0 48.6 48.6 48.6 *This could be reduced by 3dB to 37dB(A) to provide additional protection

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APPENDIX F (CONT…)

Between 23:00 and 07:00 - Noise level dB LA90, 10-minute Standardised wind speed at 10 meter height (m/s) Location 1 2 3 4 5 6 7 8 9 10 11 12 Lan-Clyn-Adda 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.9 46.3 46.3 46.3 Bryngwili 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 45.1 47.7 47.7 Cwm Llydan Ganol 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 45.1 47.7 47.7 Cwmllydan Isaf 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 45.1 47.7 47.7 Tyllwyd 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 45.1 47.7 47.7 Cwmere 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.9 46.3 46.3 46.3 Ystrad 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 Gilfach Meredydd 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 Cae'r-blaidd 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.3 44.6 44.6 44.6 Ffynnon-Las 39.4 39.4 39.4 39.4 39.4 39.3 39.6 39.7 45.2 50.6 50.5 54.9 Blaen-nant-gwyn 37.1 37.1 37.1 37.1 37.1 37.0 37.4 39.8 44.0 45.7 45.6 52.5 Blaen-Gwyddgrug 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.9 45.6 46.0 46.0 Gellifelen 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* Pen Llwydcoed 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* Salach 40.9 40.9 40.9 40.9 40.9 40.9 41.1 41.1 46.7 52.3 52.3 54.9 Hafod 38.9 38.9 38.9 38.9 38.9 38.8 39.1 39.2 39.0 41.1 44.3 52.4 Tirlan 37.2 37.2 37.2 37.2 37.2 37.1 37.5 37.6 37.4 39.2 42.5 52.4 Cwmyronnen Uchaf 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.9 46.3 46.3 46.3 Llwynteg 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.9 46.3 46.3 46.3 Lan Farm 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* Blaengwen Farm 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* Foel-y-ddafad-ddu 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.9 45.6 46.0 46.0 Coedlannnau Fawr 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* 43* Lan-ddu 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.9 45.6 46.0 46.0 Clyn Mawr 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 Cerbynau 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 Bryngolau 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.0 43.9 45.6 46.0 46.0 *This could be reduced by 3dB to 40dB(A) to provide additional protection

Brechfa Forest West Wind Farm Consultation Report 210

Appendix g

Meeting minutes - statutory consultee meetings during and after consultation period

Brechfa Forest West Wind Farms Meeting 30th March 2011

RWE npower renewables Bethan Thomas Tabitha Fowler

CCW Huw Williams Nia Phillips Stuart Rowden Karen Maddock-Jones

Forestry Commission Wales Steven Pocock Andrew Maberly-Jones

Introduction Bethan Thomas reiterated that all consultation responses needed to be received by 5pm on the 6th April and that NRL will respond in full after the close of consultation. Bethan Thomas stated that this meeting was to discuss issues but no commitments would be made. Bethan Thomas gave an update on Brechfa Forest West consultation, including numbers of exhibitions and responses.

Alternative Access- Dry runs and the Transport Management Plan: Nia Phillips asked whether NRL have done a dry run as CCW are concerned that it may not be possible. These arise from a vehicle on the dry run for Alltwalis getting stuck on a bump. Bethan Thomas confirmed that we have not done a dry run as the majority of the route has been used to transport abnormal loads for Alltwalis. Computer modelling has been used to check that the access route is feasible. A longer blade than that used at Alltwalis is likely to be used and this was modelled for. Bethan Thomas confirmed that the maximum height of the turbines for this planning application is 145m to tip. Bethan Thomas explained that the worst case had been used for each of the assessments, e.g. the tallest turbine for visual impact and the noisiest turbine for the noise assessment. Nia Phillips requested a copy of the Transport Management Plan. Bethan Thomas confirmed that any road widening required would not be included in this application as it would be classed as associated development. It would therefore require a separate application should it be required. Brechfa Forest West Wind Farm Consultation Report 211

Appendix g (cont…)

Nia Phillips raised concerns over the visual impact of the access track running parallel to the access track for the Alltwalis wind farm. Concerns were also raised about the carbon footprint of a new track. Bethan Thomas explained that currently the Alltwalis access track is not an option due to ongoing legal issues between the land owner and the existing wind farm operator in the area. Nia Phillips raised concerns over the probability of the Bryn Llywelyn scheme creating another new access track. Bethan Thomas explained that this option was considered by us but was rejected due to the hedgerows, gradients and village. The current access track proposed was assessed and considered to have the least environmental impact.

Bethan Thomas will have another look at the access proposed by RES now that the ES is available. Nia Phillips suggested that if the current access proposed were to be used then a possible mitigation for L&V would be to plant close to the forest on both sides of the access track. This will be outlined in their consultation response. Andrew Maberly Jones suggested dropping the level of the road to mitigate L&V. Steven Pocock raised a question about a possible S106 over the area close to the forest through which the access track runs. Bethan Thomas confirmed that this was the case and that the S106 is in place to reduce grazing on that area of land and that approximately 600m of our track runs through this section of land. Huw Williams suggested that possible mitigation for this would be to provide an area of similar size and quality as a replacement for that being taken out of the S106. Huw Williams raised the possibility of RES and NRL sharing access.

Public Access Management plan is being drawn up for East which may feed into West. Nia Phillips to contact Rosie Carmichael to request that the access maps and the report outlining the usage of forestry by recreational users be forwarded to NRL to assist in drawing up an access management plan. Nia Phillips highlighted that East and West may be constructed simultaneously and requested a cumulative assessment for recreation based on this. Bethan Thomas highlighted that the biggest issue will be communication especially with the recreational users that are not part of recreational groups. This will be an important consideration when drawing up the access management plan. We would like to go through feedback received before writing up our detailed access management plan. Steven Pocock suggested that NRL contact the local access forum (FCW representative is possibly Marie George). Bethan Thomas to check whether we are already consulting them and if not, get in contact with the local access forum. Steven Pocock stressed that mitigation may be difficult in some locations and may require long diversions. Brechfa Forest West Wind Farm Consultation Report 212

Appendix g (cont…)

Huw Williams suggested that we need to address the following in our access management plan: Impact, time period for diversions, mitigation (diversions). Huw Williams suggested that each diversion or relocation will need to be justified, e.g. better route, will be able to stay open for longer. Steven Pocock suggested that any routes that are currently impassable could be relocated to new tracks. CCW questioned whether CCC raised the need for an access management plan in the scoping stage. Bethan Thomas to check CCC’s scoping response for a request of an Access Management Plan. Bethan Thomas highlighted that within the EIA regulations the impact on recreation is not a significant impact. Bethan Thomas highlighted that CROW closures will have to be carefully managed, especially when considering users that are very familiar with the forest. CCW state that the access management plan will form part of the consultation response.

Water Management Plan: Nia Phillips discussed the water management plan which arose from a technical meeting organised by CCC. The requirement of this plan was to pull together all things water related. This includes run-off, washing out of cement lorries, periods of high rainfall, pollution control. Bethan Thomas highlighted that a document containing this level of detail is best produced by the principal contractor when appointed and should be produced in parallel with the Construction Method Statement. CCW suggested appointing an Environmental Clerk of Works to assess the risks and mitigation from construction through to operation. This may or may not be the same person as the Ecological Clerk of Works. This may cover felling if FCW are agreeable. Steven Pocock and Andrew Maberly Jones suggested that FCW would consider this. CCW suggested that the Environment Agency are also likely to request a similar document, ‘Pollution Prevention Plan’.

CCW raised the question about requirements that accompany the DCO. Bethan Thomas explained that these would consist of both standard requirements and specific requirements. These will be discussed with the relevant stakeholders. The DCO will be discussed with FCW and CCC.

Progress from here: After 6th April (deadline for responses) we can discuss issues further with CCW. This date does not stop a two way dialogue with key stakeholders. We will then write up a consultation report and submit the application to the IPC, likely to be in July/August. This is dependant on any changes that may be required to the scheme.

Draft Habitat Management Plan: CCW requested more detail than that presented in the ES and some indicative maps for habitat management. Brechfa Forest West Wind Farm Consultation Report 213

Appendix g (cont…)

CCW questioned whether PAWS was additional and this was confirmed. Bethan Thomas explained that the post-construction monitoring for bats is intended to add to the body of scientific knowledge. CCW highlighted that the areas of Nightjar habitat will increase as a result of felling for the wind farm. This is the area created at the side of tracks and all areas that are not the 47m felling around turbines. Can NRL quantify this?

CCW highlighted that a small pond would be lost due to the construction of the wind farm (13.251) and that suitable mitigation would be to create a new pond in the area surrounding the access track.

Costings for mitigation: CCW requested reassurance that the habitat management plan is deliverable/financially viable. FCW are concerned that there may be conditions on the land/legacy that they would be ultimately responsible for. Steven Pocock explained that trees on FCW land are only allowed to be managed by FCW, hence the 47m cleared area surrounding each turbine. CCW suggested that there should be a process in place for any arbitration. Nia Phillips requested costing in both £s and manhours and index linked. Bethan Thomas explained that we would rather not put £ costing to it, it is detailed in the ES as manhours. Huw Williams suggested that a statement such as ‘there would be sufficient funds for the following works …..’ Bethan Thomas suggested that high priority PAWS would be identified for the habitat management plan..

Construction Method Statement: Nia Phillips raised the question of metal contaminates from cabling left in situ. May/may not form part of the consultation response. Nia Phillips highlighted that the CMS must address decommissioning and reinstatement. Nia Phillips highlighted that Japanese Knotweed was in the area and this needs to be included in the CMS. Steven Pocock suggested that a contingency plan needs to be in place for a potential outbreak of Phytophthora. This needs to be detailed in the CMS.

Grid: Bethan Thomas gave an update on the progress of Grid. Karen Maddock-Jones stated that CCW consider the grid connection to be an integral part of the scheme and CCW would require more information. The Cothi Valley is a sensitive landscape and alternative routes have not been identified. CCW have requested that NRL approach WPD for alternative grid connection routes and costings. Brechfa Forest West Wind Farm Consultation Report 214

Appendix g (cont…)

Meeting to discuss Brechfa Forest West Wind Farm Draft DCO

20th May 2011 Carmarthenshire County Council- Spilman Street In attendance: Alun Rees (CCC) Richard Jones (CCC) Ruth Southby (CCC) Richard Perkins (Parsons Brinckerhoff) Alex Blake (RWE NRL) Bethan Thomas (RWE NRL) Matthew Cand (Hoare Lea Acoustics) Apologies:

NOTE – these minutes should be read alongside the noise section of CCC’s S42 consultation response

Actions Topic Met mast data MC- data from the most recently erected mast was used.

MC To do some analysis work to compare the two masts for consistency. Background noise Questions were raised about the differences between Gellifelen and Blaen Gwyddgrug. MC - likely more significant effect of stream noise at Gellifelen. Brechfa West survey results could be used RP - he trees removed due to Alltwalis have affected noise compared to previous measurements at Gellifelen Financially involved properties Alltwalis financially involved properties. Cumulative limit- 45dB MC- clarified that the higher limit was considered when looking at total noise, but not appropriate when looking at Brechfa Forest West alone. Lower limits such as those derived at locations around Brechfa West may be more appropriate- will revisit this. Sample calculations Appendix 16.7 shows screening details. RP - a single page spreadsheet showing one property and one wind speed would be useful MC MC - will produce one example Brechfa Forest West Wind Farm Consultation Report 215

Appendix g (cont…)

ETSU RP - compliance with ETSU does not mean no noise disturbance. MC- if there are complaints, it does not mean that they are not protected by ETSU- it is first necessary to ensure that the wind farm is complying with ETSU.

Re release of Alltwalis data- Andrew Bullmore has discussed this with Statkraft, who are not keen to release the data. MC- is the data available elsewhere? AR - it may also be necessary to get consent of the landowners

AB- if something is being investigated as part of an enforcement complaint, it would be confidential as long as the investigation is ongoing. Once concluded- should be able to release the info. MC/ RP MC & RP to discuss this issue LFN & Infrasound RP - not suggesting any further action at the moment- there is a protocol for investigating, no condition necessary. Brechfa Forest West Wind Farm Consultation Report 216

Appendix g (cont…)

Amplitude Modulation (AM) MC - currently involved in a large piece of research. The information presented in the ES and government advice still stands, AM is not a widespread issue

Control by condition is difficult because insufficient information is available at the current time, it would not be enforceable. But noted that it is a relevant consideration.

RP - Denbrook- the Inspector did think that he could present an adequate condition. CCC have included ‘Other AM’ in response to a complaint within the draft condition provided. Presentationally, there is a public perception that if this is not covered in a planning condition, there is no redress.

AB - IPC conditions (requirements) need to comply with the six tests set out in Circular 11-95. At the Covanta Hearing, the DCO requirements were heavily scrutinised by the Commissioners, so it is important that they are robust and enforceable.

RJ RJ- to send on latest version of Condition x Post meeting note- done

MC - there is no info in the Guidance Note attached to condition x about how to assess ‘Other AM’: the proposed wording does not address the issue substantially There are examples where excessive AM has been solved.

RP - if RWE NRL apply for immunity from Statutory Nuisance and if it is not covered in the conditions- how are CCC able to deal with AM complaints?

MC - there is currently no definition of method of quantifying excess AM

RP - statutory nuisance is subjective so wouldn’t be concerned with a numerical definition. Would like to keep the ‘Other AM’ condition in at the moment. It is important that CCC are seen to be doing all they can. Even if the IPC take the condition out through rigorous investigation later. Brechfa Forest West Wind Farm Consultation Report 217

Appendix g (cont…)

Cumulative Impact RP - Bryn Llywelyn wind rose shows an approximate split of 50-50 north and south wind directions based on a year’s wind data.

Wind reference query- differences with Alltwalis. MC - can we get this information from Alltwalis? Standardising the noise limits would provide a shift but not change the conclusions. But would need the information from Alltwalis in order to do this. RP - the reason for this request is that if the limits are expressed in different ways, it is difficult to enforce. MC – using limits based on Brechfa West survey at these locations would remove this difficulty

MC Set limits lower than the existing wind farm, MC to provide some numbers/ graphs to RP

MC - also need to set partial limits- splitting the limits with Bryn Llywelyn. RWE NRL/ MC to speak with RES

BT/ MC RP - request that RWE NRL compare the Gorsedd Bran case with the Brechfa Forest West wind rose and present this information. CCC can then consider whether the cumulative impact is acceptable.

MC MC - will provide some directivity information. It is very unlikely that any property close to RES site would be down wind of both wind farms at the same time.

MC - are CCC asking similar questions of RES? AOB

RJ - CCC are not recommending that we remove turbines for noise reasons. No analysis has been done to identify the turbines named in the consultation response, these came from the local members. Brechfa Forest West Wind Farm Consultation Report 218

Appendix g (cont…)

Meeting to discuss Brechfa Forest West Wind Farm Draft DCO

16th June 2011 Carmarthenshire County Council - 40 Spilman Street Attendees Eifion Bowen (CCC) Richard Jones (CCC) Steven Murphy (CCC) Paul Maile (Eversheds) Bethan Thomas (RWE NRL) Tabitha Fowler (RWE NRL) Apologies Alex Blake (RWE NRL)

Actions Topic Introduction BT explained that the DCO at this stage has been drafted on the basis of the contents of the draft ES that was consulted on from February to April.

RWE NRL are still working through the consultation responses and doing additional work, therefore we expect that the DCO will be amended as we move closer to submission in response to the consultation and the additional work taking place.

Comments and queries are welcome from CCC at this stage.

In this and future meetings, RWE NRL will note down areas of agreement/ disagreement. These will be appended to the minutes of the meeting to be agreed by the attending parties.

This should ensure that we do not need to keep revisiting issues that have already been discussed and makes the process of drafting a Statement of Common Ground easier and more transparent when we get to that stage. Brechfa Forest West Wind Farm Consultation Report 219

Appendix g (cont…)

Draft DCO- Provisions 3(1)(b)- mentions consent for ancillary works- are these anticipated. BT Query to Eversheds- this is square bracketed- will it come out?

5(1)(a)- lateral deviation- the 50m micrositing figure is not included here, CCC suggest that it should be included

5(1)(b)(ii)- query from CCC- there is no limit on the downwards vertical deviation- is there a cut off where the ecological impact assessment would need to change? BT Query to LUC- is there a point where-eg- bat impacts would be different if the turbines were shorter?

7- re transfer of Order- CCC- request that we include some reference to informing the LPA of any transfer as there would be difficulties in enforcement if they are not informed

8- Statutory nuisance- CCC queried what the current status of this provision was. BT confirmed that RWE NRL is currently awaiting feedback from the noise consultants and therefore this provision remains in place at the current time.

9(3)&(4)- CCC sought clarification that these clauses mean that if the street is named in Schedule 2, the street can be closed after consultation with the street authority and if not named in Schedule 2, the street cannot be closed without the consent of the street authority (i.e. specific consent is not required for those streets named in Schedule 2). EB advised to consult with Swansea CC and Trunk Road agency if works affect land under their control SM was concerned that this would not be acceptable to the relevant departments within the Council. BT- this may be clearer and less controversial once Schedule 2 is populated.

10- CCC query- have RWE NRL contacted EAW about this issue? BT- a letter has been sent to EAW in relation to S150 of the Planning Act but no response has been received as yet.

12- Compulsory acquisition of land- EB- are we comfortable that this does not interfere with human rights legislation? PM- these provisions need to be in the Order at the start of the process, but may be withdrawn at a later date if not required.

20- CCC query- what is the reason for the TPO provision in the Order? BT BT- we are concerned that trees may be TPOd prior to construction Will check how this can be included without naming specific trees as per the model provision. Brechfa Forest West Wind Farm Consultation Report 220

Appendix g (cont…)

Draft DCO- Requirements 3- CCC query whether three months prior to the expiry of permission is sufficient time to agree decommissioning plan. CCC normally request a decommissioning bond.

RJ To send Mynydd y Bettws S106 agreement & conditions

6- RJ queried why felling had been excluded from this provision. The specific query related to felling for road improvements and RJ suggested that agreement of TMP would be necessary prior to felling for road improvements taking place. Felling may require the submission of surveys to assess impact upon European Protected Species. BT explained that this was intended to refer to felling taking place for infrastructure on FCW land, which will be undertaken by FCW (or their approved contractors) in line with their usual procedures. There is no need for some of the more onerous conditions that will apply to the wind farm construction work. CCC request the inclusion of some additional principles (mentioned in S42 response): - Road condition survey - Agreeing movement schedule with other developers of other projects - Assessment of existing structures - Dry run CCC would also request that this plan be approved by the LPA, not the Commission as stated in this requirement. Include a Travel Plan- relating to movement of people- for sustainability/ traffic minimisation

In the definition of ‘Commission’, CCC suggest that it may be appropriate to amend this to ‘…or any body which HAS authority...’ There was a discussion about the current IPC advice on who would be responsible for discharging requirements. Contradictory views have been given and there seems to be a general lack of clarity at the current time. RJ- if requirements are to be discharged by the Commission, CCC would seek a consultation role.

7(p)- RWE NRL provided confirmation that they would not seek to commence felling (and therefore stacking timber) until the CMS was agreed. Part 1 of the DCO- Authorised Development- the description of works needs to specifically mention felling.

11. Construction hours. CCC would prefer working hours to be 7am- 6pm as there will be residual traffic outside of these hours. Brechfa Forest West Wind Farm Consultation Report 221

Appendix g (cont…)

12 RJ – 24hrs notice considered a short timescale to inform police, public bodies emergency services etc. (not mentioned at meeting but worth flagging up now)

13 & 14- HMP & AMP- these topics will subject to separate meetings

18- CCC request further details about the substation. This is one of the main components of the scheme therefore CCC expects this information up front, not as part of a ‘requirement’.

21- RJ asked whether RWE NRL had consulted Dyfed Archaeological Trust on the draft DCO. BT- post meeting note- can confirm that DAT have not been consulted on the draft DCO

22. Ecological Clerk of Works- CCC request that RWE NRL extend the period of employment to cover residual impacts after the completion of construction. This issue to be discussed at S.42 meeting. Section 106 Agreement PM- what would CCC like to be included within a S106 agreement? EB- for example, details of who will manage the ECoW. Further details about monitoring. It would be useful to work up a Heads of Terms document for the Section 106 agreement. EB asked whether anything had come out of the S47 responses that would be appropriate for inclusion in the S106 agreement BT to review the responses and pull together a list. AOB EB- is there any conflict between the proposed access track and the habitat management area for Alltwalis Wind Farm? BT- no, we believe there is no conflict- there is nothing in the S106 agreement prohibiting the construction of a track in this area- it relates only to reduced grazing.

RJ- the DCO has been circulated to a number of other departments with CCC (and consultants)- if there are any further observations, these will be sent on.

BT RJ stated that CCC had not received the S150 letter relating to Rights of Way and Hedgerows. BT to resend this letter. RJ RJ to send minutes from the Working Groups.

PM- RWE NRL will seek agreement from CCC that the scope of the order is appropriate. Brechfa Forest West Wind Farm Consultation Report 222

Appendix g (cont…)

Next meeting There is a meeting scheduled for 13th July to go through S42 responses. CCW will also be in attendance at this meeting and the agenda will be circulated to EAW for information (they may attend if they feel it is appropriate). 13th July meeting to be moved to 10am to allow sufficient time for a full discussion.

BT will meet with RJ on 7th July to discuss Working Groups.

Suggested next meeting to discuss DCO- w/c 25th July. Also invite CCW. BT BT to send round a request for available dates. Brechfa Forest West Wind Farm Consultation Report 223

Appendix g (cont…)

MEETING

Wednesday 13th July 2011 Attendees Richard Jones, CCC Eifion Bowen, CCC Steve Welchman, CCC Rosie Carmichael, CCC Lindsey Rendle, CCC Nia Phillips, CCW Huw Williams, CCW Rhian Jardine, CCW Bonnie Miles, EAW Dai Rees, FCW Steven Pocock, FCW Bethan Thomas, RWE Tabitha Fowler, RWE

Bethan Thomas began the meeting by explaining that we were going to go through the CCC and CCW Section 42 consultation responses. The objective of the meeting is to give an overview of the approach that RWE will be taking to the consultation responses received and that it was not (from RWEs perspective) meant to be a forum to raise new, or repeat existing, issues. Bethan highlighted that RWE had not brought any specialist consultants and therefore would not be able to talk about specialist subjects in detail. The meeting therefore was to be treated strictly as ‘high-level’ only. Bethan explained that the minutes of the meeting would be appended to the consultation report.

A separate meeting has been held with Carmarthenshire County Council to discuss noise.

The meeting is not to discuss EAW’s S42 consultation response which is primarily being dealt with by our specialist consultants. It primarily covers distinct areas when compared to the CCC/ CCW responses, with some limited overlap.

The meeting is not to discuss the merits of the project but the consultation responses.

Bethan gave an overview of the IPC process and explained that the draft DCO will be submitted with the application and will form part of the permission. A meeting has already been held with Carmarthenshire County Council to discuss the DCO and a meeting with CCW will be held next week to discuss the DCO. Post meeting note- CCW meeting to be held at a later date if this is felt to be appropriate.

RWE will be aiming to submit the application to the IPC before the end of September, avoiding the summer holidays. Post meeting note- in the light of the these meetings, it has been decided to delay submission in order to spend more time considering the issues raised. Brechfa Forest West Wind Farm Consultation Report 224

Appendix g (cont…)

Recreation Access Management Plan Bethan explained that Brechfa Forest East will be leading on the general principles of the recreation access management plan. These general principles will then be used for Brechfa Forest West (BFW). Detail will be added that is specific to BFW. Bethan reiterated that the detail of the RAMP for BFW will not be discussed now as the broad principles and detail were still to be agreed with FCW. Bethan explained that RWE had taken the decision that the access management plan will not target tourism, but that it will primarily be a health and safety document but will also be used for information. Within the access management plan, the needs of each user group will be addressed individually and lines will be drawn on maps to define areas of responsibility for FCW and RWE. The access management plan will cover the three types of rights within the forestry, CROW, PROW and permissive rights (Bethan confirmed that this will include bridleways). The access management plan will also address the following issues: – Signage – Emergency procedures – Communication.

The access management plan will be accompanied by plans showing the areas of responsibility of FCW and RWE. There will be two recreation access management plans, one for Brechfa Forest East and one for Brechfa Forest West. CCW expressed concern that whilst the plans needed to mitigate for the impacts of the two schemes individually, that collectively the plans would also need to be holistic. CCW requested confirmation that the plans would do this.

Eifion Bowen queried whether the access management plan will be covered by conditions or form part of the application. Bethan explained that it will be appended to the ES in draft form. CCW and CCC advised that the RAMP be submitted ‘as close to final’ as possible when submitting the final ES to IPC. Bethan explained that for reasons outwith RWEs control (e.g. primary contractors) the documents could not be fully finalised. CCW and CCC explained that they understood, but that the more detail up-front the better.

Eifion Bowen queried who would be signing the s106 and raised concerns over enforcement and who the notices should be served upon- WAG or FCW. WAG doesn’t have to accept notices served on them.

Action – FCW- get an official view in writing on these matters. Both who signs the s106s and who the notices will be served upon, WAG or FCW.

Richard Jones asked if RWE had engaged with any groups for the access management plan. Bethan responded that early on in the process RWE had engaged with a number of groups for recreation.

Rosie Carmichael asked if RWE NRL used the maps sent through. Bethan explained that RWE believed there are a few contradictions between the maps. Some forms said that certain parts were passable whereas others said that they were impassable. Rosie Carmichael explained that the combined map drawn up represented the worst case Brechfa Forest West Wind Farm Consultation Report 225

Appendix g (cont…)

scenario and indicates which groups use which tracks. Bethan explained that this map was useful as background. Rosie Carmichael said it was an indication of the condition of the paths and should be used as baseline information.

Tourism Richard Jones said a good starting point for tourism would be EN1 S5 and queried whether RWE had engaged a tourism consultant. Bethan Thomas explained that RWE would be standing by our ES with regards to tourism. Richard Jones explained that a lot of the letters provided information in relation to tourism and the tranquillity of the area- Richard Jones did state that admittedly these were anti letters. Richard Jones asked what mitigation RWE are proposing. Bethan said that they were not proposing mitigation for tourism, as the section 42 response received from CCC was ‘subjective’ and not ‘objective’ but nevertheless asked Richard for suggestions. Richard Jones suggested investment into marketing, funding for areas that are underfunded, funding trails for walking etc but emphasised that it is the developers’ responsibility to consider mitigation and for statutory consultees to then advise on the adequacy of those suggestions. Richard re-emphasised the requirements of EN1 (section 5) and also emphasised the recommendations in TAN 8 at para 2.10 which references tourism and socio-economic mitigation and enhancement. Richard stated that the baseline of the tourism impact needed to be accurately established i.e. holiday lets, visitor attractions etc. Bethan reiterated that RWE would not be altering the baseline as presented in the ES. Richard stated that the IPC examination stage would allow for verbal cross-examination of areas of disagreement.

Nia Phillips asked how they would receive their response and justification for why things hadn’t been amended in light of their consultation response. Bethan explained that all s42 consultees who had written in as part of the consultation would receive a written response from RWE. A consultation report will also be published which will document the responses that have been received and comment on those responses.

Bethan noted that tourism was an area of disagreement between the parties.

Huw Williams asked when the s42 consultees could expect a response. Bethan Thomas explained that this is expected to be around September. Post meeting note- further to the revision to timescales, this may also be delayed. It is not possible to confirm a specific date.

Access Route to Site Bethan Thomas explained that the access route to site was one of the main issues coming out of the s.42 and s.47 responses during consultation. The main point highlighted was the need to explain why RWE haven’t used an alternative access route and to give evidence of the alternatives that RWE have assessed. Bethan Thomas ran through the history of the access route. A number of routes were considered, these were Alltwalis, New Inn and the current route. Brechfa Forest West Wind Farm Consultation Report 226

Appendix g (cont…)

The New Inn route: There is currently a road there and it heads to the Tower entrance. It is considered that this access track would have more disruption on amenity, it is a longer access track, it involves turning in the centre of the village of New Inn and would require more works in terms of hedge removal and street furniture. The landowner was approached but the discussions did not progress.

The Alltwalis route: RWE approached the landowner for this in mid 2009, but at the time there were ongoing legal issues between the landowner and Statkraft (operators of the Alltwalis Wind Farm) which were a constraint. Due to these legal issues the landowner could not discuss or did not want to discuss this option with us. Since RWE received the consultation responses, this option has been revisited and it looks like the legal issues may have been resolved. RWE have approached the landowner again. RWE are still trying to find out whether the landowner wishes to consider this option and are waiting for a response from the landowner. Bethan stated that there has to be a cut-off to how long RWE can wait for a decision. Eifion explained that the said landowner had written to CCC informing them that he had been in discussions with RWE and was considering the options available to him as proposed by RWE. He also stated that the landowner had responded to RWE and that the landowner was therefore awaiting a response. Bethan explained that as far as her knowledge allows, she was not aware of the landowner having responded to RWE regarding the Alltwallis track. Post meeting note- BT received an email response on 13th July- it arrived whilst this meeting was taking place. Bethan explained that additional surveys would be required should this route be progressed further. If agreement cannot be reached with the landowner for the Alltwalis track then RWE plan to use the track within the ES and will propose mitigation methods such as screening.

Eifion Bowen noted that there was an option in the draft Development Consent Order to Compulsory Purchase Order (CPO) the land. Bethan stated that this is a ‘last resort’ option and that RWE would not want to go down this route if at all possible.

Bethan confirmed that a land agent is currently contracted by RWE to lead negotiations regarding access and that consultants are contracted to look at the issues highlighted on the proposed route (eg. LVIA, ecol, hydrol & residential) and alternative routes and confirmed that all options and rationale will be re-empahsised in the revised ES.

Eifion Bowen highlighted that there is a s106 agreement in place over the land required for the currently proposed access route, which relates to the Habitat Management Plan of a neighbouring wind farm. He questioned whether this will have to be altered. Bethan explained that as the S106 agreement relates only to limited grazing, there should be no conflict. Eifion disagreed. Bethan explained that some correspondence on this from CCC would be very helpful.

Bethan queried whether RES are proposing to use the access across Mynydd Llanllwni for abnormal loads. Bethan asked whether CCC have asked RES to look at RWE’s proposed access. Richard Jones stated that they had not. Brechfa Forest West Wind Farm Consultation Report 227

Appendix g (cont…)

Rosie Carmichael questioned the extent of the works required at the New Inn access and whether it has been quantified. Bethan explained that swept path analysis had been done on this access and that there is an issue with gradients. Rosie Carmichael questioned the gradients and how these were different from the access proposed in the ES. Bethan explained that along the New Inn access there are warning signs for the high gradient. By building a new road you can control the gradients to a greater degree- it may be necessary to reprofile the existing road due to the gradient issues. Steve Welchman stated that building a new road would have a higher impact.

Richard Jones questioned whether RWE have drafted a strategic traffic management plan. Bethan explained that RWE are not planning to draft a traffic management plan. Nia Phillips asked why. Bethan explained that it is too early to provide a draft as RWE can’t say with certainty which size of loads will be used, what the traffic flows will be at the time of construction and what the cumulative impact would be due to timings between the proposed projects. RWE currently don’t have the level of detail required to produce a detailed traffic management plan.

Geology/Peat Bethan explained that this was an issue raised by both Carmarthenshire County Council and CCW. Due to the lack of intrusive survey, there were worries that RWE couldn’t substantiate the information presented from the desktop survey. In response to the consultation, a peat survey has been undertaken. The report from the survey was received by RWE yesterday (12th July) and the survey supports the desktop studies. Dry ash studies identified small quantities of peat at some locations. The average depth at the locations where it was found was 10.3cm and the maximum depth was 14cm. The assumptions used for the carbon balance assessment assumed an average of 10cm depth across the site as a worst case scenario; RWE will continue to use this based on the study that has just been completed. Nia Phillips asked whether this report will be appended. Bethan confirmed that it would be and that the hydrology chapter will incorporate the findings.

Landscape and Visual Bethan explained that both the CCC and the CCW response requested a 5 point scale instead of a 3 point scale. RWE have consulted with the landscape and visual consultant and they are keen to stick with the 3 point scale due to it being clearer and in line with the guidance. RWE’s consultants are currently reviewing the comments in the consultation responses. There will be some small changes in response to comments made such as the layout of the visuals within the ES. The comments on turbine height will be rebutted by RWE NRL.

Our technology team are currently working on a response with regards to reducing the height of the turbines and the interaction this will have with turbulent flow. Bethan explained that you would have to fell an incredibly large area of the forest in order to avoid the turbulence from the trees. Felling large areas of the forest was never intended to be part of the project. RWE will incorporate the report which explains turbulence in forestry. The choice of turbine height due to turbulence is consistent with other Forestry Commission wind farm developments and this will be explained in the response. Brechfa Forest West Wind Farm Consultation Report 228

Appendix g (cont…)

Steve Welchman queried a statement given in the ES which explained about the relative heights of turbines compared to Alltwalis being generally at a lower level. Bethan explained that this is going to be revisited.

Huw Williams questioned which comments would be addressed by the consultant. Bethan explained that all the comments would be reviewed but particularly those raised by both parties and agreed on by both parties and those with clear questions.

Ecological Clerk of Works Bethan questioned whether CCC and CCW were seeking a job specification for an ecological clerk of works. Richard Jones suggested that an area would need to be defined and the job specification would involve gathering information and reviewing the impacts. Job specification and principles of role would have to be agreed prior to submission.

Bethan Thomas suggested that a separate meeting would be needed for this and asked whether a previous job specification could be sent to RWE. Eifion Bowen suggested that the HMP produced for Bettws could be used. He stated that monitoring is a key function. For water quality would there be a hydrological clerk of works? Scope for a land management role dealing with wider habitats The Local Authority would need resources to monitor and this will need to be paid for by RWE. Steven Pocock explained that FCW will need to play an active role in this. CCW requested an active role in this. Bethan Thomas proposed that an advisory group would be needed to assist in the delivery of the HMP. Richard Jones advised Bethan Thomas to speak to colleagues dealing with wind farm schemes in Powys, regarding progress on a SSA wide officer covering post consent ecology / habitat issues.

Action – Eifion Bowen to send through HMP from the Bettws scheme.

Rosie Carmichael suggested that the National gas pipeline could be used as an example. If both East and West coincide then more than one ecological clerk of works may be needed. Bethan Thomas explained that was built primarily on peat and that the ecological clerk of works was an essential role during construction. Rosie Carmichael suggested that the ecological clerk of works needs to be on site at all times. Nia Phillips added that they need to be present during operation. Bethan Thomas agreed that there was some need for ecological monitoring during operation but added that this would be less of a role and would not be the same as an ecological clerk of works. Bethan Thomas explained that Ecology/HMP will need to be discussed further in a later meeting after RWE has discussed the HMP in more detail with FCW.

Access Management Plan (AMP) Bethan Thomas explained that both the AMP and HMP will need a separate meeting and asked whether the general consensus would be to combine the two topics into one meeting? Brechfa Forest West Wind Farm Consultation Report 229

Appendix g (cont…)

Nia Phillips asked when there will be more information about the access track? Bethan Thomas explained that as soon as RWE know which route will be used they will inform CCC/ CCW.

Huw Williams asked about timescales for the AMP/HMP meeting. Bethan explained that this is likely to be around week after next.

Huw Williams requested that the AMP and HMP, including costs, be presented before the DCO. Bethan explained that the documents will still be draft at application and that costs will not be included as this is not a material planning consideration. Huw Williams stated that PAWS will not be accepted as mitigation and that more detail in the HMP is required.

Steven Pocock explained that the legacy issues need to be discussed and agreed with FCW first. Rosie Carmichael suggested that consultees need to be involved early, as it is frustrating otherwise. Huw Williams agreed that the documents need to be agreed with FCW before discussing with CCW.

Eifion Bowen raised concerns over which body will be responsible for discharging conditions.

Bethan explained that the HMP will aim to include as much detail as possible and that the DCO could be discussed before the HMP is agreed in draft but can be discussed the other way round if CCW prefer. Huw stated that CCW preferred discussions to be in the correct and logical sequence and that discussions surrounding the draft DCO would be premature prior to understanding how RWE intend to (or not) address the concerns outlined in the s.42 responses. Nia Phillips asked for the inclusion of indicative costings. Bethan Thomas questioned why this is being requested. Nia Phillips stated that there aren’t any lines on maps and CCW are seeking reassurance that sufficient funds are available to deliver the proposed measures. Bethan Thomas explained that costs may vary depending on who RWE employ to undertake the work (or indeed if internal staff are used) and that therefore costs are very difficult to judge. Nia Phillips stated that costs need to be assured. Bethan Thomas explained that this would be discussed further at a separate meeting.

Grid Bethan Thomas explained that RWE disagrees with the interpretation of policy with regards to responses on grid and will be providing a rebuttal to these. RWE will not be amending the ES on this topic.

Eifion Bowen questioned whether this was before or after the minister’s statement? Bethan Thomas explained that this is RWE’s stance in both situations. Brechfa Forest West Wind Farm Consultation Report 230

Appendix g (cont…)

Eifion Bowen questioned whether the grid connection application is currently going through IPC? Bethan Thomas stated that it wasn’t at that stage yet and that WPD are responsible for taking this forward.

Huw Williams questioned whether RWE have asked WPD to look at alternatives as requested at our meeting on 31st March 2011? Bethan Thomas explained that WPD will need to look at alternatives for the IPC application and not RWE. As no specific issues were raised by the consultees in their responses, RWE have not asked WPD to do this at this stage. Nia Phillips stated that there is not sufficient detail in the ES to raise specific issues. Bethan Thomas explained that it has to be shown in the wind farm application that it is possible to connect the scheme to the grid. This has been done within the ES. There have been no responses to suggest that the grid connection isn’t possible. Rhian Jardine questioned whether they can submit a supplementary response. Bethan Thomas explained that they were welcome to but a rebuttal is likely to be provided.

Eifion Bowen questioned whether WPD are confident that they can provide a connection on a wooden pole line. Bethan Thomas confirmed that they were. Eifion Bowen questioned where RWE would stand if a condition was applied that stated that Brechfa Forest East had to be constructed within 5 years of consent but grid was not in place by this time.

Action – BT to seek advice on the above question.

Huw Williams stated that WPD are not intending to do any more work on the grid connection until the permission for the wind farm is granted. Bethan Thomas indicated surprise at this suggestion and will speak with WPD.

Rhian Jardine asked whether the developer considered twin tracking the wind farm application with the grid connection.

AOB Date for HMP/AMP meeting is likely to be 28th July.

Action – BT to send meeting invite to get the date in diaries.

A query was raised about potential venues for meetings relating to the IPC application- pre- examination meetings/ hearings. BT replied that a suitable venue (ie capable of accommodating all those who wish to attend) would need to be found reasonably local to the site. Due to a lack of venues closer to Brechfa Forest West, it is anticipated that this is likely to be somewhere in Carmarthen.

Nia Phillips asked about the dry run. Bethan Thomas confirmed that this had been completed on Monday. Rosie Carmichael questioned whether this included the New Inn entrance. Bethan Thomas confirmed that it didn’t include the New Inn entrance. Brechfa Forest West Wind Farm Consultation Report 231

Appendix g (cont…)

Ecology Meeting

Carmarthenshire County Council 28th July 2011

Attendees Bethan Thomas RWE NRL Tanya Davies RWE NRL Dai Rees FCW Steven Pocock FCW Nia Phillips CCW Huw Williams CCW Rosie Carmichael CCC Richard Jones CCC Lindsey Rendle CCC Phil Snaith CCC Kate Collins EAW Sofie Swindlehurst LUC

PS Regeneration Manager from Carmarthenshire County Council (CCC) with responsibility for mountain bike interests was present at the beginning of the meeting. He said that he would expect to see more in terms of cycling opportunities for Brechfa Forest East. Need to look at the Visit Wales website and put some information on there and also consider wild cycling. Economic impacts need to be looked at in the Environmental Statement. PS expressed concern that the RAMP as it stood was not a ‘Recreation and Access Management Plan’, more a H&S document. PS stated that if the equivalent was submitted for Brechfa East that it would not be acceptable. PS stressed that the RAMP needs to consider impact on individual user groups.

There is a five year rule for European funding, PS thinks there are 3.5 more years to go for European funding for the cycle routes. CCC will either need to mitigate or apply to WAG. Also need to consider the use of the CCC website, their ‘Discover’ site.

Action CCC and FCW to check

PS npower should consider enhancement opportunities for wilderness / off-piste cycling for those riders wanting to use alterntive trails to the MTB tracks in Brechfa East.

HW Will tourism be added?

RC Suggestion- call it something else if not a recreation and public access management plan. But it still needs to cover the impact on individual recreational user groups.

Brechfa Forest West Wind Farm Consultation Report 232

Appendix g (cont…)

PS Will East plan look at economic development?

BT Can’t comment on East, this meeting is to discuss Brechfa Forest West.

RC Need to ensure East is aware of West issues.

TD The application process is different for East and West. East can be dealt with by planning condition.

RJ Wants general principles up front agreed for East.

RC Separate meeting needed for East but do not want duplication.

Ecology SS Keep vegetation under the wind turbines to 0.5 metres high. Propose we commit to the height and type of vegetation and commit to keep it at this height. Will give clear objectives in the HMP but not going to include fine detail more than just cutting cycles etc. Key is to keep off the woody species.

HW Query- is 0.5m too high? Don’t want areas around turbines to be treated as habitat.

RC If they are habitat, then they must be closely monitored. It is preferable to have monitoring rather than management to avoid development of habitat. Quite a lot of space, need to consider what the risks are. What habitats are developing, what insects are there etc. If there is a negative impact, will need to rethink and have a contingency plan. It’s a large area so there is the opportunity to create good habitat- we should not discount this.

LR Vegetation monitoring must run alongside invertebrate monitoring.

HW The better the habitat the greater the risk of insects, birds and bats being attracted into the area and therefore potentially into turbines.

RC Try not to be too prescriptive- different areas could be managed in different ways- contribute to semi natural habitats and different types of management. Would like to see some monitoring.

SS Suggest fixed quadrats – NVC survey. Monitoring needs to answer a specific question i.e. it must be objective, and a consequence e.g species, cover, generic understanding of systems. The answer will be needed to e.g. inform the cutting/management regime and understand recolonisation rates.

SS We will need to consider enhancement also e.g broad leaf, heathland, marshy grassland etc. Regime will need to be on annual basis for 5 years Brechfa Forest West Wind Farm Consultation Report 233

Appendix g (cont…)

RC Need to identify the key species to encourage and/or eliminate- record positive and negative percentage cover of these key species. NVC won’t be appropriate because habitat will be in flux. It is important to have control sites that are cross-comparable. Control sites are important to understand the impact

LR Need a key vision.

RC And control sites so we know what aiming towards.

Bats, birds and invertebrates

SS Monitoring proposed is needed to verify assumptions made in the assessment. Baseline assessments will take place within the areas cut into the existing plantation after clearance has taken place- ‘year 0’.

SS Haven’t proposed to do any survey work for invertebrates- the chapter makes assumptions based on habitat. Bat activity will be monitored directly

LR It would be useful to know if trends/correlations are emerging e.g. in terms of vegetation and bats.

SS Looking at churring and productivity for bird species.

HW Do we need (collision) mortality monitoring?

LR yes bird and bat mortality would be useful monitoring to do. It could be as simple as counts – the results of which will help inform the decision making processes

SS Looking at activity rather than mortality because recording mortality is extremely difficult in a forestdue to ground cover.

SS Natural England guidance advises a 50 metre gap between the tree edge and the turbine sweep.

Action SS to get further clarification from the bat specialist.

HW Will need baseline information for nightjar as well

DR There is existing information about nightjar- national averages and historical surveys within Brechfa Forest.

Brechfa Forest West Wind Farm Consultation Report 234

Appendix g (cont…)

Action BT/SS to get information on methodology for nightjar from Mike McGrady.

BT Within the 47m radius around the turbines, the hardstandings will remain clear. It has also been proposed that dry swales will be placed at the base of every turbine ensuing that the hydrology is not impeded or altered. The dry swale will also remain clear accept for during extreme rainfall.

SS The swales are not meant as ephemeral pond, but, rainfall events in Brechfa will possibly mean that they become so and will therefore need to be checked consistently.

SS The swale is 1 metre deep, 10 metres by 10 metres and it will not be allowed to scrub up.

RC It would be useful to have a cross section of what is acceptable- vegetation and to understand the general principles of swale.

Action BT to find out if we have more information about dry swale management.

SS We need to ensure that the monitoring is answering the correct questions and therefore ensure that the questions to be answered are specific and targeted.

Decommmissiong BT We do not anticipate we will need to clear anything to decommission. RWE will re-assess information/area when closer to the decommissioning time.

Temporary Felling BT Replant in line with the FDP.

SP The FDP is in abeyance, FCW will review it after construction and will restock in line with the FDP. CCW and CCC are consultees on the FDP.

DR Any HMP will be taken into account in the FDP review. There is currently an approved FDP for Brechfa West. If planning is granted for the windfarm development the FDP will be revised during the construction period and will no doubt reflect the requirements/affect of the development.

SP on existing roads the FC will cut back 12.5 metres to accommodate tracks and cables and this will be managed for 25 years. For new roads, 25 metres will be cut and both sides can be managed.

HW Will it be able to regenerate?

NP Can this be managed as a mosaic of habitat/verge side management? Brechfa Forest West Wind Farm Consultation Report 235

Appendix g (cont…)

DR It can be managed and heathland/ other habitat corridors can be created. Suggest a five year rotation of cutting- staggered approach. Monitor annually to check for tree re-growth

RC Can we quantify the approximate amount of habitat management, it’s important to create a mosaic of habitats. Hedgerow/track management is very important.

SS Could we leave track sides alone for 5 years to see what will re-grow (but check for trees)? Habitats could be categorised. Then monitor for what is naturally regenerating over the 5 year time frame and manage as that specific habitat for the duration of the scheme. Create a mosaic of habitats.

HW There will be a huge area of benefit not accounted for at the moment in terms of the new tracks and the existing roads. This makes the wind turbine bases seem insignificant.

HW Got to be realistic about what could be achieved- based on what is there. HMP should provide the general principles of managing open spaces needed to create a mosaic of habitats.

SS There will be small areas of habitats lost.

HW Need to show the mitigation for these and the additionality.

NP Quantifying areas is important.

SS Full details of loss, mitigation and gain figures will be provided in the revised ES.

In terms of new tracks which will be 25 metres wide, there will be 5.5 hectares. In terms of existing tracks, there will be 12 hectares created and in terms of the turbine basis there will be 14 hectares created so be around 31 hectares in total.

SS There will be several pockets of losses and don’t want to promise that these managed areas will be able to re-vegetate like for like. Not all habitats to be lost are of BAP standard (even if they fall within a BAP habitat classification).

HW The tracks will be linear corridors.

SS Not all the corridors will be bat friendly.

SS In the light of the comments made by CCW in their consultation response, we have revisited the proposals for PAWS restoration. We propose to now take this out. Brechfa Forest West Wind Farm Consultation Report 236

Appendix g (cont…)

HW There is no need to take PAWS restoration out of the HMP, rather it was important to realise that it could not be coined as mitigation in the original ES when it was not being impacted. Still want the PAWS restoration, looking for additionality and betterment. From an ecology viewpoint this is not mitigation its enhancement. Just make terminology clearer.

SS We need to be more specific in habitat management plan.

RC Is there anything worth translocating? It is important to have a starter culture and to retain seed bank, this is what was done on the pipeline.

BT We are aware of the need for appropriate storage of soils and to maintain a seed bank.

Action BT to check that this is covered in the draft Construction Method Statement.

SS The borrow pit won’t be reseeded; it will need some form of vegetation.

NP CCWs section 42 response stresses that given the long-term presence of this quarry as open habitat in the area, consideration should be given to keeping this habitat free from trees. Biodiversity would benefit far more from the borrow pits either being left to recolonise totally naturally, or perhaps from having their surface soils removed prior to stone ripping and then replaced. We do not consider seeding/planting to be acceptable.

SP If anything is left in the borrow pit, FCW might want to carry on using it.

HW Tracks outside habitats are particularly important- more so than the wind turbine radius- for habitat restoration.

SP Heathland restoration on forestry is slow.

HW Particularly where areas are not de-stumped- may take 10-12 years to regenerate.

DR Suggested that the ground could be mulched.

RC Need to be clear about what is beneficial.

HW The track sides will need to be de-stumped because of the cable runs.

RC De-stumping and de-needling along these areas is very important for regeneration which will allow quality soil to come back.

DR The nightjars like a stumpy habitat because they need camouflage- they would avoid mulched habitat. Brechfa Forest West Wind Farm Consultation Report 237

Appendix g (cont…)

Action SS to tabulate stump requirements and consider further

Ponds and Water Courses SS Confident that no ponds affected, no loss just need to protect. Confirmed by hydrologist. Cross referencing has taken place between the hydrology and ecology chapters.

Tree lines and Hedgerows SS Replanting on the access track to the A485. We’ve worked with the landscape and visual consultant regarding the length of the hedgerow south of the track for connectivity. Most planting on the north side is for L&V purposes, around a kilometre of planting- we have got lengths and types of species but not specific details yet. Grassland mix.

RC Need to try and landscape the track itself, need to say where the detail is.

SS Priorities from an ecology point of view are to replace with more than has been lost, with species rich habitat, and provide connectivity. Maximising benefit of re-growth after construction and during operation.

Wetlands SS The main approach is to avoid riparian zones.

HW stated that CCW would wish to see monitoring of hydrology and drainage on tracks.

RC Pleased with attention to SUDS approach, keen to see water retained on site. Opportunities for additional wetland habitats.

SP Water and cables and roads don’t mix.

RC Want to make most of what is there- the area has got drier over the years, if it is possible to increase wetland habitats this would be beneficial.

SS Dry swales, sediment reduction measures and frequency and duration of monitoring has been added to the HMP. Details will be outlined.

Pine cat and Polecat SS Monitoring in habitat management plan.

Nightjar RC ES should make it clear that there are suitable areas for nightjar elsewhere in the forest. Brechfa Forest West Wind Farm Consultation Report 238

Appendix g (cont…)

SP Trees in Brechfa Forest West are not in an appropriate state for nightjar in the next few years.

DR There is anecdotal evidence that the nightjar are still present and calling in an area near to the Alltwalis Wind Farm.

SP CCC and CCW can influence the FDP at the point of revision.

HW Have to accept that the management of the forest as it stands is beneficial for nightjar but there are no guarantees that this will remain. CCC and CCW will have an influence at consultation on the FDP. Would expect to see wind farm monitoring informing FDP development. The mid term review of the FDP (5 years in) fits in well with monitoring and site development.

DR FDP will be informed by the monitoring for nightjar

BT Mike McGrady (Natural Research) not convinced that management for nightjar away from turbines is needed.

Otters SS concerns have been raised about works at the ‘pinchpoint’ at the top of the Pib, especially regarding noise and disturbance. Words are to be provided in the ES providing further clarification. The relevant distances are: 115 metres between the track and the otter shelter; 304 metres from the borrow pit. 384 metres from wind turbine 9.

SS Spoken to noise specialist to provide information about noise produced at the above sources. All the detail has now been included in the ES. At the levels provided and with the current otter activity we don’t anticipate a requirement for otter licensing.

SS The shelter type can now be confirmed as a lie up (under roots) and not a natal holt.

SSA Wide Ecological Clerk of Works

BT Powys has 22 planning applications and the different sites are making a contribution. There has been some high level discussion but nothing has been put down on paper. Developers are waiting on Powys to provide clear proposals.

RJ Looking for one role for the SSA at a managerial level and someone else as well for 20 years- ‘Ecological Audit Officer’ may be a more appropriate title. Looking at ecology and common land and the draft habitat management plans and considering trends and monitoring. If Bryn Llywelyn were approved, then a warden managing common land issues would be useful. Statkraft will not be Brechfa Forest West Wind Farm Consultation Report 239

Appendix g (cont…)

involved, just RWE (both schemes) and RES. For the first three years, would anticipate an Ecological Clerk of Works for each site plus somebody from the local planning authority overseeing- it may be a temporary role. Not clear who would employ but the individual would need to be responsible and answerable to CCC.

The workload and responsibilities could diminish over time, therefore it is suggested that a three year temporary role be created and money given by the developer(s) to fund the role. A review could then be taken towards the end of the three year period to asses whether the duties/responsibilities of the role should increase or become part-time.

SP FCW intending to monitor conditions etc- is there duplication? FCW are aware of the legacy issues on the site.

RJ question over how to assign costs- some schemes may have more impacts than others eg Bryn Llywelyn and commons issues.

TD By MW installed would be the simplest solution.

Action NP and RJ to meet and consider potential of SSA-wide office further

Costings, man hours and resourcing. HW Need assurance of the deliverability of proposals and that the developer is not over committing. Want transparency to ensure that things can be delivered.

RC In terms of the PAWS, will it be a sum of money or defined areas? There is an opportunity through the wind farm proposal to look at a network of mosaic sites- the tracks will help. Lots of tracks are dead ends. Wants to optimise the mosaic approach. Need to ensure that a balance is achieved linking riparian zones and other areas of open ground. Need to ensure that ecological connectivity is achieved across the forest; a linked network of riparian zones and open ground will contribute to this. In accordance with FC policy and UKWAS 10% of the FCW site can be managed as open ground. This figure does not include riparian zones.

SP Through normal forest management they are moving towards a more mosaic approach at Brechfa. To lose more forest on top of what is proposed is not acceptable to FCW. There may be a contravention of UKWAS.

Brechfa Forest West Wind Farm Consultation Report 240

Appendix g (cont…)

Brechfa Forest West Wind Farm Recreation & Public Access Management Plan

28th July 2011 Attendees Bethan Thomas RWE NRL Tanya Davies RWE NRL Steven Pocock FCW Dai Rees FCW Gary Carlson Carmarthenshire Council Rights of Way Richard Jones Carmarthenshire Council Planning Rosie Carmichael Carmarthenshire Council Nia Phillips CCW Phil Stone CCW Huw Williams CCW

BT opened the meeting by stating that the RAMP is primarily an H&S document as well as a communications document. BT explained that the RAMP is currently in draft format and will have some changes but, it is not envisaged that there will be that much change.

SP Explained that the RAMP, for FCW, now clearly defines the areas for public liability and H&S and that this is the foremost and most paramount consideration for FCW.

RC & NP Completely understand that and wholeheartedly agree that H&S is exceptionally important, but - the RAMP does not outline any mitigation (or enhancement) proposed for impacts on individual recreation user groups of the forest.

Crow BT The safest way of controlling access is restricting access from the access points that could lead to the construction areas.

SP Forestry Commission Wales (FCW) work closely with the developer and wanted to clearly define roles and responsibilities. Anything that RWE do not take over FCW retain as managers of the land. There are numerous entry points into the forest, the proposed area is a sensible area, FCW will retain management of public access in other areas of forest and liability.

BT For the duration of construction it will become ‘excepted’ land under CROW. (Meaning that any access rights afforded under CRoW on ‘excepted’ land do not apply (but any other rights such as PRoWs are unaffected).

PS once the security fencing for imminent development is up then the land becomes excepted under Schedule 1, Part I, Paragraph 9 (development resulting in the land becoming excepted.) Upon completion the land is Brechfa Forest West Wind Farm Consultation Report 241

Appendix g (cont…)

excepted under Schedule 1, Part I, Paragraph 2 (buildings & curtilage.) Unless the turbines (& related buildings) are so close together that their curtilage touches/overlaps it will be the base & curtilage of each individual turbine/ related building that will be excepted.

RJ Did you look at splitting it to keep some bits open?

SP Looked at very closely on a forest-wide basis, could have permitted routes.

PS only land with buildings can be classed as excepted. Any land that is subject to development, including access tracks and fenced off storage areas, would also be included. Once the development phase has come to an end and fences come down those particular areas would revert back to being access land.

SP Can you apply for excepted land?

PS Not really- excepted land just happens. Would need apply under CROW for exclusion and restriction. Technically, however, if the land is excepted you don’t need to apply for a direction to exclude or restrict as it is already not access land because of being excepted. It is only the areas that are subject to development/building/works that would be excepted land and that would only be for the period of those works.

If any exclusion or restriction (not including excepted land) is to last for a period longer than 6 months FCW will have to consult with the Local Access Forum.

GC 28 day rule? Must be looked at iteratively – in a step-wise and progressive manner

PS FCW area- FCW are the relevant body, give exclusions and restrictions. Also need to apply least restrictive provision, would need consultation with user groups if restriction was for more than 6 months, CROW act covers access on foot only. If you do apply for an exclusion and restriction, liability is raised because there is less liability and exclusion under CROW. The liability is with FCW.

SP If apply under CROW, liability already minimised because will not be letting a lot of people in.

PS The three relevant bodies are FCW, CCW and the National Park Authorities. If somebody wants to exclude access, can apply to the relevant body and on FCW managed land that’s Forestry Commission Wales. FCW are familiar with the exclusions and restrictions for felling.

SP For felling in relation to development, the felling closures are quite extensive.

HW Need to ensure sensible areas are to be managed. Brechfa Forest West Wind Farm Consultation Report 242

Appendix g (cont…)

SP FCW can’t rely on a red line existing within the forest, health and safety has to be the priority.

PS Trespassers will be RWE’s concern.

RC At Alltwallis the track to FCW land wasn’t shut, this was a reasonable response in light of the nature and risk and level of usage.

SP FCW employees need to enter if managing the site. If they are harvesting the site they need to have a 200 metre buffer around the felling area. Currently small areas of felling are done under the 6 month rule, wind farm development will be a significant amount of felling- around 140 hectares- which is very different.

RC How long are you anticipating for felling?

BT Depends whether Schedule 1 birds are found, they could cause a delay.

SP Depends on timing, could be completed within 3-4 months if no gaps and delays. Need to balance, need for flexibility and timing of works.

HW If planning permission is granted in April you wouldn’t start the exclusion then, the date of commencement can be flexible.

DR It depends on the coupe planning process.

SP There are also practical issues because if advertising the closure UK wide, will need certainty of when things are going to happen- you wouldn’t want to be too flexible.

RC The advantages are that you will know where all the kit will be, risk is in a defined area for physical construction, felling is familiar in the forest but construction is new. Important to differentiate between the stages and the type of risks. The risks between the type of operation (felling, construction etc) need to be defined and the levels of risk at each stage need to be assessed.

HW Suggests that for construction you add a buffer.

RC once construction starts and felling is done, it should be clear where the vehicles need to be.

BT Construction is quite dispersed, difficult to manage, need to keep people safe.

RC Could fence all along tracks and around wind turbines. Don’t need to cast the net as wide as possible. Brechfa Forest West Wind Farm Consultation Report 243

Appendix g (cont…)

SP People won’t be there under CROW. Acknowledge that the diversions are very long.

PROW GC Excluding wider access under the CROW, diverting rights of way is a temporary alternative- can only be granted for six months. Carmarthenshire County Council would need to go to WAG for an extension if the diversion is longer than this. The walking groups will object if excluded from the whole block of forest. Will need to advertise and sort out a traffic regulation order which might result in a public inquiry. Small scale objections can be sort of taken onboard and don’t pose a huge concern but significant objections cannot be overlooked. A public inquiry would be needed to look to consider whether it’s reasonable. Having issues with Mynydd y Bettws at present.

SP Can the diversion orders form part of the IPC application?

BT Possibly include in the Development Consent Order (DCO). BT to confirm her own suggestion and whether diversion orders can form part of IPC submission.

RC At Alltwallis the path along the access track was fenced. Footpaths can remain open in high risk environments eg footpath crossing the A48- walkers use the RoW at their own risk.

GC Could phase the closures.

BT Difficulties involved with phasing e.g. PROW 13/77. Much of the main construction route impacts on this.

PS Should have surveyed the usage before now. The baseline needs to be robust. Is there any scope to re-calculate forest user numbers to get a more accurate representation of users groups and numbers?

RC In practice people are on the tracks.

PS Developer should pay for FCW to actively manage the routes.

SP FCW do not want their employees in the middle of the construction site.

RC FCW are used to felling.

SP Not used to construction, just felling.

PS Use more people to manage. Brechfa Forest West Wind Farm Consultation Report 244

Appendix g (cont…)

HW Not just construction traffic, its people accessing the site and causing liability issues.

GC Certain points such as crossings will need banksmen and warnings and lights. BT There is one place where this won’t be possible, 13/90 temporary diversion because of wind turbines 23 and 24 south of the existing right of way. When felling is taking place, this will be an exclusion zone and will need to close the right of way, no alternative but it is a temporary measure.

GC That has less impact, more concerned about 13/77.

PS All agree, some restrictions or closures are necessary but the developer should look to manage not FCW seek to close.

RC 13/77 is an important route. The impact on this route needs be adequately mitigated. Is there any scope to divert along the Pib?

BT There are agreed felling areas so rights of way may need to be closed during the felling.

PS We are all in agreement that restrictions on access have to be put in place, but there is scope to phase the closures so as to retain opportunities to use the forest for recreation purposes

PS Seem to be lots of assumptions on both sides.

BT It’s the draft document, it’s the nature of the document to have assumptions.

TD Very early in the process to be doing this, usually done by planning conditions, need to retain flexibility but provide comfort to consultees. Will depend on how its actual built.

SP Could consider permissive routes.

RC Where CROW closure is proposed, should look at the provision of permissive rights through the forest.

Action FCW & RWE to look at permissive routes elsewhere in the forest- provide in plan form.

BT There are lots of small tracks off the main roads- need to control these to stop people wandering into construction sites.

SP Want as few fences as possible to enable emergency access. Brechfa Forest West Wind Farm Consultation Report 245

Appendix g (cont…)

RC Look at how the forestry is used, people are used to events, signage etc. People are used to it. Not used to wholesale closure for 22 months.

BT RWE and FCW will discuss

RC Plan needs to include recreation not just rights of way, need to address impact on all users.

BT 13/77 crosses forest east to west.

GC Likely to be a fair bit of opposition to this proposed diversion due to the length proposed. Suggest that you try and accommodate something through the application site and manage that. The length of a diversion is an important consideration. This should not be excessive over and above the length of PROW it intends to divert.

PS If you try to divert along other rights of ways, some user groups will view as losing a route.

GC on a permanent basis yes this is the case, but not on a temporary basis. However, the diversion is too far.

RC 13/77 is a dull, flat route, the track along the Pib is more interesting.

SP Knowing the forest well, FCW have looked at alternatives.

RC What about the Pib? You could have a tunnel to avoid the construction areas and maintain safety for forest users?

CCC / CCW Agreement on bringing the diversion down the banks of the Pib

SP That’s close to the borrow pit and a new culvert.

NP This is where all construction traffic passes – heavily used route and poses the most risk in terms of management, but happy to discuss options

RC At least you would be focussing all problems in one place.

HW It’s the amount of construction traffic and proximity to the borrow pit in this location- it is a bottleneck.

GC Would wish to have a look at the Pib.

BT 13/90- how would this be diverted to the Pib route? Brechfa Forest West Wind Farm Consultation Report 246

Appendix g (cont…)

GC Is it possible to divert 13/90 down the edge of the site and bring it down to 13/82 then link up to the 13/77 diversion?

SP Would need a crossing point.

BT There is already a proposed crossing point further down the track.

RC Thinks it’s already access land associated with Alltwallis.

HW What is the minimum size for a footpath?

PS 1 metre

RC Is there a route from the Pib to Lady Megan Ride?

SP Look into dirt bike track.

GC It would be a better solution to divert towards the Pib as it is a more concentrated construction area at the Pib pinch point where there will be better scope for the crossing point to be manned. If other diversions are used then there could be difficulties manning the crossing points.

GC B OAT is a right of way. An ORPA hasn’t got confirmed status. Is an historic vehicle route- local community believe it should run through the forest. However under the 2006 legislation NERCA, it is intended to stop additional vehicle access routes being claimed.

BT 13/83 crosses this farm land- active management proposed gate man or traffic lights.

GC Does not see the need for a human presence there, signage and lights will be adequate. Needs ongoing monitoring if popularity increases.

PS Barrier to stop people wandering onto the track.

BT 13/92- temporary diversion due to felling buffers- take to top of the forest and back down.

GC on a temporary basis seems OK.

PS Not a great deal more distance.

RC Does right of way go down track? Need to show 200 metre buffer on felling area and change colour of substation. Brechfa Forest West Wind Farm Consultation Report 247

Appendix g (cont…)

SP If managed with a banksman, might not need felling distance.

RC Review all locations to consider whether 200 metre buffer is required.

HW Will need some sort of buffer

BT 13/91- Skims through corner of forest. 27/8 & 27/9 – SW corner of forest unaffected.

BT Do BOATs have reference numbers?

GC yes 17/22.

Pib HW Borrow pit makes it almost a mini opencast- the volume of traffic creates a pinch point for construction and for crossing.

SP Environmental impacts of a tunnel make this an unlikely option, it causes me concern.

NP Agree. If this is deemed as a viable option/route, then it will need to be managed exceptionally carefully. There is a huge potential for further environmental impact at this pinch-point.

RC Need to separate vehicles and pedestrians need a solution, need to go and have a look.

SP Will look at it.

GC Registered rights of way, temporary diversion or continue on registered route. Temporary fencing gap or gate- not stile- this is an LPA policy.

Signage BT Would like to have some discussion about the practical elements of the plan, ensuring people are aware of what’s happening even if content of the RAMP changes. Tower and Keepers are the only major receptor points. Additionally, several points to the south near Llanllawddog warrant additional signage.

RC one after the church, where there is better access.

SP Signage leading up to- indicating what’s happened and then what’s happening on closures.

RJ Should be distributed to the walking groups. Brechfa Forest West Wind Farm Consultation Report 248

Appendix g (cont…)

NP As many user groups as possible.

RC Schools, Filling stations, local businesses, bed and breakfasts and outdoor centres. The details of the diversions need to be explicit e.g. length of diversion.

SP Specific signage plan. Specifically for east as well.

GC Under IPC will there be a duty to publicise.

NP Important to positively promote what is happening in the forest. Acknowledgement, to the public, that you are altering the forest, but a positive commitment to make the forest even better for recreational users once the farm is operational. Positive marketing.

BT Planning Act refers to relevant legislation.

SP Signage of permissive routes and waymarking to be done early in the process (ahead of construction).

PS Any points of diversion need to say how great the diversion is e.g. in hours or miles.

RJ General concern regarding the content of the draft RAMP. CCC’s response to the Section 42 consultation (Planning Act 2008) requested Npower to look at improving and enhancing recreation and public access during the lifetime of the development. The submitted draft RAMP appears to be silent on post- construction mitigation and enhancement. CCC considers that such a large project which will have significant visual, landscape, ecological and recreational impacts should be supported by providing mitigation and enhancement opportunities to balance these impacts. At present CCC has not been given any details of proposed S.106 contributions to consider. This is concerning given the nature and scale of the project.

PS Are we Just looking at mitigation?.

RJ Impact on recreational users and different types of users, positive provisions in TAN and policy EN1, different types of walks i.e. educational walks, forestry walks, ecology walks, energy walks.

TD Elsewhere, similar mitigation has been low key, signage, information boards, interpretive information. Brechfa Forest West Wind Farm Consultation Report 249

Appendix g (cont…)

RJ, NP & RC But there are opportunities to make this scheme different to the others! More importantly, each scheme has to consider the site-specific impacts and therefore site-specific mitigation and compensation.

SP There are legacy implications.

RJ CCC would not wish to see visitors put off visiting the area. Ideas need to be brought to the table on how visitors could be stimulated in visiting the forest for recreational use..

BT What do you suggest in terms of mitigation and enhancement?

RJ The onus is on you as the developer to think creatively about mitigation and enhancement. Examples could be new trails within the forest e,g, nature trail with information boards, renewable energy trail where by process of generating electricity from wind is described.. GC Due to the increased horse activity in the area Npower should consider upgrading byway 17/22 to bridleway status.

GC Future plan for post construction to be included within AMP.

RC Need to maintain recreational experience, maintain tracks, keep tracks open, not necessarily new tracks, tracks other than FCW roads. Opportunities to soften some of the areas, Keepers/ Pib- this is not creating legacy because there are already tracks there.

RJ Need to improve orientation within the forest.

RC Felling will change the experience and perception of the forest.

SP Deliverable reducing signage in the forest because of CROW liability. 13/92 could do with some additional signage.

GC 13/77 is a long road. One request, asks FCW to consider upgrading the southern end of fp13/77 and fp13/90 (connects to an unmetalled highway and the A485) to bridleway status, lots of horse ownership to the north.

SP Forest has permissive rights for horseriders.

PS Permissive can be closed at any time.

RC Long distance ride Pembrokeshire to Powys, unclear status but need more information. Good mitigation if it goes through forestry block.

GC Currently a desire line. Brechfa Forest West Wind Farm Consultation Report 250

Appendix g (cont…)

RJ CCC might object on the basis of lack of enhancement. CCC will be objecting to the scheme based on the content of the draft RAMP. To overcome this CCC expect to see more details on mitigation and enhancement for the recreation user in addition to improved access and condition of paths etc.

GC Happy to speak to the BHS, would be positive if we could propose additional bridleway.

Cumulative Impact RJ Need to know area of unaffected forest. Npower need to provide a % ratio of affected and unaffected tracks and PROWs in order to assess the access as a resource.

BT Will get this information based on FCW data.

RC Length of track requested and all areas accessible under CROW. Need to provide approximate figure- some idea of the resource affected and unaffected areas.

PS How do the plans for BFW and BFE interact?

NP The separate plans need to work as individual plans mitigating for the impact of the specific scheme that they cover, but the two plans also need to be holistic with one another.

BT Need to consider the plans separately and cumulatively as both might not proceed. Need to be standalone documents- can’t be completely combined.

PS Need to consider separately and together look at whether Nant Yr Arian has a management plan in place. West needs to fit together with East, what is the resource left? Need to see plans together.

RC Need to establish if the area of forest in the middle can cope with the influx of people displaced by BFW and BFE. Need to provide comfort and context to BFE and link the two.

NP Will we be seeing a revised RAMP prior to submission?

BT Do not expect to consult on a further draft prior to submission.

Concern raised about the time scales and the actual delivery of the projects, will there be sequential or parallel build? Will one proceed without the other. Need to future proof and retain flexibility. Brechfa Forest West Wind Farm Consultation Report 251

APPENDIX H

Statement of Community Consultation

StAtEmEnt of CommunIty ConSultAtIon (SoCC) Brechfa forest West Wind farm

This Statement of Community Consultation explains how you Plan showing 5km buffer can comment on proposals for an application for a development consent order to be submitted by RWE npower renewables to for newsletter distribution develop and operate a wind farm at Brechfa Forest West.

Your comments on the proposals are important. They will be considered as RWE npower renewables refines and prepares the final application, to be made to the Infrastructure Planning Commission (IPC). There will be a 56 day formal consultation period. The start and end dates, as well as the locations of events and details about where you can access further information will be advertised before the consultation starts.

1. Project Summary The proposed project is located within Carmarthenshire, north east of Carmarthen on land managed by Forestry Commission Wales, centred around the Afon Pib Valley, east of Alltwalis. The proposed development includes 28 wind turbines and other infrastructure including access tracks, a meteorological mast, temporary construction compounds, an onsite substation and associated felling.

The project will have an installed capacity of more than 50 Megawatts and the application for the project will therefore be Legend determined by the Infrastructure Planning Commission (IPC) under the Planning Act 2008 (The Act). Roads Forest boundary The project will bring significant benefits through the 5km buffer generation of energy from renewable sources. The consultation materials will also set out the adverse impacts of the project, including impacts upon archaeology, ecology and landscape. 4. objectives • Community Liaison Group- NRL has invited representatives of local groups to participate. This group will meet NRL are also developing a wind farm at Brechfa Forest East. A The objectives of the consultation are: regularly throughout the project’s development, to discuss separate planning application will be made to Carmarthenshire • To inform local people about our proposals in a clear and specific issues, raise concerns and pose questions to NRL County Council, who will be responsible for the consultation concise way; representatives. This will enable two-way dialogue, allowing on that application. This document only relates to the Brechfa • To provide access to information to all people in the community; information to be disseminated into the local community. Forest West Wind Farm. • To provide an opportunity for local people to put forward their • Face-to-face meetings- NRL staff will be available to attend ideas and have a role in developing proposals; face-to-face meetings, on request, with individuals who may 2. Summary of the role of the Infrastructure Planning Commission • To provide an opportunity for local people to meet face-to- not be able to attend public exhibitions, for example, elderly face with NRL staff who are involved in the development; This application will be submitted to the IPC, an independent or disabled people. • To create a process through which local people can comment body that now decides applications for nationally significant on the formal proposals; infrastructure projects. Full details about the IPC can be found 7. Inclusive consultation • To respond to local people. on their website- http://infrastructure.independent.gov.uk/. In order to reach out to as many local people as possible, The IPC is required by law to make its decisions in accordance 5. Consultation approach NRL propose to use a wide range of consultation methods with National Policy Statements (NPSs) published by the as outlined above. government unless there are particular reasons for not doing so. In March 2010, prior to formal consultation, NRL undertook a period For this project, the relevant NPSs are the overarching energy of information provision for local people, including an indicative All local communications will be in clear, non-technical language NPS (EN-1) and the renewables NPS (EN-3). If there is no National turbine layout. Comments and suggestions were welcomed during and will be billingual. Welsh speaking staff will attend public Policy Statement in force at the time that the IPC complete their this early engagement, which included a newsletter, updates to the exhibitions and Community Liaison Group meetings. It is not examination, then they will make a recommendation to the project webpage, public exhibitions and media engagement. proposed to translate technical documents into Welsh. Secretary of State who will then determine the application. Formal consultation will take place when full proposal information 8. Who will we consult? The IPC strongly emphasises the need to engage early with local is available, including: site layout; the preliminary environmental communities so that they can have their say and help to shape information; mitigation. Activities will include a newsletter; updates NRL proposes to send leaflets to homes and businesses that proposals which will affect their area. to website; public exhibitions; formal press adverts; Community lie within a 5 kilometre buffer from the outer boundary of the Liaison Group meeting; technical documents to be made available. Brechfa Forest (excluding small, outlying blocks of Forestry This Statement of Community Consultation explains how the local Commission Wales land) as shown in the plan below: community will be consulted. A report on the consultation exercise 6. Consultation methods will be submitted to the IPC as part of the application which will Local representatives, including ward Councillors and • Newsletters- to be sent to the homes of people living within detail the results and explain how the final proposals have taken Community Councils will be consulted directly and have 5km of the Brechfa Forest boundary; comments into account. been invited to attend the Community Liaison Group. Local • Website- www.npower-renewables.com/brechfaforest to be organisations, including leisure users of the forest, across updated regularly; All statutory consultation responses relating to Brechfa Forest Carmarthenshire and the wider area will be consulted directly. • Points of contact- postal address, phone number, email address: West will be copied to Carmarthenshire County Council. Exhibitions will be held at appropriate venues within the 5km 3. Environmental Impact Assessment RWE npower renewables buffer, but will be open to all. Other forms of communication, Unit 22: Technium including the website and use of the designated address/ The project which NRL proposes to make application for Central Avenue phone number will not be geographically limited. a development consent order for is EIA development for Baglan Energy Park the purposes of Schedule 2 to the Infrastructure Planning Port Talbot All consultation responses will be taken into account, whether (Environmental Impact Assessment) Regulations 2009. SA12 7AX from people living in the immediate vicinity of the site, or from Accordingly, NRL has compiled the preliminary environmental Phone: 01639 816180 those living outside of this area. information required to assess the environmental effects of Email: [email protected] the development. 9. further information • Media engagement- press releases and formal adverts; That preliminary environmental information will be available • Exhibitions- to include plans, diagrams and descriptive Further background information about NRL’s consultation during the formal consultation period at a range of locations information. A programme of public exhibitions will be held. proposals is included in the ‘Proposals for determining the and details of how you can comment on that information will be Visitors will be able to discuss the proposals with NRL staff; content of the Statement of Community Consultation’ publicised as outlined in this document before the consultation • Making technical documents available, including preliminary document which is available on our website- period commences. A non-technical summary document will be environmental information, at a range of locations www.npower-renewables.com/brechfaforest freely available. throughout the formal consultation period; Brechfa Forest West Wind Farm Consultation Report 252

APPENDIX H (CONT…)

DAtgAnIAD ynghylCh ymgynghorI â’r gymunED (Dyyâg) fferm Wynt GorlleWin coedWiG Brechfa

Mae’r Datganiad hwn ynghylch Ymgynghori â’r Gymuned Cynllun yn dangos y (DYYÂG) yn esbonio sut y gallwch gynnig sylwadau ar y cynigion ar gyfer cais am orchymyn caniatâd datblygu a glustogfa o 5km ar gyfer gyflwynir gan RWE npower renewables i ddatblygu a rhedeg ymgynghori uniongyrchol fferm wynt yng Ngorllewin Coedwig Brechfa.

Mae’ch sylwadau chi ar y cynigion yn bwysig. Cânt eu hystyried wrth i RWE npower renewables fireinio a pharatoi’r cais terfynol a wneir i’r Comisiwn Cynllunio Seilwaith (CCS). Bydd cyfnod ymgynghori ffurfiol o 56 diwrnod. Cyn dechrau’r ymgynghoriad, byddwn yn hysbysebu dyddiadau dechrau a diwedd yr ymgynghori, ynghyd â lleoliadau’r cyfarfodydd a manylion y mannau lle cewch ragor o wybodaeth.

1. Crynodeb o’r Prosiect Bwriedir datblygu’r prosiect yn Sir Gaerfyrddin, i’r gogledd ddwyrain o Gaerfyrddin ar dir a reolir gan Gomisiwn Coedwigaeth Cymru, o gwmpas cwm Afon Pib, i’r dwyrain o Alltwalis. Mae’r datblygiad arfaethedig yn cynnwys 28 o dyrbinau gwynt a seilwaith arall yn cynnwys lonydd mynediad, mast meteorolegol, ierdydd adeiladu dros dro, is-orsaf ar y safle, a gwaith torri coed cysylltiedig.

Gan y bydd y prosiect yn gallu cynhyrchu dros 50 Megawat, Allwedd yr CCS fydd yn penderfynu ar y cais o dan Ddeddf Cynllunio 2008 (y Ddeddf). Ffyrdd Ffin y goedwig Daw’r prosiect â manteision sylweddol yn ei sgil trwy gynhyrchu Clustogfa o 5km ynni o ffynonellau adnewyddadwy. Bydd y defnyddiau ymgynghori yn cyfeirio at effeithiau niweidiol y prosiect hefyd, yn cynnwys yr effaith ar archaeoleg, ecoleg a’r dirwedd. 4. Amcanion • Bydd dogfennau technegol, yn cynnwys gwybodaeth amgylcheddol ragarweiniol, ar gael mewn nifer o wahanol Mae NRL yn datblygu fferm wynt yn Nwyrain Coedwig Brechfa Amcanion yr ymgynghoriad yw: fannau trwy gydol y cyfnod ymgynghori ffurfiol; hefyd. Gwneir cais cynllunio ar wahân am hwnnw i Gyngor Sir • Rhoi gwybod i bobl yr ardal am ein bwriadau mewn ffordd • Grŵp Cyswllt Cymunedol – mae NRL wedi gwahodd Caerfyrddin a nhw fydd yn gyfrifol am ymgynghori ar y cais glir a chryno; cynrychiolwyr o grwpiau lleol i gymryd rhan. Bydd y grŵp hwnnw. Dim ond at Fferm Wynt Gorllewin Coedwig Brechfa y • Sicrhau bod gwybodaeth ar gael i bawb yn y gymuned; hwn yn cwrdd yn rheolaidd tra bydd y prosiect yn datblygu, i mae’r ddogfen hon yn sôn. • Rhoi cyfle i bobl yr ardal gyflwyno’u syniadau a chwarae rhan drafod materion penodol, i godi pryderon ac i ofyn cwestiynau yn y gwaith o ddatblygu cynigion; i gynrychiolwyr NRL. Felly, bydd y ddwy ochr yn siarad â’i 2. Crynodeb o swyddogaeth y Comisiwn Cynllunio Seilwaith (CCS) • Rhoi cyfle i bobl yr ardal gwrdd wyneb yn wyneb â rhai o staff gilydd a bydd gwybodaeth yn cael ei rhannu â’r gymuned leol. NRL sy’n ymwneud â’r datblygiad; Caiff y cais hwn ei gyflwyno i’r Comisiwn Cynllunio Seilwaith, sef • Cyfarfodydd wyneb yn wyneb. Bydd modd gofyn i staff NRL • Creu proses y gall pobl yr ardal ei dilyn i gynnig sylwadau am y corff annibynnol sy’n penderfynu ar geisiadau am brosiectau ddod i gyfarfodydd wyneb yn wyneb gyda phobl sy’n methu cynigion ffurfiol; seilwaith cenedlaethol eu harwyddocâd. Ceir manylion llawn yr dod i’r arddangosfeydd cyhoeddus – pobl oedrannus neu • Ymateb i bobl yr ardal. CCS ar ei wefan: http://infrastructure.independent.gov.uk/. Mae’r anabl, er enghraifft. gyfraith yn mynnu bod yr CCS yn gwneud ei benderfyniadau yn 5. y drefn ar gyfer ymgynghori unol â Datganiadau Polisi Cenedlaethol (DPCs) a gyhoeddir gan 7. ymgynghori cynhwysol y llywodraeth os nad oes rhesymau neilltuol dros beidio â Ym mis Mawrth 2010, cyn y cyfnod ymgynghori ffurfiol, bu Er mwyn cyrraedd cynifer o bobl yr ardal ag sy’n bosib, gwneud hynny. Yn achos y prosiect hwn, y Datganiadau Polisi NRL yn darparu gwybodaeth ar gyfer pobl yr ardal, yn cynnwys mae NRL yn bwriadu defnyddio nifer o wahanol ddulliau o perthnasol yw’r Datganiad cyffredinol ar ynni (EN-1) a’r cynllun yn rhoi syniad o leoliad y tyrbinau. Croesawyd sylwadau ymgynghori fel y nodir uchod. Datganiad ar ynni adnewyddadwy (EN-3). Os nad oes Datganiad ac awgrymiadau yn ystod y cyfnod cynnar hwn a oedd yn Polisi Cenedlaethol mewn grym pan fydd yr CCS yn cwblhau ei cynnwys darparu cylchlythyr, newyddion ar wefan y prosiect, Wrth gysylltu â phobl yr ardal, byddant yn defnyddio Cymraeg archwiliad, bydd yn gwneud argymhelliad i’r Ysgrifennydd arddangosfeydd cyhoeddus a sylw ar y cyfryngau. a Saesneg clir, heb lawer o eiriau technegol. Bydd aelodau o’r Gwladol a bydd yntau’n penderfynu ar y cais. staff sy’n siarad Cymraeg yn dod i’r arddangosfeydd cyhoeddus Cynhelir ymgynghoriad ffurfiol pan fydd yr holl wybodaeth a chyfarfodydd y Grŵp Cyswllt Cymunedol. Does dim bwriad i Mae’r CCS yn pwysleisio’n gryf bod angen tynnu’r cymunedau lleol ar gael, yn cynnwys: gosodiad y safle; yr wybodaeth gyfieithu dogfennau technegol i’r Gymraeg. i mewn i’r broses yn fuan fel y gallant ddweud eu dweud a helpu i amgylcheddol ragarweiniol; camau i leddfu’r effaith. Bydd y lunio’r cynigion a fydd yn effeithio ar eu hardal nhw. dulliau o roi gwybod yn cynnwys cylchlythyr; newyddion ar 8. Pwy fyddwn ni’n ymgynghori â nhw? y wefan; arddangosfeydd cyhoeddus; hysbysebion ffurfiol Mae’r Datganiad hwn ynghylch Ymgynghori â’r Gymuned yn yn y wasg; cyfarfod o’r Grŵp Cyswllt Cymunedol; darparu Mae NRL yn bwriadu anfon taflenni i gartrefi a busnesau sydd o esbonio sut y byddwn yn mynd ati i ymgynghori â’r gymuned. dogfennau technegol. fewn clustogfa o 5km o gwmpas ffin allanol Coedwig Brechfa (ac Caiff adroddiad ar yr ymgynghoriad ei gyflwyno i’r CCS fel rhan eithrio blociau bach o dir Comisiwn Coedwigaeth Cymru) fel y o’r cais. Bydd yn nodi’r canlyniadau ac yn esbonio sut y mae’r 6. Dulliau ymgynghori dangosir ar y cynllun isod: cynigion terfynol wedi talu sylw i’r sylwadau a wnaed. • Cylchlythyrau – i’w hanfon i gartrefi pobl sy’n byw o fewn 5km Maent yn bwriadu ymgynghori’n uniongyrchol â chynrychiolwyr i ffin Coedwig Brechfa; Anfonir copïau o’r holl ymatebion i’r ymgynghoriad statudol lleol, yn cynnwys Cynghorwyr wardiau a Chynghorau Cymuned • Y wefan - www.npower-renewables.com/brechfaforest i’w ynghylch Gorllewin Coedwig Brechfa at Gyngor Sir Caerfyrddin. ac fe wahoddwyd y rhain i ddod i’r Grŵp Cyswllt Cymunedol. diweddaru’n rheolaidd; Maent yn bwriadu ymgynghori’n uniongyrchol â mudiadau 3. Asesiad o’r Effaith Amgylcheddol • Dulliau cysylltu – cyfeiriad post, rhif ffôn, cyfeiriad e-bost: lleol, yn cynnwys rhai sy’n defnyddio’r goedwig at ddibenion hamdden, ledled Sir Gaerfyrddin a’r ardal ehangach. Mae angen cynnal Asesiad o Effaith Amgylcheddol y prosiect RWE npower renewables y mae’r NRL yn bwriadu gwneud cais am orchymyn caniatâd Unit 22: Technium Cynhelir arddangosfeydd mewn canolfannau addas o fewn datblygu ar ei gyfer at ddibenion Atodlen 2, Rheoliadau Central Avenue i’r glustogfa o 5km ond byddant ar agor i bawb. Bydd dulliau Cynllunio Seilwaith (Asesiad o’r Effaith Amgylcheddol) 2009. Parc Ynni Baglan eraill o gyfathrebu, yn cynnwys y wefan a’r cyfeiriad/rhif ffôn Felly, mae NRL wedi casglu’r wybodaeth amgylcheddol Port Talbot arbennig ar gael i bobl o bob ardal. ragarweiniol angenrheidiol er mwyn asesu effeithiau SA12 7AX amgylcheddol y datblygiad. Ffôn: 01639 816180 Caiff yr holl ymatebion i’r ymgynghoriad eu hystyried – y rhai gan Ebost: [email protected] bobl sy’n byw ger y safle a’r rhai gan bobl o’r tu allan i’r ardal. Bydd yr wybodaeth amgylcheddol ragarweiniol honno ar gael yn ystod y cyfnod ymgynghori ffurfiol mewn nifer o leoedd ac fe • Sylw yn y cyfryngau – datganiadau i’r wasg a 9. rhagor o wybodaeth gyhoeddir sut y gallwch gynnig sylwadau ar yr wybodaeth honno hysbysebion ffurfiol; cyn dechrau’r cyfnod ymgynghori fel y nodir yn y ddogfen hon. • Arddangosfeydd – i gynnwys cynlluniau, diagramau a Ceir rhagor o wybodaeth gefndir am gynlluniau NRL i Bydd dogfen yn rhoi crynodeb annechnegol ar gael i bawb. gwybodaeth ddisgrifiol. Cynhelir rhaglen o arddangosfeydd ymgynghori yn y ddogfen ‘Proposals for determining the content cyhoeddus. Bydd cyfle i ymwelwyr drafod y cynlluniau gyda of the Statement of Community Consultation’ sydd i’w gweld ar staff NRL; ein gwefan - www.npower-renewables.com/brechfaforest Brechfa Forest West Wind Farm Consultation Report 253

APPENDIX I

NEWSLETTER 1

Newyddion Pwˆer Gwynt | | Mawrth 2009 | www.npower-renewables.com/brechfaforest Newyddion Pwˆer Gwynt Cynnig ar gyfer Fferm Wynt Coedwig Brechfa

Fferm Wynt Ffynnon Oer ger Castell-nedd, De Cymru. Adeiladwyd gan RWE npower renewables yn 2006. Nid yw lluniau’r ffermydd gwynt gweithredol a geir yn y cylchlythyr hwn yn cynrychioli ymddangosiad Fferm Wynt arfaethedig Coedwig Brechfa. Cyflwyno RWE npower renewables

Hoffai RWE npower renewables gymryd y arfaethedig, nifer ac uchder y tyrbinau cyfle cynnar hwn i gyflwyno’i hun i’r bobl a gosodiad y safle, mae angen cynnal a’r cymunedau hynny sydd yng nghyffiniau astudiaeth amgylcheddol sylweddol ar Coedwig Brechfa, Sir Gaerfyrddin. y safle gan fod y cynllun yn ei ddyddiau Llanbedr Pont Steffan cynnar. O ganlyniad, nid oes gennym gryn

Mae’n bleser gennym ein bod wedi arwyddo lawer o fanylion manwl tan ein bod yn Llanybydder Cytundeb Opsiwn gyda Llywodraeth medru cynnal yr astudiaethau o ddifri. Llandysul Cynulliad Cymru gyda golwg ar ddatblygu Llangeler fferm wynt ar dir a rheolir gan Gomisiwn Fodd bynnag, rydym wrthi erbyn hyn yn Coedwigaeth Cymru (ar ran Llywodraeth dechrau cynnal yr astudiaethau, er mwyn i ni Galar Fferm Wynt Cynulliad Cymru) yn Nodyn Cyngor fedru rhannu’r manylion gyda chi cyn gynted Coedwig Brechfa Technegol 8 (TAN 8) Ardal Chwilio Strategol â phosib (rydym yn esbonio sut y byddwn G - Coedwig Brechfa yn Ne Orllewin Cymru. yn gwneud hynny yn ddiweddarach yn y cylchlythyr hwn.) Byddwn wedyn yn eich A40 Golyga hyn bod gennym ganiatâd i gwahodd i ddatgan eich barn a’ch syniadau Caerfyrddin Llanarthne ymchwilio’r safle a bwrw ymlaen â chaniatâd er mwyn ein galluogi i ddatblygu cynnig sy’n A40 cynllunio ar gyfer darpar fferm wynt yn gweddu i’r ardal, ac sy’n ystyried eich barn A48 yr ardal. o ddifri.

Cyn i ni gadarnhau unrhyw fanylion Edrychwn ymlaen at weithio gyda chi! Lleoliad safle Fferm Wynt Coedwig Brechfa, yn Ne sylweddol, megis maint y fferm wynt Orllewin Cymru. Brechfa Forest West Wind Farm Consultation Report 254

APPENDIX I (CONT…)

Wind Power News | | March 2009 |www.npower-renewables.com/brechfaforest 2

What’s happened so far? RWE npower

In 2005, Forestry Commission Wales (FCW) bidder in 2008. We are preparing to renewables in Wales invited renewable energy developers to commence the relevant environmental express their interest in developing studies required to develop a proposal at RWE npower renewables is one of wind farms on land managed by FCW and this site, and are seeking the initial opinions the UK’s leading renewable energy identified within TAN 8. RWE npower of key statutory organisations. companies, dedicated to generating renewables was announced as the preferred electricity using sustainable, environmentally friendly resources.

The proposed development area We develop, build and operate renewable energy schemes across The proposed project would be located the development of a successful wind farm, the UK, and are particularly proud within the county of Carmarthenshire, such as: of our heritage in Wales, where our between 11km and 20km south/south-west a) strong and persistent winds increasing oldest hydro-electric power station of Lampeter and between 12km and 23km the energy produced by the turbines has been operating for over 100 years. north east of Carmarthen. b) a large land area allowing a wind farm design with good separation distances Across Wales, we operate a number The proposed development area comprises from nearby properties of onshore wind farms, in north, mid two geographically distinct areas of upland c) access to the existing road network and south Wales. Our latest, Ffynnon plateau. The first area is centred around the d) it is outside of international, national Oer Wind Farm, north of Neath, Afon Pib Valley, east of Alltwalis and the and county landscape and ecological became fully operational in 2006, second area around Banc Llywelau, south designations and we have submitted proposals for of Rhydcymerau. e) Brechfa Forest lies within one of the three further wind farms, including SSAs (Area G) identified by the Welsh a major wind farm near Welshpool, The proposed development has a number Assembly Government (WAG) in TAN 8 as which incorporates one of the largest of key features, which are important for being suitable for large-scale wind farms. habitat restoration projects in Wales.

Offshore in Wales, our company About Technical Advice Note (TAN) 8 developed and operates the UK’s first major offshore wind farm, In its document Ministerial Interim Planning concluded that large scale wind farms North Hoyle, near Rhyl, we are Policy Statement on Renewable Energy should only be developed in specific areas currently constructing our second 2005, Welsh Assembly Government (WAG) of Wales, called Strategic Search Areas (SSAs). offshore wind farm, Rhyl Flats and recognizes that wind energy offers “the These were detailed in its TAN 8 planning we have recently received permission greatest potential for an increase in the policy document. TAN 8 identifies 7 areas to build a third, Gwynt y Môr. generation of electricity from renewable in Wales where wind farms could be best energy, at least in the short to medium term.” sited, by looking at factors such as wind We also operate six hydroelectric speeds, proximity to houses, and important power stations around Wales, and To enable wind to take this leading role in landscape or ecological designations. have based our UK operations the fight against climate change, WAG control centre at , Conwy. Finally, RWE npower renewables has a number of established office bases Ongoing Communications in North, South and Mid Wales, and employs over a third of its UK staff Throughout the development of our a series of public exhibitions later on in in Wales. proposals for Brechfa Forest, RWE npower the process. renewables will keep you up to date with progress and provide opportunities for We have set up a website containing dialogue with local communities and information about the scheme and stakeholders interested in the project. this will be regularly updated: We will do this through our newsletters, www.npower-renewables.com/brechfaforest updates to our website and through the local press. If you have any questions about the scheme, please don’t hesitate to contact us. As part of our commitment to developing By email: [email protected] the site in consultation with local Or by post: Brechfa Forest RWE npower communities, we will establish public renewables, Unit 22, Technium: Sustainable consultation opportunities, including Technologies, Central Avenue, Baglan Energy Park, Port Talbot, South Wales, SA12 7AX. Brechfa Forest West Wind Farm Consultation Report 255

APPENDIX I (CONT…)

Newyddion Pwˆer Gwynt | | Mawrth 2009 | www.npower-renewables.com/brechfaforest Newyddion Pwˆer Gwynt Cynnig ar gyfer Fferm Wynt Coedwig Brechfa

Fferm Wynt Ffynnon Oer ger Castell-nedd, De Cymru. Adeiladwyd gan RWE npower renewables yn 2006. Nid yw lluniau’r ffermydd gwynt gweithredol a geir yn y cylchlythyr hwn yn cynrychioli ymddangosiad Fferm Wynt arfaethedig Coedwig Brechfa. Cyflwyno RWE npower renewables

Hoffai RWE npower renewables gymryd y arfaethedig, nifer ac uchder y tyrbinau cyfle cynnar hwn i gyflwyno’i hun i’r bobl a gosodiad y safle, mae angen cynnal a’r cymunedau hynny sydd yng nghyffiniau astudiaeth amgylcheddol sylweddol ar Coedwig Brechfa, Sir Gaerfyrddin. y safle gan fod y cynllun yn ei ddyddiau Llanbedr Pont Steffan cynnar. O ganlyniad, nid oes gennym gryn

Mae’n bleser gennym ein bod wedi arwyddo lawer o fanylion manwl tan ein bod yn Llanybydder Cytundeb Opsiwn gyda Llywodraeth medru cynnal yr astudiaethau o ddifri. Llandysul Cynulliad Cymru gyda golwg ar ddatblygu Llangeler fferm wynt ar dir a rheolir gan Gomisiwn Fodd bynnag, rydym wrthi erbyn hyn yn Coedwigaeth Cymru (ar ran Llywodraeth dechrau cynnal yr astudiaethau, er mwyn i ni Pentre Galar Fferm Wynt Cynulliad Cymru) yn Nodyn Cyngor fedru rhannu’r manylion gyda chi cyn gynted Coedwig Brechfa Technegol 8 (TAN 8) Ardal Chwilio Strategol â phosib (rydym yn esbonio sut y byddwn G - Coedwig Brechfa yn Ne Orllewin Cymru. yn gwneud hynny yn ddiweddarach yn y cylchlythyr hwn.) Byddwn wedyn yn eich A40 Golyga hyn bod gennym ganiatâd i gwahodd i ddatgan eich barn a’ch syniadau Caerfyrddin Llanarthne ymchwilio’r safle a bwrw ymlaen â chaniatâd er mwyn ein galluogi i ddatblygu cynnig sy’n A40 cynllunio ar gyfer darpar fferm wynt yn gweddu i’r ardal, ac sy’n ystyried eich barn A48 yr ardal. o ddifri.

Cyn i ni gadarnhau unrhyw fanylion Edrychwn ymlaen at weithio gyda chi! Lleoliad safle Fferm Wynt Coedwig Brechfa, yn Ne sylweddol, megis maint y fferm wynt Orllewin Cymru. Brechfa Forest West Wind Farm Consultation Report 256

APPENDIX I (CONT…)

Newyddion Pwˆer Gwynt | Fferm Wynt Coedwig Brechfa | Mawrth 2009 | www.npower-renewables.com/brechfaforest 4

Beth sydd wedi digwydd hyd yma? RWE npower

Yn 2005, fe wnaeth Comisiwn Coedwigaeth mai RWE npower renewables oedd y renewables yng Cymru (CCC) wahodd datblygwyr ynni cynigydd a ffafriwyd. Rydym wrthi’n paratoi Nghymru adnewyddadwy i fynegi diddordeb mewn i ddechrau’r astudiaethau amgylcheddol datblygu ffermydd gwynt ar dir a rheolir perthnasol sydd eu hangen i ddatblygu cynnig RWE npower renewables yw un o gan Gomisiwn Coedwigaeth Cymru ac a ar gyfer y safle hwn, a hoffem glywed barn gwmnïau ynni adnewyddadwy nodwyd yn TAN 8. Cyhoeddwyd yn 2008 gychwynnol sefydliadau statudol allweddol. mwyaf blaenllaw’r DU. Rydym wedi ymrwymo i gynhyrchu trydan drwy ddefnyddio adnoddau cynaliadwy Yr ardal ddatblygu arfaethedig ecogyfeillgar.

Bydd y prosiect arfaethedig yn cael ei leoli a) gwyntoedd cryfion, parhaus a fydd yn Rydym yn datblygu, adeiladu a yn Sir Gaerfyrddin, rhwng 11km ac 20km i’r cynyddu’r ynni a gynhyrchir gan y tyrbinau gweithredu cynlluniau ynni de/ de-orllewin o Lambed a rhwng 12km a b) arwynebedd helaeth o dir sy’n caniatáu adnewyddadwy ledled y DU, 23km i’r gogledd ddwyrain o Gaerfyrddin. cynllun fferm wynt sydd â phellteroedd da ac rydym yn hynod falch o’n Mae’r ardal ddatblygu arfaethedig yn rhyngddo ac eiddo eraill sydd gerllaw treftadaeth yng Nghymru. Mae ein cynnwys dau lwyfandir sy’n amlwg iawn yn c) mynediad i’r rhwydwaith ffyrdd presennol gorsaf bwˆer trydan dwˆr hynaf ddaearyddol. Mae’r ardal gyntaf yn cwmpasu d) y mae’r ardal y tu allan i ddynodiadau wedi bod yn gweithredu yma ers Dyffryn Afon Pib, i’r dwyrain o Alltwalis, ac tirlun ac ecolegol rhyngwladol, dros 100 mlynedd. mae’r ail yn cwmpasu’r ardal o amgylch Banc cenedlaethol a sirol Llywelau, i’r de o Rydcymerau. e) Gorwedda Coedwig Brechfa o fewn un o’r Rydym yn gweithredu nifer o Ardaloedd Chwilio Strategol (Ardal G) a ffermydd gwynt artraeth yng Mae gan y datblygiad arfaethedig nifer o nodwyd gan Lywodraeth Cynulliad Cymru ngogledd, canolbarth a de Cymru. nodweddion allweddol sy’n bwysig o ran (LlCC) yn TAN 8, fel ardal sy’n addas i Daeth ein Fferm Wynt diweddaraf datblygu fferm wynt lwyddiannus, megis: ffermydd gwynt ar raddfa fawr. Ffynnon Oer, sydd i’r gogledd o Gastell-nedd yn hollol weithredol yn 2006, ac rydym wedi cyflwyno Ynglyˆn â Nodyn Cyngor Technegol (TAN) 8 cynigion am dair fferm wynt arall, gan gynnwys fferm wynt fawr ger Yn ei ddogfen Datganiad Polisi Cynllunio daeth LlCC i’r casgliad mai dim ond mewn Y Trallwng, sy’n corffori un o’r Interim ar Ynni Adnewyddadwy 2005, ardaloedd penodol o Gymru, a alwyd yn prosiectau mwyaf yng Nghymru yn mae Llywodraeth Cynulliad Cymru (LlCC) yn Ardaloedd Chwilio Strategol, y dylid nhermau adfer cynefinoedd. cydnabod mai ynni gwynt sy’n cynnig “y datblygu ffermydd gwynt mawr. Nodwyd potensial mwyaf ar gyfer cynyddu’r trydan a hyn yn nogfen polisi cynllunio TAN 8. Mae Mae ein cwmni wedi datblygu ac gynhyrchir o ynni adnewyddadwy, o leiaf yn TAN 8 yn dynodi’r 7 ardal orau yng Nghymru wrthi’n gweithredu fferm wynt y tymor byr i’r tymor canol.” ar gyfer lleoli ffermydd gwynt, drwy ystyried alltraeth fwyaf y DU, sef North Hoyle, ffactorau fel cyflymder gwynt, pa mor agos ger Y Rhyl. Ar hyn o bryd, rydym I alluogi gwynt i gymryd y rôl flaenllaw hon ydynt at dai cyfagos a dynodiadau tirwedd yn adeiladu ein hail fferm wynt yn y frwydr yn erbyn newid yn yr hinsawdd, ac ecolegol sydd o bwysigrwydd. alltraeth, Fflatiau’r Rhyl ac yn ddiweddar cawsom ganiatâd i Cyfathrebu Rheolaidd adeiladu’r trydydd, Gwynt y Môr. Rydym hefyd yn gweithredu chwe Drwy gydol y cyfnod y byddwn yn datblygu Rydym wedi sefydlu gwefan sy’n gorsaf bwˆer trydan dwˆr yng ein cynigion ar gyfer Coedwig Brechfa, cynnwys gwybodaeth ynglyˆn â’r Nghymru, a sefydlwyd ein canolfan bydd RWE npower renewables yn darparu’r cynllun, a bydd y gwefan hwn yn cael ar gyfer rheoli gweithrediadau’r DU newyddion diweddaraf am y cynnydd ar eich ei ddiweddaru’n rheolaidd: yn Nolgarrog, Conwy. Yn olaf, mae cyfer ac yn cynnig cyfleoedd i drafod gyda www.npower-renewables.com/brechfaforest gan RWE npower renewables nifer chymunedau lleol a rhanddeiliaid sydd â o swyddfeydd sefydledig yng diddordeb yn y prosiect. Byddwn yn gwneud Os oes gennych unrhyw gwestiynau ynglyˆn Ngogledd, De a Chanolbarth Cymru, hyn drwy ein cylchlythyron, diweddaru’n â’r cynllun hwn, mae croeso i chi gysylltu â ni ac mae dros draean o’r staff a gwefan a’r wasg leol. Drwy e-bost: [email protected] gyflogir yn y DU, yma yng Nghymru. Neu drwy’r post: RWE npower renewables – Fel rhan o’n hymrwymiad i ddatblygu’r Coedwig Brechfa, Uned 22, safle mewn ymgynghoriad â chymunedau Technium: Technolegau Cynaliadwy, lleol, byddwn yn creu cyfleoedd ar gyfer Central Avenue, Parc Ynni Baglan, ymgynghoriadau cyhoeddus , gan gynnwys Port Talbot, De Cymru, SA12 7AX. cyfres o arddangosfeydd cyhoeddus yn ddiweddarach yn y broses. Brechfa Forest West Wind Farm Consultation Report 257

APPENDIX J

NEWSLETTER 2

Wind Power News | Issue 02 | March 2010 1 www.npower-renewables.com/brechfaforest Wind Power News Brechfa Forest West Wind Farm and Brechfa Forest East Wind Farm proposals

Ffynnon Oer Wind Farm – 2 megawatt turbines, 58 metre tower, 70 metre rotor diameter. (Photographs of existing operational wind farms within this newsletter are not intended to represent the appearance, size or scale of the proposed Brechfa Forest Wind Farms.) Moving forward on proposals RWE npower renewables has spent the last year preparing Public exhibitions information in support of a proposal to install wind details turbines within Brechfa Forest, Carmarthenshire. Thursday 25th March 2010 2pm – 7pm We have looked at which locations within RWE npower renewables project Llansawel Village Hall the forest are most suitable for turbines manager Bethan Thomas explains: Llansawel and have now concluded that, due to “As the project manager for both sites Llandeilo geographic differences between the two I can be consulted on either proposal. SA19 7JH sites, there will be two separate wind farm Residents’ queries are likely to be similar sites and applications. The two proposed for the two proposed wind farms, so it sites would be: makes sense to present both projects at Friday 26th March 2010 – Brechfa Forest West Wind Farm, centred the same time. We sincerely hope that 2pm – 7pm around the Afon Pib valley, east of Alltwalis local people will take the opportunity Brechfa Church Hall – Brechfa Forest East Wind Farm, centred to come and meet us when our public Brechfa around Banc Llywelau, south of Rhydcymerau. exhibitions take place, and we will do our Carmarthenshire best to answer any questions at the time.” SA32 7RA Our studies so far suggest that Brechfa Forest West could accommodate 28 Final proposals are still some way off, turbines and Brechfa Forest East could and this newsletter provides information Saturday 27th March 2010 accommodate 12. about the current plans for the projects 12pm – 4pm and explains how they will progress. Cae’r Felin Primary School To ensure information about both proposals Importantly, it gives you details of Pencader is available to everyone at the same time, we upcoming public exhibitions. These Carmarthen have decided to discuss both sites together are an opportunity for local people to SA39 9AA when engaging with the local community. find out more about our proposals. Brechfa Forest West Wind Farm Consultation Report 258

APPENDIX J (CONT…)

Wind Power News | Issue 02 | March 2010 | www.npower-renewables.com/brechfaforest 2

What is the plan for Brechfa Forest? What are the

In November 2008, RWE npower Brechfa Forest East up to 12 turbines. Draft next steps? renewables signed an agreement which site plans showing the location of turbines gave the company the rights to potentially will be available at the public exhibitions RWE npower renewables will need to get develop a wind farm on land in Brechfa and can be seen on the next page. It is permission to construct and operate the Forest, which is managed by Forestry important to note that these are not the wind farms in Brechfa Forest. Commission Wales, on behalf of the Welsh final plans and they may change. Assembly Government. Due to the differences in size, each site Plans for both sites will be decided will follow a different application route. After initial studies, two geographically following discussions with Forestry For each application the local authority separate areas were identified for Commission Wales on how best to is formally involved. development; one in the western minimise the wind farms’ impacts on the block of the forest and the second in forest. This may be achieved, for example, As Brechfa Forest East is smaller, a local the eastern block. by positioning turbines in existing open planning application will be submitted to spaces or within areas recently felled where Carmarthenshire County Council for Studies suggest that Brechfa Forest West possible, and by maximising the consideration. could accommodate up to 28 turbines and use of existing access tracks. As Brechfa Forest West is likely to be over 50MW, it will need to be considered by the Infrastructure Planning Commission (IPC). Beginning on 1 March 2010, this newly created, independent body will consider applications for ‘Nationally Significant Infrastructure Projects’ - including large wind farms - and will make decisions based on policies which are set out by the Government. Carmarthenshire County Council will be involved throughout each step of the formal process.

The IPC takes a national approach to such applications, but local views remain very important to these proposals. In addition to Previously cleared areas could make good turbine locations, and minimise impacts on the forest the current round of public information sharing, RWE npower renewables will be conducting further consultation on our Checking every angle detailed plans once all project information is available and before submitting our Developing a wind farm involves many complex application to the IPC. technical and environmental studies.

Firstly, and most importantly, we have to taking place to ensure that we have thorough establish that there is a good wind resource. and comprehensive information. The next This is done using an anemometry mast, and stage of the process is the Environmental four have been installed in Brechfa Forest. Impact Assessment (EIA) which will look at the potential impacts of the proposed wind A ‘Scoping Request’ allows stakeholders farms and how these might be reduced. such as Carmarthenshire County Council, the Countryside Council for Wales and Once the EIA report is completed for the Environment Agency to provide their Brechfa Forest East, a planning application views on subjects that they think should will be prepared and submitted to be covered in environmental surveys, Carmarthenshire County Council. for example, ecology, ornithology, traffic and telecoms. Once the EIA report is completed for Brechfa Forest West, further consultation will take We use the scoping opinions to refine the place on the proposal, including more studies that we carry out. These studies exhibitions, before an application can be made IPC will determine “Nationally Significant started in winter 2008 and some are still to the Infrastructure Planning Commission. Infrastructure Projects” including large wind farms Brechfa Forest West Wind Farm Consultation Report 259

APPENDIX J (CONT…)

Wind Power News | Issue 02 | March 2010 | www.npower-renewables.com/brechfaforest 3 Project details The following maps have been simplified for use in this newsletter. More information about the turbine layouts will be available during the public exhibitions in March.

Specifications – Current layout could provide installed capacity for Brechfa Forest West wind farm – between 56 and 84 MW and Brechfa Forest East wind farm – between 24 and 36 MW1 Installed– capacity of each turbine: between 2 MW and 3 MW per turbine1 – Tip height: up to 145m

– Capable of providing the equivalent energy needs of up to: 33,900 homes (Brechfa Forest West); 14,500 homes (Brechfa Forest East)2

– Area covered by Potential Development Area Boundary: – Brechfa Forest West: 750 hectares Brechfa Forest West location and initial proposals for the layout of the turbines – Brechfa Forest East: 270 hectares

– Total area of Brechfa Forest: 5,700 hectares.

Footnotes: 1These predictions are specific to the site of RWE npower renewables’ proposed Brechfa Forest West and Brechfa Forest East wind farms as outlined in this newsletter.

2 Energy predicted to be generated by the proposal has been calculated using an assumed capacity factor of 26% (DTI Energy Trends UK regional capacity factors 1998-2004). For Brechfa Forest West, this is based on an installed capacity of 70MW. For Brechfa Forest East, this is based on an installed capacity of 30MW. For both sites, the energy capture predicted and hence derived homes equivalent or emissions savings figures may change as site specific information is gathered. Equivalent homes supplied is based on an annual electricity consumption per home of 4700 kWh. This figure is supported by recent domestic electricity consumption data available from The Digest of UK Energy Statistics and household estimates and projections from the UK Statistics Authority. Brechfa Forest East location and initial proposals for the layout of the turbines Brechfa Forest West Wind Farm Consultation Report 260

APPENDIX J (CONT…)

Wind Power News | Issue 02 | March 2010 | www.npower-renewables.com/brechfaforest 4

Why RWE npower renewables? Community

RWE npower renewables is one of the UK’s power projects, two offshore wind farms leading renewable energy developers and and seven onshore wind farms. benefits operators, committed to developing and operating wind farms and hydro plant to RWE is a major employer in Wales, operating If we receive planning consent, RWE npower produce sustainable electricity. four renewables office bases in South, Mid and renewables will offer a benefits package North Wales, the Aberthaw Power Station and designed to meet the needs of the local Recently we have begun working with marine two combined heat and power plants. In all, community. energy technology partners to deliver new RWE’s installed conventional and renewable wave and tidal stream power projects. Our energy generation in Wales supplies the RWE npower renewables has a long track Welsh portfolio includes six hydroelectric equivalent of around one-third of Wales’ record in delivering benefits for the electricity needs. communities in which it operates and we look forward to exploring what the priorities might be for people living near Key communication to the Brechfa Forest. Welsh Assembly Planning Policy for Renewable Getting involved in the communities in Energy (TAN 8) clearly explains that which we operate is key to our success, as it “experience has shown that there are allows us to develop positive relationships opportunities to achieve community benefits and understand local issues and concerns. through major wind farm development.”

RWE npower renewables is keen to meet The policy also states that “It is perfectly with local people living in and around the acceptable for a business to enter into a Brechfa Forest and will be holding public legally binding agreement with third parties information exhibitions in March, as detailed to deliver particular and agreed benefits on the front page. to the community.”

During these exhibitions, there will be At the exhibitions we hope to explain how our At a later and more appropriate point in the opportunities to find out more about the proposal will work alongside the forest project lifetime, we will begin a thorough proposed wind farm projects in their current process with the local community, to draft form. Following the exhibitions, In Autumn 2009, a Community Liaison determine how a Community Benefits progress will be communicated through Group was set up to enable local package could work best for the local area. newsletters, and the website will be updated representatives to meet and discuss the This would be entirely independent of the to provide ongoing information. progress of and ask questions about the planning process, because the offer of a proposals. The group is made up of Community Benefits package is not a material representatives from organisations including planning consideration. If you would like Community Councils, the County Council, recreational groups and the voluntary sector. Watch out for more information about the this newsletter process and how you can get involved locally If you would like to know more about the through the media, our website and other in larger print please CLG, please visit the group’s website: local communication channels. www.brechfaforestclg.org.uk contact us on: For more information about our approach to Community Benefits, visit the ‘Benefits’ 01738 825132 This booklet is printed on paper which is made from FSC section at our website: certified pulp and has been printed using vegetable inks. www.npower-renewables.com

Contact us E-mail [email protected] If you have any questions about the proposal then members of the project Telephone POSITIONAL team would be pleased to meet you at the 01639 816180 Post public exhibitions. Brechfa Forest RWE npower renewables, Web Unit 22, Technium: Sustainable Technologies, However, if you are unable to attend, Our website is regularly updated: Central Avenue, Baglan Energy Park, Port please don’t hesitate to contact the team. www.npower-renewables.com/brechfaforest Talbot, South Wales, SA12 7AX

Brechfa Forest West Wind Farm Consultation Report 261

APPENDIX J (CONT…)

Newyddion Ynni Gwynt | Rhifyn 02 | Mawrth 2010 1 www.npower-renewables.com/brechfaforest Newyddion Ynni Gwynt Cynigion Fferm Wynt Gorllewin Coedwig Brechfa a Fferm Wynt Dwyrain Coedwig Brechfa

Fferm Wynt Ffynnon Oer - tyrbinau 2 megawatt, tŵr 58 metr, rotor â diamedr o 70 metr (Ni fwriedir i’r lluniau o ffermydd gwynt gweithredol yn y cylchlythyr hwn gynrychioli ymddangosiad, maint na graddfa Fferm Wynt arfaethedig Coedwig Brechfa.) Symud ymlaen gyda’r cynigion Mae RWE npower renewables wedi treulio’r flwyddyn ddiwethaf yn paratoi gwybodaeth sy’n ategu cynnig i osod Manylion tyrbinau gwynt yng Nghoedwig Brechfa, Sir Gaerfyrddin. arddangosfeydd cyhoeddus Rydym wedi bod yn chwilio am y lleoliadau Esboniodd Bethan Thomas, rheolwr prosiect gorau yn y goedwig ar gyfer tyrbinau ac wedi RWE npower renewables: TDydd Iau 25ain Mawrth 2010 dod i’r casgliad, oherwydd gwahaniaethau “Fel y rheolwr prosiect ar gyfer y ddau safle 2pm – 7pm daearyddol rhwng y ddau safle, y bydd dau gellir siarad â mi am y ddau gais. Mae Neuadd Bentref Llansawel safle ar wahân ar gyfer y ffermydd gwynt ymholiadau’r trigolion yn debygol o fod yn Llansawel ynghyd â dau gais. Y ddau safle rydym am debyg ar gyfer y ddwy fferm wynt sy’n cael Llandeilo eu cynnig yw: eu cynnig, felly mae’n gwneud synnwyr i SA19 7JH – Fferm Wynt Gorllewin Coedwig Brechfa, gyflwyno’r ddau brosiect yr un pryd. Rydym wedi’i chanoli o amgylch dyffryn Afon Pib, yn gobeithio’n wir y bydd pobl leol yn Dydd Gwener 26ain Mawrth 2010 i’r dwyrain o Alltwalis manteisio ar y cyfle i’n cyfarfod yn ystod 2pm – 7pm – Fferm Wynt Dwyrain Coedwig Brechfa, yr arddangosfeydd cyhoeddus, a gwnawn Neuadd Eglwys Brechfa wedi’i chanoli o amgylch Banc Llywelau, ein gorau i ateb unrhyw gwestiynau’r Brechfa i’r de o Rydcymerau. adeg honno.” Sir Gaerfyrddin SA32 7RA Mae ein hastudiaethau hyd yma yn awgrymu Mae cryn dipyn o waith i’w wneud o hyd cyn y gallai 28 o dyrbinau gael eu gosod yng y bydd y cynigion terfynol yn barod, ac Dydd Sadwrn 27ain Mawrth 2010 Ngorllewin Coedwig Brechfa a 12 yn Nwyrain mae’r cylchlythyr hwn yn darparu 12pm – 4pm Coedwig Brechfa. gwybodaeth am gynlluniau cyfredol ar gyfer Ysgol Gynradd Cae’r Felin y prosiect ac yn egluro sut y byddant yn Pencader Er mwyn sicrhau bod y wybodaeth am y ddau datblygu. Yn bwysig, mae hefyd yn rhoi Caerfyrddin gais ar gael i bawb ar yr un pryd, rydym wedi gwybodaeth am arddangosfeydd cyhoeddus SA39 9AA penderfynu trafod y ddau safle gyda’i gilydd sydd i ddod. Mae’r rhain yn rhoi cyfle i bobl wrth ymgynghori a’r gymuned leol. leol ddod i wybod mwy am ein cynigion. Brechfa Forest West Wind Farm Consultation Report 262

APPENDIX J (CONT…)

Newyddion Ynni Gwynt | Rhifyn 02 | Mawrth 2010 | www.npower-renewables.com/brechfaforest 2

Beth yw’r cynllun ar gyfer Beth yw’r Coedwig Brechfa? camau nesaf?

Ym mis Tachwedd 2008, llofnododd RWE gael yn yr arddangosfeydd cyhoeddus a Bydd angen i RWE npower renewables gael npower renewables gytundeb yn rhoi’r gellir eu gweld ar y dudalen nesaf. Mae’n caniatâd i godi a gweithredu ffermydd hawl iddo ddatblygu fferm wynt o bosib ar bwysig nodi nad y cynlluniau terfynol yw’r gwynt yng Nghoedwig Brechfa. dir Coedwig Brechfa, a reolir gan Gomisiwn rhain ac y gallant eu newid. Coedwigaeth Cymru, ar ran Llywodraeth Oherwydd y gwahaniaethau mewn maint, Cynulliad Cymru. Penderfynir ar y cynlluniau ar gyfer y bydd y ceisiadau yn dilyn trywydd safleoedd yn dilyn trafodaethau gyda gwahanol o ran gwneud cais. Mae’r Yn dilyn astudiaethau cychwynnol, nodwyd Chomisiwn Coedwigaeth Cymru ar sut awdurdod lleol yn rhan ffurfiol o bob cais. dwy ardal wahanol i’w datblygu; un yn i leihau effaith y ffermydd gwynt ar y rhan orllewinol y goedwig a’r ail yn y goedwig. Gellir cyflawni hyn drwy, er Gan fod Dwyrain Coedwig Brechfa yn llai, rhan ddwyreiniol. Mae astudiaethau yn enghraifft, leoli’r tyrbinau mewn mannau bydd cais cynllunio lleol yn cael ei gyflwyno awgrymu y gallai 28 o dyrbinau gael eu agored sy’n bodoli eisoes neu ardaloedd i Gyngor Sir Caerfyrddin i’w ystyried. gosod yng Ngorllewin Coedwig Brechfa lle y torrwyd coed i lawr yn ddiweddar pan a 12 yn Nwyrain Coedwig Brechfa. Bydd yn bosibl, a thrwy wneud y defnydd mwyaf Gan fod Gorllewin Coedwig Brechfa yn cynlluniau drafft o leoliadau’r tyrbinau ar o’r traciau sy’n bodoli eisoes. debygol o fod dros 50MW, bydd angen iddo gael ei ystyried gan y Comisiwn Cynllunio Seilwaith. Bydd y corff annibynnol newydd hwn, o 1 Mawrth 2010, yn ystyried ceisiadau am ‘Brosiectau Seilwaith Cenedlaethol Bwysig’- gan gynnwys ffermydd gwynt mawr - ac yn gwneud penderfyniadau yn seiliedig ar bolisïau sydd wedi eu llunio gan y Llywodraeth. Bydd Cyngor Sir Caerfyrddin yn rhan o bob cam o’r broses ffurfiol.

Mae’r Comisiwn Cynllunio Seilwaith yn ymdrin â’r fath geisiadau ar sail genedlaethol, ond mae barn leol yn parhau i fod yn bwysig iawn i’r cynigion hyn. Yn ogystal â’r cylch cyfredol o rannu Gall ardaloedd o dir a gliriwyd eisoes fod yn lleoliadau da ar gyfer tyrbinau, a gall hyn lleihau’r effaith ar y goedwig gwybodaeth â’r cyhoedd, bydd RWE npower renewables yn cynnal ymgynghoriad pellach ar ein cynlluniau Edrych ar bopeth manwl pan fydd yr holl wybodaeth am y prosiect ar gael a chyn cyflwyno ein cais i’r Mae datblygu fferm wynt yn cynnwys llawer o Comisiwn Cynllunio Seilwaith. astudiaethau technegol ac amgylcheddol cymhleth.

Yn gyntaf, ac yn bwysicaf oll, rhaid i ni sicrhau cynnal er mwyn sicrhau bod gennym bod adnodd gwynt dichonadwy. Gwneir wybodaeth drylwyr a chynhwysfawr. hyn drwy ddefnyddio mast mesur gwynt, a Cam nesaf y broses yw’r Asesiad Effaith gosodwyd pedwar yng Nghoedwig Brechfa. Amgylcheddol (AEA) a fydd yn edrych ar effeithiau posibl y ffermydd gwynt Mae ‘Cais Cwmpasu’ yn galluogi’r arfaethedig, a sut y gellir eu lleihau. rhanddeiliaid megis Cyngor Sir Caerfyrddin, Cyngor Cefn Gwlad Cymru ac Asiantaeth yr Ar ôl cwblhau’r AEA ar gyfer Dwyrain Amgylchedd i ddatgan eu barn ar bynciau y Coedwig Brechfa, bydd cais cynllunio yn cael dylid eu hystyried yn yr arolwg amgylcheddol ei baratoi a’i gyflwyno i Gyngor Sir Caerfyrddin. yn eu barn hwy, e.e. ecoleg, ornitholeg, trafnidiaeth a thelecom. Ar ôl cwblhau’r AEA ar gyfer Gorllewin Coedwig Brechfa, bydd ymgynghori pellach Rydym yn defnyddio’r farn gwmpasu hon i ar y cais, gan gynnwys mwy o arddangosfeydd, fireinio’r astudiaethau rydym yn eu cynnal. cyn y gellir cyflwyno cais i’r Comisiwn Bydd y Comisiwn Cynllunio Seilwaith yn Dechreuwyd yr astudiaethau hyn yn ystod Cynllunio Seilwaith. penderfynu ar “Brosiectau Seilwaith Cenedlaethol gaeaf 2008 ac mae rhai yn parhau i gael eu Bwysig”, gan gynnwys ffermydd gwynt mawr Brechfa Forest West Wind Farm Consultation Report 263

APPENDIX J (CONT…)

Newyddion Ynni Gwynt | Rhifyn 02 | Mawrth 2010 | www.npower-renewables.com/brechfaforest 3 Manylion y prosiect Symleiddiwyd y mapiau canlynol ar gyfer y cylchlythyr hwn. Bydd rhagor o fanylion am leoliad y tyrbinau ar gael yn yr arddangosfeydd cyhoeddus ym mis Mawrth.

Manylebau – Gallai’r cynllun cyfredol ddarparu rhwng 56 ac 84 MW ar gyfer fferm wynt Gorllewin Coedwig Brechfa a rhwng 24 a 36 MW ar gyfer fferm wynt Dwyrain Coedwig Brechfa1 – Capasiti pob tyrbin wedi’i osod: rhwng 2 MW a 3 MW fesul tyrbin1 – Uchder blaen: hyd at 145m

– Yn gallu diwallu anghenion ynni cyfatebol hyd at: 33,900 o gartrefi (Gorllewin Coedwig Brechfa); 14,500 o gartrefi (Dwyrain Coedwig Brechfa)2

– Yr ardal o fewn Ffiniau Ardal a allai gael ei Datblygu: – Gorllewin Coedwig Brechfa: 750 hectar Lleoliad Gorllewin Coedwig Brechfa a chynllun arfaethedig cychwynnol y tyrbinau – Dwyrain Coedwig Brechfa: 270 hectar

– Cyfanswm maint ardal Coedwig Brechfa: 5,700 hectar.

Troednodiadau: 1 Mae’r rhagolygon hyn yn benodol i safle ffermydd gwynt arfaethedig RWE npower renewables yng Ngorllewin Coedwig Brechfa a Dwyrain Coedwig Brechfa fel yr amlinellir yn y cylchlythyr hwn.

2 Mae’r ynni y rhagwelir y caiff ei gynhyrchu gan y cynnig wedi’i gyfrifo gan ddefnyddio ffactor capasiti tybiedig o 26% (Ffactorau capasiti rhanbarthol Tueddiadau Ynni’r DU yr Adran Masnach a Diwydiant 1998-2004). Ar gyfer Gorllewin Coedwig Brechfa, mae hyn yn seiliedig ar gapasiti tyrbin wedi’i osod o 70MW. Ar gyfer Dwyrain Coedwig Brechfa, mae hyn yn seiliedig ar gapasiti tyrbin wedi’i osod o 30MW. Ar gyfer y ddau leoliad, mae’n bosibl y bydd newid o ran yr ynni a ragamcanir ac felly’r ffigurau cyfatebol ar gyfer cartrefi neu arbedion allyriadau wrth gasglu gwybodaeth am y lleoliad penodol. Seilir y ffigur cyfatebol a gyflenwir i dai ar ddefnydd pob cartref o drydan bob blwyddyn sef 4700 kWh. Cefnogir y ffigwr hwn gan ddata diweddar am ddefnydd domestig o drydan a gyhoeddwyd yn y Crynhoad o Ystadegau Ynni ar gyfer y DU ac amcangyfrifon ac amcanestyniadau mewn perthynas â chartrefi gan Awdurdod Ystadegau’r DU. Lleoliad Dwyrain Coedwig Brechfa a chynllun arfaethedig cychwynnol y tyrbinau Brechfa Forest West Wind Farm Consultation Report 264

APPENDIX J (CONT…)

Newyddion Ynni Gwynt | Rhifyn 02 | Mawrth 2010 | www.npower-renewables.com/brechfaforest 4

Pam RWE npower renewables? Manteision

RWE npower renewables yw un o ceir chwe’ phrosiect trydan dŵr, dwy fferm ddatblygwyr a gweithredwyr ynni wynt ar y môr a saith fferm wynt ar y tir. cymunedol adnewyddadwy blaenllaw’r DU, sydd wedi ymrwymo i ddatblygu a gweithredu Mae RWE yn gyflogwr mawr yng Nghymru, Os byddwn yn cael caniatâd cynllunio, bydd ffermydd gwynt a gwaith dŵr i gynhyrchu gyda phedair swyddfa ynni adnewyddadwy RWE npower renewables yn cynnig pecyn trydan cynaliadwy. yn y De, y Canolbarth, a’r Gogledd, Gorsaf buddion sydd wedi’i gynllunio’n arbennig i Ynni Aberddawan, a dau waith gwres ac ynni ddiwallu anghenion y gymuned leol. Yn ddiweddar, rydym wedi dechrau gweithio cyfunol. At ei gilydd, mae cynhyrchiad ynni gyda phartneriaid technoleg ynni’r môr i confensiynol ac adnewyddadwy RWE yng Mae gan RWE npower renewables enw da gyflwyno prosiectau ynni tonnau a llanw Nghymru yn cyflenwi tua un rhan o dair o am gynnig manteision i’r cymunedau y newydd. Yn ein portffolio ar gyfer Cymru anghenion trydan Cymru. mae’n gweithredu ynddynt, ac edrychwn ymlaen at ymchwilio i flaenoriaethau posibl y trigolion sy’n byw ger Coedwig Brechfa.

Cyfathrebu allweddol Mae Polisi Cynllunio Ynni Adnewyddadwy’r Cynulliad Cenedlaethol (TAN 8) yn nodi’n glir Mae ein cyswllt â’r cymunedau rydym bod profiad wedi dangos y gellir bod o fudd yn gweithredu ynddynt yn allweddol i’n i’r gymuned drwy ddatblygu ffermydd gwynt. llwyddiant, gan ei fod yn ein galluogi i ddatblygu perthynas gadarnhaol a deall Mae’r polisi hefyd yn datgan ei bod yn hollol materion a phryderon lleol. dderbyniol i fusnes lofnodi cytundeb rhwymol cyfreithiol â thrydydd parti er Mae RWE npower renewables yn awyddus i mwyn cynnig manteision penodol a chytûn gyfarfod â phobl leol sy’n byw yng nghyffiniau i’r gymuned. Coedwig Brechfa a byddwn yn cynnal arddangosfeydd gwybodaeth gyhoeddus ym Yn ystod yr arddangosfeydd, hoffem esbonio sut y Yn hwyrach ac ar adeg fwy priodol yn mis Mawrth, fel y nodir ar y dudalen flaen. bydd ein cynnig yn mynd law yn llaw â’r goedwig natblygiad y prosiect, byddwn yn dechrau proses fanwl gyda’r gymuned leol, i Yn ystod yr arddangosfeydd hyn bydd cyfle i bydd y wefan yn cael ei diweddaru er mwyn benderfynu ar y pecyn Manteision Cymunedol gael gwybod mwy am brosiectau’r ffermydd darparu gwybodaeth yn rheolaidd. mwyaf addas ar gyfer yr ardal leol. gwynt arfaethedig ar eu ffurf ddrafft gyfredol. Yn dilyn yr arddangosfeydd, caiff unrhyw Yn hydref 2009, sefydlwyd Grŵp Cyswllt Byddai hwn yn llwyr annibynnol ar y broses gynnydd a wneir ei rannu drwy gylchlythyrau a Cymunedol i alluogi cynrychiolwyr lleol i gynllunio, gan nad yw’r cynnig o becyn gyfarfod a thrafod datblygiadau a holi unrhyw Manteision Cymunedol yn ystyriaeth gwestiynau am y cynigion. Mae aelodau’r gynllunio berthnasol. Os hoffech gael grŵp yn cynnwys cynrychiolwyr o sefydliadau megis Cynghorau Cymuned, y Cyngor Sir, Bydd rhagor o wybodaeth am y broses a sut y cylchlythyr hwn grwpiau hamdden a’r sector gwirfoddol. y gallwch gymryd rhan yn ymddangos yn y cyfryngau lleol, ar ein gwefan a thrwy sianeli mewn print bras Am ragor o wybodaeth am y Grŵp Cyswllt cyfathrebu lleol eraill. mae croeso i chi Cymunedol, ewch i wefan y grŵp: www.brechfaforestclg.org.uk Am ragor o wybodaeth am ein dullo gysylltu â ni: weithredu o ran Manteision Cymunedol, Argraffwyd y llyfryn hwn ar bapur sydd wedi’i wneud ewch i’r adran ‘Benefits’ ar ein gwefan: 01738 825132 o fwydion sydd wedi eu hardystio gan yr FSC ac fe’i hargraffwyd gan ddefnyddio inc llysiau. www.npower-renewables.com

Cysylltu â ni E-bost [email protected] Os oes gennych unrhyw ymholiadau am y Ffôn POSITIONAL cynigion bydd aelodau’r tîm prosiect yn 01639 816180 Post fwy na pharod i gyfarfod â chi yn yr Y We RWE npower renewables Coedwig Brechfa, arddangosfeydd cyhoeddus. Fodd bynnag, Mae ein gwefan yn cael ei diweddaru’n Uned 22, Technium: Technolegau os na allwch ddod, mae croeso i chi rheolaidd: www.npower-renewables.com/ Cynaliadwy, Rhodfa Ganol, Parc Ynni Baglan, gysylltu â’r tîm. brechfaforest Port Talbot, De Cymru, SA12 7AX Brechfa Forest West Wind Farm Consultation Report 265

APPENDIX K

NEWSLETTER 3

Wind Power News | Issue 03 | March 2011 1 www.npower-renewables.com/brechfaforest Wind Power News

Ffynnon Oer wind farm near Neath, South Wales. Constructed by RWE npower renewables in 2006. Photographs of existing operational wind farms within this newsletter are not intended to represent the appearance of the proposed Brechfa Forest Wind Farm. Welcome to the Brechfa Forest West Wind Farm newsletter This February, RWE npower renewables is launching The consultation period will start on 10th February and will last for its formal consultation period for Brechfa Forest West. 56 days. All Consultation responses must be received by 5pm on 6th April to be considered. The Brechfa Background Forest West team look forward to RWE npower renewables is proposing to under the provisions of the Planning Act meeting you at our public exhibitions build a wind farm, with a generating 2008 (the Act). – details of which are included in this capacity of between 56 and 84 megawatts newsletter – and to discussing our (MW), at Brechfa Forest, Carmarthenshire, The Act requires applicants to carry out proposals for Brechfa Forest West. known as Brechfa Forest West Wind Farm. pre-application consultation on the This will involve the construction of 28 development proposal under Section 42 wind turbines, 9.1km of new access tracks of The Act. Groups that must be consulted we will consult local people on our plans to and the upgrade of around 12.7km of include local authorities, a prescribed list develop Brechfa Forest West Wind Farm. existing access tracks. Also construction of public and regulatory bodies and those of other wind farm components including who own or have an interest in the land Comments made during the consultation an onsite substation, hardstanding areas, affected by the project. process will be recorded and considered external transformers, underground cabling carefully by the project team. A consultation and one permanent wind monitoring mast. In addition, RWE npower renewables, as report will be prepared, setting out the the applicant, must consult with the local comments and feedback that has been As the generating capacity of the wind community under Section 47 of the Act. received and describing how the issues raised farm is over 50 megawatts (MW), the In November 2010, RWE npower renewables have been dealt with. The IPC must take into planning application will be determined published a Statement of Community account the consultation report in its by the Infrastructure Planning Commission Consultation (SoCC) which outlined how consideration of the application. Brechfa Forest West Wind Farm Consultation Report 266

APPENDIX K (CONT…)

Wind Power News | Issue 03 | March 2011 | www.npower-renewables.com/brechfaforest 2

– a non-technical summary of the draft What are we Environmental Statement – available in Public exhibitions English and Welsh details consulting on? – a draft Planning Statement setting out the planning context for the proposed Friday 18 February 2011 wind farm. 2pm – 8pm During the consultation period, we will be Brechfa Church Hall consulting local people, users of the forest We will be seeking opinions about the St. Teilo, Brechfa and statutory consultees about the Brechfa proposal, including ways in which it may Carmarthenshire, SA32 7BL Forest West Wind Farm project. be changed or improved. People may like to comment on how the benefits of the Saturday 26 February 2011 The Infrastructure Planning (Environmental scheme could be maximised or how impacts 10am – 3pm Impact Assessment) Regulations 2009 require can be minimised. Llanybydder Community School us to consult on ‘preliminary environmental Llanybydder, Carmarthenshire information’. For the purposes of this It is important to be clear about what we SA40 9RP consultation, the ‘preliminary environmental are and what we are not consulting on. information’ is a full draft Environmental The following table provides a breakdown Monday 28 February 2011 Statement for the site, setting out all of the of example subjects: 2pm to 8pm environmental work that has been completed Llanllwni Church Community Hall Consulting on Not consulting on at Brechfa Forest West to date. Llanllwni, Pencader Turbine layout The need for Carmarthenshire, SA39 9DR A number of documents will be available for renewable energy consideration during the consultation period: Siting of other Suitability of the Thursday 10 March 2011 infrastructure Brechfa Forest Strategic 2pm to 8pm – a full draft Environmental Statement Search Area for wind Llanpumsaint Memorial Hall which sets out the results of the farm development Heol Y Neuadd, Llanpumsaint assessment of likely impacts of the wind Surveys The grid connection Carmarthenshire, SA33 6BZ farm development on the environment, undertaken (subject to a including mitigation measures to minimise separate application) Saturday 19 March 2011 any predicted environmental impacts 12pm to 5pm Proposed mitigation Llanllwni Church Community Hall Llanllwni, Pencader Carmarthenshire, SA39 9DR

How are we consulting? Saturday 26 March 2011 12pm – 5pm Local consultation will take place as described Brechfa Church Hall in our SoCC, which is available on our website – St. Teilo, Brechfa Carmarthenshire, SA32 7BL www.npower-renewables.com/brechfaforest

Throughout the consultation period, the full Venues where documents will be available: Brechfa Community Shop consultation materials will be available at a Carmarthen Planning Office (Monday and Thursday 9am – 1pm, number of local venues. In addition, (9am – 5pm) Planning Services Tuesday and Saturday 9am – 12noon) consultation exhibitions will take place in Carmarthenshire County Council Brechfa, Carmarthen venues near to Brechfa Forest. 40 Spilman Street, Carmarthen, SA31 1LQ Carmarthenshire, SA32 7QY

The events will give local people the chance Carmarthen Library The Old School Community Centre to find out more about the plans to develop (Monday – Wednesday and Friday: 9.30am to (only between 9am-4pm) a new wind farm at Brechfa Forest West and 7pm, Thursday and Saturday: 9.30am – 5pm) Llansawel Road, Llanybydder formally give their views. St. Peters Street, Carmarthen, SA31 1LN SA40 9RN

Consultation materials will also be Llandeilo Planning Office(9am – 5pm) Gwyddgrug Post Office available on our website – Planning Services Civic Offices, (9am – 5pm) www.npower-renewables.com/brechfaforest Llandeilo, SA19 6HW Gwyddgrug, Pencader and copies of the non-technical summary Carmarthenshire, SA39 9AX are available free of charge on request. Llandeilo Library (Tuesdays and Fridays If you wish to purchase a copy of the 10am – 12noon, 1.30pm – 4.30pm, Pencader Post Office Environmental Statement, DVD copies 5pm – 7pm; Wednesdays 1.30pm – 5.30pm; & Albion Stores are available for £10 and in hard copy Saturdays 10am – 12noon) Albion Stores, Pencader format at a cost of £250. Crescent Road, Llandeilo, SA19 6HN Carmarthenshire, SA39 9ES Brechfa Forest West Wind Farm Consultation Report 267

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Wind Power News | Issue 03 | March 2011 | www.npower-renewables.com/brechfaforest 3 How to respond to the consultation

RWE npower renewables is keen for people to Please note that your feedback will be passed Contact us respond in writing. Comments can be made onto Carmarthenshire County Council and the Brechfa Forest West Consultation, by filling in a feedback form with a number of Infrastructure Planning Commission (IPC). RWE npower renewables Unit 22 set questions which can be sent out on Your comments and contact details may be Technium, Central Avenue request, is available on our website and can made public in a Consultation Report that will Baglan Energy Park be picked up at the exhibitions. Alternatively, document all comments received and how Port Talbot, SA12 7AX you can write to us or email us with your they have been acted upon. This report will feedback on the proposals. We request that be submitted to the IPC as part of the Brechfa Email: [email protected] any responses include contact information Forest West planning application. Phone (for information only): including a name and an address to which 01639 816180 any correspondence relating to the Consultation responses must be received by Website: www.npower-renewables.com/ consultation can be sent. 5pm on 6th April. brechfaforest Project details

The main components of the scheme are: – installation of 28 wind turbines (each with a maximum height to blade tip of 145 metres) – construction of approximately 9.1 km of new onsite access tracks and the upgrading of 12.7 km of existing access track – construction of an onsite substation, hardstanding areas, external transformers, underground cabling and one permanent wind monitoring mast – creation of two temporary construction compounds – working of one new borrow pit for the extraction of stone to be used elsewhere on the site – a period of felling works to take place prior to construction.

Brechfa Forest West could accommodate an installed capacity of between 56 and 84 megawatts (MW). The average annual generation expected at the site would be equivalent to the approximate domestic needs of up to 39,700 average UK households. This figure is based on annual electricity consumption per home of 4,700 kWh and is supported by recent domestic electricity consumption data available from The Digest of UK Energy Statistics and Brechfa Forest West – Site Layout household estimates and projections from the UK Statistics Authority. The wind farm will have an operational life of 25 years. At the end of this period, Subject to the IPC granting planning the turbines will be dismantled and removed permission, construction is likely to be from the site, unless further planning completed over 22 months. It is estimated permission is sought. that up to 150 people will be directly employed on the site during the 22 month construction period. Brechfa Forest West Wind Farm Consultation Report 268

APPENDIX K (CONT…)

Wind Power News | Issue 03 | March 2011 | www.npower-renewables.com/brechfaforest 4 Brechfa Forest East Wind Farm planning application Plans submitted for wind farm that could power 15,700 homes

RWE npower renewables is proposing another suitable for the development of large scale wind farm project at Brechfa Forest – Brechfa renewable energy schemes. Forest East. As part of the application, RWE npower RWE npower renewables has recently renewables has submitted a detailed submitted a planning application to Environmental Statement (ES). This brings Carmarthenshire County Council for Brechfa together the findings of a wide ranging Forest East Wind Farm, located to the South Environmental Impact Assessment (EIA), of Rhydcymerau. led by environmental consultants Land Use Consultants (LUC). Brechfa Forest East is a 12 turbine wind farm with an installed capacity of between 24 and Carmarthenshire County Council will now 36MW and, when fully operational, could be hold its own consultation on the application capable of generating enough energy to before it is considered by the Planning supply the needs of up to 15,700 average Committee, and will advertise details of UK households (1). where the application documents can be viewed. Any comments should be made in Prior to submission, a programme of public writing, and quoting the application reference engagement was held about the proposal, number (E/24195), to Head of Planning at which included a number of public exhibitions Planning Services, Carmarthenshire County in local venues. RWE npower renewables also Council, 40 Spilman Street, Carmarthen, set up a Community Liaison Group, involving SA31 1LE or by emailing planning@ a number of representatives from local carmarthenshire.gov.uk. Information about groups with an interest in RWE npower the application can also be found at: http:// renewables’ two proposals for Brechfa Forest. www.carmarthenshire.gov.uk/english/ environment/planning/applications/pages/ Jenny Prothero, Renewables Developer at viewapplicationsonline.aspx RWE npower renewables said: “Our proposal for Brechfa Forest East Wind Farm has been developed in consultation with Footnotes: Carmarthenshire County Council and Forestry 1Equivalent homes supplied is based on an annual electricity consumption per home of If you would like Commission Wales. The wind farm could 4700 kWh. This figure is supported by recent make an important contribution toward domestic electricity consumption data available from The Digest of UK Energy Statistics and this newsletter Wales’ renewable energy targets as well as household estimates and projections from the creating up to 100 jobs during construction.” UK Statistics Authority. in larger print please

Brechfa Forest East Wind Farm is in accordance contact us on: with the Welsh Assembly Government’s planning guidance Technical Advice Note 8 This booklet is printed on paper which is made from FSC 01738 825132 (TAN 8), which identifies Brechfa Forest as certified pulp and has been printed using vegetable inks.

Contact us E-mail [email protected] If you have any questions about the POSITIONAL proposal then members of the project Telephone team would be pleased to meet you at the 01639 816180 Post public exhibitions. Brechfa Forest RWE npower renewables, Web Unit 22, Technium: Sustainable Technologies, However, if you are unable to attend, Our website is regularly updated: Central Avenue, Baglan Energy Park, Port please don’t hesitate to contact the team. www.npower-renewables.com/brechfaforest Talbot, South Wales, SA12 7AX

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Newyddion Ynni Gwynt | Issue 03 | March 2011 1 www.npower-renewables.com/brechfaforest Newyddion Ynni Gwynt

Fferm Wynt Ffynnon Oer ger Castell-nedd, De Cymru. Adeiladwyd gan RWE npower renewables yn 2006. Nid yw lluniau’r ffermydd gwynt gweithredol a geir yn y cylchlythyr hwn yn cynrychioli ymddangosiad Fferm Wynt arfaethedig Coedwig Brechfa Croeso i gylchlythyr Fferm Wynt Gorllewin Coedwig Brechfa Ym mis Chwefror, mae RWE npower renewables yn lansio’i gyfnod ymgynghori ffurfiol ar gyfer Gorllewin Coedwig Brechfa.

Bydd y cyfnod ymgynghori yn Y Cefndir dechrau ar 10 Chwefror ac yn para am 56 o ddiwrnodau. Mae’n rhaid derbyn Mae RWE npower renewables yn bwriadu O dan Adran 42 o’r Ddeddf, mae’n ofynnol pob ymateb i’r Ymgynghoriad erbyn codi fferm wynt o’r enw Fferm Wynt Gorllewin i ymgeiswyr gynnal ymgynghoriad ar y 5pm ar 6 Ebrill er mwyn ei ystyried. Coedwig Brechfa, a all gynhyrchu rhwng cynlluniau datblygu cyn gwneud cais. 56 ac 84 megawat (MW), yng Nghoedwig Ymhlith y grwpiau y mae’n rhaid ymgynghori Mae tîm Gorllewin Coedwig Brechfa’n Brechfa, Sir Gaerfyrddin. Bydd y gwaith yn â nhw mae’r awdurdodau lleol, rhestr edrych ymlaen at gwrdd â chi yn ein cynnwys codi 28 tyrbin gwynt, creu 9.1km benodol o gyrff cyhoeddus a chyrff harddangosfeydd cyhoeddus – mae’r o lonydd mynediad newydd ac uwchraddio rheoleiddio, a pherchenogion a phobl manylion yn y cylchlythyr hwn – ac at tua 12.7km o lonydd mynediad sydd yno sydd â buddiant yn y tir y mae’r prosiect eisoes. Yn ogystal bydd angen elfennau eraill yn effeithio arno. drafod ein cynlluniau ar gyfer o’r fferm wynt yn cynnwys is-orsaf ar y safle, Gorllewin Coedwig Brechfa. darnau o lawr caled, trawsnewidyddion Yn ogystal, mae’n rhaid i RWE npower allanol, ceblau tanddaearol ac un mast renewables, sef yr ymgeisydd, ymgynghori parhaol i fonitro’r gwynt. â’r gymuned leol o dan Adran 47 o’r Ddeddf. Caiff y sylwadau a wnaed yn ystod y broses Ym mis Tachwedd 2010, cyhoeddodd RWE ymgynghori eu cofnodi a’u hystyried yn Gan y bydd y fferm wynt yn gallu cynhyrchu npower renewables Ddatganiad ynghylch ofalus gan dîm y prosiect. Caiff adroddiad ei dros 50 megawat (MW), y Comisiwn Cynllunio Ymgynghori â’r Gymuned (SoCC) yn lunio ar yr ymgynghoriad, yn nodi’r sylwadau Seilwaith (IPC) fydd yn penderfynu ar y cais amlinellu’r ffordd y byddwn yn ymgynghori a’r ymateb a gafwyd ac yn disgrifio sut y cynllunio o dan ddarpariaethau Deddf â’r bobl leol ar ein cynlluniau i ddatblygu deliwyd â’r materion a godwyd. Bydd raid Cynllunio 2008 (y Ddeddf). Fferm Wynt Gorllewin Coedwig Brechfa. i’r IPC dalu sylw i’r adroddiad ar yr ymgynghoriad wrth ystyried y cais. Brechfa Forest West Wind Farm Consultation Report 270

APPENDIX K (CONT…)

Newyddion Ynni Gwynt | Issue 03 | March 2011 | www.npower-renewables.com/brechfaforest 2

Beth rydyn ni’n ymgynghori arno? Arddangosfeydd Cyhoeddus Yn ystod y cyfnod ymgynghori, byddwn – Datganiad Cynllunio drafft yn nodi cyd- yn ymgynghori â phobl leol, defnyddwyr destun cynllunio’r fferm wynt arfaethedig. Dydd Gwener 18 Chwefror 2011 y goedwig ac ymgynghoreion statudol 2pm – 8pm ynghylch prosiect Fferm Wynt Gorllewin Byddwn yn ceisio barn pobl am y cynllun, yn Neuadd yr Eglwys, Brechfa Coedwig Brechfa. cynnwys ffyrdd y gellir ei newid neu ei wella. Sant Teilo, Brechfa Efallai y bydd pobl yn dymuno awgrymu sut Sir Gaerfyrddin, SA32 7BL O dan y Rheoliadau Cynllunio Seilwaith (Asesu y gellid elwa i’r eithaf ar fanteision y cynllun Effeithiau Amgylcheddol) 2009, mae’n ofynnol neu leihau unrhyw effeithiau niweidiol. Dydd Sadwrn 26 Chwefror 2011 i ni ymgynghori ar ‘wybodaeth amgylcheddol 10am – 3pm ragarweiniol’. At ddibenion yr ymgynghoriad Mae’n bwysig deal beth yr ydym yn Ysgol Gymunedol Llanybydder hwn, mae’r ‘wybodaeth amgylcheddol ymgynghori arno a beth nad ydym yn Llanybydder, Sir Gaerfyrddin ragarweiniol’ yn golygu Datganiad ymgynghori arno. Mae’r tabl isod yn rhoi SA40 9RP Amgylcheddol drafft llawn ar gyfer y safle, enghreifftiau o’r pynciau: yn nodi’r holl waith amgylcheddol a wnaed Yn ymgynghori ar Ddim yn ymgynghori ar Dydd Llun 28 Chwefror 2011 yng Ngorllewin Coedwig Brechfa hyd yma. 2pm to 8pm Gosodiad Yr angen am ynni Neuadd Gymunedol Eglwys Llanllwni y tyrbinau adnewyddadwy Bydd nifer o ddogfennau ar gael i’w hystyried Llanllwni, Pencader yn ystod y cyfnod ymgynghori: Lleoliad Addasrwydd Ardal Sir Gaerfyrddin, SA39 9DR – Datganiad Amgylcheddol drafft llawn seilwaith arall Chwilio Strategol Co yn nodi canlyniadau’r gwaith o asesu edwig Brechfa ar gyfer Dydd Iau 10 Mawrth 2011 effeithiau tebygol datblygu’r fferm wynt datblygu ffermydd 2pm to 8pm ar yr amgylchedd, yn cynnwys camau gwynt Neuadd Goffa Llanpumsaint lliniaru i leihau unrhyw effeithiau Yr arolygon Y cysylltiad â’r grid Heol Y Neuadd, Llanpumsaint amgylcheddol disgwyliedig a gynhaliwyd (Bydd angen gwneud Sir Gaerfyrddin, SA33 6BZ – Crynodeb annhechnegol o’r Datganiad cais arall ar gyfer hyn) Amgylcheddol drafft – ar gael yn y Camau lliniaru Dydd Sadwrn 19 Mawrth 2011 Gymraeg a’r Saesneg arfaethedig 12pm to 5pm Neuadd Gymunedol Eglwys Llanllwni Llanllwni, Pencader Sir Gaerfyrddin, SA39 9DR

Sut yr ydym yn ymgynghori? Dydd Sadwrn 26 Mawrth 2011 12pm – 5pm Byddwn yn ymgynghori’n lleol fel y disgrifir yn ein Neuadd yr Eglwys, Brechfa SoCC sydd i’w weld ar ein gwefan – Sant Teilo, Brechfa Sir Gaerfyrddin, SA32 7BL www.npower-renewables.com/brechfaforest

Y Ganolfan Gymunedol Hen Ysgol Trwy gydol y cyfnod ymgynghori, bydd y Mannau lle bydd y dogfennau ar gael: (9am – 4pm) Heol Llansawel, Llanybydder defnyddiau ymgynghori i gyd ar gael mewn Swyddfa Cynllunio Caerfyrddin Sir Gaerfyrddin, SA40 9RN nifer o ganolfannau lleol. Yn ogystal, bydd (9yb hyd at 5yh) Gwasanaethau Cynllunio arddangosfeydd mewn canolfannau ger Cyngor Sir Caerfyrddin, 40 Heol Spilman Gwyddgrug Swyddfa’r Post Coedwig Brechfa. Caerfyrddin, SA31 1LQ (Dydd Llun – Sadwrn 7.30am – 8pm, Dydd Sul 9.30am – 8pm) Gwyddgrug ydd y rhain yn gyfle i bobl leol gael gwybod Llyfrgell Caerfyrddin Sir Gaerfyrddin, SA39 9AX mwy am y cynlluniau i ddatblygu fferm wynt (Dydd Llun – Dydd Mercher a dydd Gwener: newydd yng Ngorllewin Coedwig Brechfa ac 9.30am i 7pm, Iau a dydd Sadwrn: 9.30am Swyddfa Bost a Siop Pencader Albion i roi eu barn yn ffurfiol. – 5pm) Heol San Pedr, Caerfyrddin, SA31 1LN (Dydd Llun – Sadwrn 6.30am – 8pm, Dydd Sul 7am – 7pm) Stores Albion Bydd defnyddiau ymgynghori ar gael ar ein Swyddfa Cynllunio Llandeilo Pencader, Sir Gaerfyrddin SA39 9ES gwefan hefyd – www.npower-renewables. (9am – 5pm) Llandeilo Gwasanaethau com/brechfaforest ac mae copïau o’r Cynllunio Swyddfeydd Dinesig, SA19 6HW Llyfrgell Llandeilo crynodeb annhechnegol ar gael am ddim (Dydd Mawrth a Dydd Gwener 10am – 12 os gofynnwch amdanynt. Os hoffech brynu Bryn Stores canol dydd, 1.30pm – 4.30pm, 5pm – 7pm; copi o’r Datganiad Amgylcheddol, mae (Dydd Llun a Iau 9am – 1pm, dydd Mawrth 13:30 Dydd Mercher – 5.30pm; copïau ar DVD ar gael am £10 a chopïau a dydd Sadwrn 9am – 12 hanner dydd) Dydd Sadwrn 10am – 12 canol dydd) papur am £250. Brechfa, Caerfyrddin, Dyfed, SA32 7QY Heol Cilgant, Llandeilo SA19 6HN

Brechfa Forest West Wind Farm Consultation Report 271

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Newyddion Ynni Gwynt | Issue 03 | March 2011 | www.npower-renewables.com/brechfaforest 3

Cysylltu â ni Sut i ymateb i’r ymgynghoriad Brechfa Forest West Consultation, RWE npower renewables Uned 22 Mae RWE npower renewables yn awyddus a chyfeiriad ar gyfer anfon gohebiaeth am Technium, Central Avenue i bobl ymateb mewn ysgrifen. Gellir cyflwyno yr ymgynghoriad. Baglan Energy Park sylwadau trwy lenwi ffurflen ymateb sy’n Port Talbot, SA12 7AX cynnwys nifer o gwestiynau. Gallwn anfon Bydd unrhyw sylwadau a dderbynnir yn ystod copi o’r ffurflen atoch, mae ar gael ar ein yr ymgynghoriad hwn yn ymddangos yn E-bost: [email protected] gwefan neu gallwch gymryd copi mewn yr adroddiad ar yr ymgynghoriad i’r IPC, Rhif ffôn (er gwybodaeth yn unig): arddangosfa. Fel arall, cewch ysgrifennu atom yn cynnwys enwau a chyfeiriadau. 01639 816180 neu anfon neges e-bost â’ch ymateb i’r Gwefan: www.npower-renewables.com/ cynlluniau. Gofynnwn i chi roi eich manylion Mae’n rhaid derbyn ymatebion i’r brechfaforest cysylltu ar eich ymateb, yn cynnwys enw Ymgynghoriad erbyn 5pm ar 6 Ebrill.

Manylion y prosiect

Dyma brif elfennau’r cynllun: – Gosod 28 tyrbin gwynt (pob un yn mesur dim mwy na 145 metr i flaen y llafn) – Adeiladu tua 9.1km o lonydd mynediad newydd ar y safle ac uwchraddio 12.7km o’r lonydd mynediad sydd yno eisoes – Adeiladu is-orsaf ar y safle, darnau o lawr caled, trawsnewidyddion allanol, ceblau tanddaearol ac un mast parhaol i fonitro’r gwyn – Creu dwy iard adeiladu dros dro; – Cloddio un pwll benthyg newydd i dynnu cerrig i’w defnyddio mewn rhannau eraill o’r safle – Bydd cyfnod o gwympo coed cyn y gwaith adeiladu.

Gallai Fferm Wynt Gorllewin Coedwig Brechfa gynhyrchu rhwng 56 ac 84 megawat (MW). Byddai disgwyl i’r safle gynhyrchu digon o drydan mewn blwyddyn ar gyfartaledd i gyflenwi anghenion domestig hyd at 39, 700 o gartrefi cyffredin. Wrth gyfrif nifer y cartrefi y gellid eu cyflenwi, cymerir bod pob cartref yn defnyddio 4,700 kWh o drydan y flwyddyn. Mae’r ffigwr hwn yn cyfateb i’r data diweddar am swm y trydan a ddefnyddir mewn cartrefi yn y Digest of UK Energy Statistics ac amcangyfrifon ac Gorllewin Coedwig Brechfa – Gosodiad Y Safle amcanestyniadau gan Awdurdod Ystadegau’r DU. Bydd gan y fferm wynt oes weithredol o 25 mlynedd. Ar ddiwedd y cyfnod hwn, Os ceir caniatâd cynllunio gan yr IPC, mae’n caiff y tyrbinau eu tynnu i lawr a’u symud debygol y gwneir y gwaith adeiladu dros o’r safle os na wneir cais am ganiatâd gyfnod o 22 mis. Amcangyfrifir y bydd hyd at cynllunio pellach. 150 o bobl yn gweithio’n uniongyrchol ar y cynllun hwn ar y safle yn ystod y cyfnod adeiladu o 22 mis. Brechfa Forest West Wind Farm Consultation Report 272

APPENDIX K (CONT…)

Newyddion Ynni Gwynt | Issue 03 | March 2011 | www.npower-renewables.com/brechfaforest 4 Cyngor yn cofrestru cais cynllunio ar gyfer Fferm Wynt Dwyrain Coedwig Brechfa Cyflwyno cynlluniau ar gyfer fferm wynt a allai gyflenwi 15,700 o gartrefi

Mae gan RWE npower renewables gynlluniau Cynulliad Cymru, Nodyn Cyngor Technegol 8 ar gyfer fferm wynt arall yng Nghoedwig (TAN 8) sy’n nodi bod Coedwig Brechfa’n lle Brechfa – Dwyrain Coedwig Brechfa. addas i ddatblygu cynlluniau ynni adnewyddadwy mawr. Mae RWE npower renewables wedi cyflwyno cais cynllunio yn ddiweddar i Gyngor Sir Fel rhan o’r cais, mae RWE npower Caerfyrddin ar gyfer Fferm Wynt Dwyrain renewables wedi cyflwyno Datganiad Coedwig Brechfa, i’r De o Rydcymerau. Amgylcheddol (DA) manwl. Mae hwn yn dwyn ynghyd ganfyddiadau Asesiad eang Bydd 12 tyrbin yn Fferm Wynt Dwyrain o’r Effaith Amgylcheddol (AEA) o dan Coedwig Brechfa a gallai gynhyrchu rhwng 24 arweiniad yr ymgynghorwyr amgylcheddol a 36MW. Pan fydd yn gweithio’n llawn, gallai Land Use Consultants (LUC). gynhyrchu digon o ynni i ddiwallu anghenion hyd at 15,700 o gartrefi cyffredin (1). Yn awr, bydd Cyngor Sir Caerfyrddin yn cynnal ei ymgynghoriad ei hunan ar y cais cyn Cyn cyflwyno’r cais, cynhaliwyd rhaglen i’r Pwyllgor Cynllunio ei ystyried a bydd yn o weithgareddau i roi gwybod i’r cyhoedd cyhoeddi lle y gellir gweld dogfennau’r cais. am y cynllun, gyda nifer o arddangosfeydd Dylid cyflwyno unrhyw sylwadau mewn cyhoeddus mewn canolfannau lleol. Yn ysgrifen, gan nodi cyfeirnod y cais (E/24195), ogystal, sefydlodd RWE npower renewables i’r Pennaeth Cynllunio, Gwasanaethau Grŵp Cyswllt Cymunedol, gyda nifer Cynllunio, Cyngor Sir Caerfyrddin, 40 Heol o gynrychiolwyr o grwpiau lleol y mae Spilman. Caerfyrddin, SA31 1LE neu trwy a wnelont â dau gynllun RWE npower e-bostio [email protected]. Mae renewables ar gyfer Coedwig Brechfa. gwybodaeth am y cais i’w gweld yn: http:// www.carmarthenshire.gov.uk/english/ Meddai Jenny Prothero, Datblygwr Cynlluniau environment/planning/applications/pages/ Ynni Adnewyddadwy gydag RWE npower viewapplicationsonline.aspx renewables: “Cafodd ein cynlluniau ar gyfer Fferm Wynt Dwyrain Coedwig Brechfa eu Troednodiadau: Os hoffech gael datblygu mewn ymgynghoriad â Chyngor 1 Wrth gyfrif nifer y cartrefi y gellid eu cyflenwi, cymerir bod pob cartref yn defnyddio 4700kWh Sir Caerfyrddin a Chomisiwn Coedwigaeth o drydan y flwyddyn. Mae’r ffigwr hwn yn y cylchlythyr hwn Cymru. Gallai’r fferm wynt wneud cyfraniad cyfateb i’r data diweddar am swm y trydan a ddefnyddir mewn cartrefi yn y Digest of mewn print bras pwysig at dargedau ynni adnewyddadwy UK Energy Statistics ac amcangyfrifon ac Cymru yn ogystal â chreu hyd at gant amcanestyniadau gan Awdurdod Ystadegau’r DU. mae croeso i chi o swyddi yn y cyfnod adeiladu.” gysylltu â ni: Mae Fferm Wynt Dwyrain Coedwig Brechfa yn Argraffwyd y llyfryn hwn ar bapur sydd wedi’i wneud bodloni canllawiau cynllunio Llywodraeth o fwydion sydd wedi eu hardystio gan yr FSC ac fe’i 01738 825132 hargraffwyd gan ddefnyddio inc llysiau.

Cysylltu â ni E-bost [email protected] POSITIONAL Os oes gennych unrhyw ymholiadau am y Ffôn cynigion bydd aelodau’r tîm prosiect yn 01639 816180 Post fwy na pharod i gyfarfod â chi yn yr Y We RWE npower renewables Coedwig Brechfa, arddangosfeydd cyhoeddus. Fodd bynnag, Mae ein gwefan yn cael ei diweddaru’n Uned 22, Technium: Technolegau os na allwch ddod, mae croeso i chi rheolaidd: www.npower-renewables.com/ Cynaliadwy, Rhodfa Ganol, Parc Ynni Baglan, gysylltu â’r tîm. brechfaforest Port Talbot, De Cymru, SA12 7AX

Brechfa Forest West Wind Farm Consultation Report 273

APPENDIX L

Exhibition boards

Welcome to the Exhibition We want to know what you think

The purpose of this event is to provide you with an opportunity to learn more about our proposals so you can give us your feedback and help shape our application for Brechfa Forest West Wind Farm.

This exhibition will explain the scheme, with visual representations of the wind farm to show you what it might look like, along with general information about renewable energy and the Government policies guiding wind farm developments in Wales.

We also want to give you the opportunity to talk to us directly and ask questions so please feel free to do so as you take a look around.

We welcome feedback from you - please complete a feedback form and tell us your thoughts and suggestions about the project and the exhibition. Any comments received during this consultation will be provided in the consultation report to the Infrastructure Planning Commission (IPC), including names and addresses.

As the generating capacity of the wind farm is over 50 megawatts (MW), the planning application will be determined by the IPC under the provisions of the Planning Act 2008 (the Act).

The Act requires applicants to carry out pre-application consultation on the development proposal. Groups that must be consulted include local authorities, a prescribed list of public and regulatory bodies and those who own or have an interest in the land affected by the project.

In addition, RWE npower renewables, as the applicant, must consult with the local community under Section 47 of the Act. In November 2010, RWE npower renewables published a Statement of Community Consultation (SOCC) which outlined how we will consult local people on our plans to develop Brechfa Forest West Wind Farm.

Comments made during the consultation process will be recorded and considered carefully by the project team. A consultation report will be prepared, setting out the comments and feedback that has been received and describing how the issues raised have been dealt with. The IPC must take into account the consultation report in its consideration of the application. Turbines at RWE npower renewables’ Trysglwyn Wind Farm in North Wales. (Image is not intended to represent the appearance of the proposed Brechfa Forest West and Brechfa Forest East Wind Farms). Thank you for taking the time to attend this exhibition. Brechfa Forest West Wind Farm Consultation Report 274

APPENDIX L (CONT…)

About RWE npower renewables One of the leading renewable energy companies in Wales and the UK.

We are dedicated to developing, building and operating high quality, commercial-scale renewable energy schemes throughout the UK.

We have a strong track-record of working closely with the communities in which our projects are located. From the outset of a new wind farm project, we engage with the local community and continue to be involved once the wind farm is operational.

The Welsh Assembly Government’s Energy Policy Statement says that a modern society’s energy needs should come from low carbon, renewable sources. Our expertise and commitment to investing in Wales means we are at the forefront of helping the country to realise this ambition.

We are investing in new, renewable technologies including biomass, wave, tidal and micro-renewables.

We also support the development of the Wales supply chain – in January this year we hosted a supply chain development event for over 160 Welsh business delegates with Welsh Assembly Government. In September 2010, we awarded a contract worth £15 million to a cabling company based in Wrexham.

In Wales, we operate seven onshore and two offshore wind farms, and have six hydroelectric power stations. Across the UK, we have 43 renewable energy projects.

All of these projects contribute to meeting the UK’s energy demands and replace carbon-emitting electricity generation with clean, renewable energy. We currently generate a significant proportion of Wales’ renewable energy.

RWE npower renewables operates a portfolio of hydro, onshore and offshore wind across Wales. Brechfa Forest West Wind Farm Consultation Report 275

APPENDIX L (CONT…)

Technical Advice Note (TAN) 8 The policy environment

The Welsh Assembly Government (WAG) has produced a number of Technical Advice Notes (TANs) on a range of policy areas, and TAN 8, adopted in 2005, is on Renewable Energy.

In TAN 8, WAG recognises that wind energy will have a leading role in the fight against climate change. It concludes that large scale wind farms should be developed in specific areas of Wales, in what it calls Strategic Search Areas (SSAs).

All of the proposed Brechfa Forest West wind turbines are entirely within the boundaries of what has been identified as SSA G which has a capacity target of 90MW. Brechfa Forest West would make a significant contribution towards Wales’ target of generating seven terawatt hours (TWh) of electricity from renewable sources by 2020, and to the nation’s aspiration of generating as much electricity from renewable sources as it uses annually.

In TAN 8, WAG sets out the criteria by which the SSAs were chosen, including:

o areas with a good wind resource

o upland areas featuring a plateau-type landscape

o generally sparsely populated

o dominated by conifer plantation and/or improved/impoverished moorland

o a general absence of nature conservation or historic landscape designations

o of sufficient area to accommodate developments over 25MW, to achieve at least 70MW installed capacity and to meet the target capacity

o largely unaffected by broadcast transmission, radar, MoD Mid Wales Tactical Training Area (TTA) and other constraints. Brechfa Forest West Wind Farm Consultation Report 276

APPENDIX L (CONT…)

Brechfa Forest West Wind Farm The details

Brechfa Forest West Wind Farm will involve the construction of 28 wind turbines, new access tracks and the upgrade of some existing access tracks. The total development area will cover 750 hectares of the 5,700 hectare Brechfa Forest, while the footprint of the turbines and other infrastructure will be considerably less.

The proposed wind farm could accommodate an installed capacity of between 56 and 84 megawatts (MW). The average annual generation expected at the site would be equivalent to the approximate domestic needs of up to 39,700 average UK households.(1)

The main components of the scheme are:

• Installation of 28 wind turbines (each with a maximum height to blade tip of 145 metres (475.72 feet));

• Approximately 9.1 km of new onsite access tracks and the upgrading of 12.7 km of existing access tracks;

• An onsite substation, hardstanding areas, external transformers, underground cabling and one permanent wind monitoring mast;

• Creation of two temporary construction compounds;

• Working of one new borrow pit for the extraction of stone.

Subject to the granting of planning consent by the Infrastructure Planning Commission, construction is likely to be completed over 22 months - four months of ground clearance and preparation and 18 months of wind farm construction. Prior to this a period of felling works will take place.

It is estimated that up to 150 people could be directly employed on the site during the 22 month construction period. (Source: Brechfa Forest West Environmental Statement, February 2011)

The wind farm has been designed with an operational life of 25 years. At the end of this period the turbines will be dismantled and removed from the site, unless further planning permission is sought. It is estimated that the decommissioning of the wind farm will be carried out over a period of approximately 12 months. Turbines at RWE npower renewables’ Ffynnon Oer Wind Farm in South Wales. (Image is not intended to represent the appearance of the proposed Brechfa Forest West and Brechfa Forest East Wind Farms). (1)This figure is based on an annual electricity consumption per home of 4700 kWh and is supported by recent domestic electricity consumption data available from The Digest of UK Energy Statistics, as well as household estimates and projections from the UK Statistics Authority. Brechfa Forest West Wind Farm Consultation Report 277

APPENDIX L (CONT…)

Forestry Commission Wales (FCW)

Forestry Commission Wales is acting on behalf of the Welsh Assembly Government to ensure the development of wind farms on the woodland estate is legal, safe and practical.

Forestry Commission Wales has been working with renewable resources since its foundation over 90 years ago. Now, as Wales and the rest of the world face the challenge of climate change, the Welsh Assembly Government (WAG) has entrusted Forestry Commission Wales to explore new types of renewable resources which will enhance existing energy supplies.

Welsh Assembly Government Ministers directed Forestry Commission Wales to identify suitable companies to be awarded options to develop wind farms on the land managed on behalf of WAG. This was done to enable the WAG to meet its Renewable Energy targets in Strategic Search Areas (SSAs) selected under Technical Advice Note 8 (TAN 8).

The Wind Energy Programme (previously the National Forest Estate Wind Farm Programme) was established to achieve this in December 2005.

The Programme:

• Facilitates clear and consistent engagement and communication with internal and external stakeholders to enable them to understand FCW’s role in relation to wind farm development.

• Makes sure that FCW meets its statutory responsibilities as manager of public land with respect to wind farm development.

• Whilst the team has no influence over or responsibility for the outcome of the planning process, the Team works with developers to make sure that planning applications are acceptable to FCW and are in keeping with the Commission’s responsibilities and other relevant public policy in their planning applications.

In 2008, Option Agreements were signed with selected developers including RWE npower renewables (RWE NRL). In Brechfa Forest, the agreement gives RWE NRL the rights to apply for planning permission to develop wind farms within SSA G and an option to enter into a 25 year lease, should consent be received and a wind farm built.

A key part of the tender run by the Wind Farm Programme underlined that wind farm developments on land managed by FCW are intended to be an integrated part of the forest. That is, wind turbines within woodland rather than wind farms that replace woodland.

The wind farm sites being considered at Brechfa Forest are significantly smaller than the forest boundary. This means that development will be concentrated in smaller blocks, minimising impacts on the forest.

FCW will be working closely with RWE NRL to minimise any changes in land use from that which is indicated in the long-term Forest Design Plans (FDPs) for the Brechfa Forest. This will be achieved by, for example, placing turbines in appropriate open space; areas recently clear felled or locating turbines into crops by felling as few trees as possible.

Brechfa Forest will NOT be clear felled to accommodate wind farm development. Brechfa Forest West Wind Farm Consultation Report 278

APPENDIX L (CONT…)

The IPC Process The Infrastructure Planning Commission

RWE npower renewables is proposing to build a 28 turbine wind farm, with a generating capacity of between 56 and 84 megawatts (MW), at Brechfa Forest, Carmarthenshire, known as Brechfa Forest West Wind Farm. This will involve construction of 28 wind turbines, approximately 9.1km of new access tracks and the upgrade of approximately 12.7km of existing access tracks as well as other wind farm components including an onsite substation, hardstanding areas, external transformers, underground cabling and one permanent wind monitoring mast.

As the generating capacity of the wind farm is over 50 megawatts (MW), the planning application will be determined by the Infrastructure Planning Commission under the provisions of the Planning Act 2008 (the Act).

The Act requires applicants to carry out pre-application consultation on the development proposal. Groups that must be consulted include local authorities, a prescribed list of public and regulatory bodies and those who own or have an interest in the land affected by the project.

In addition, RWE npower renewables, as the applicant, must consult with the local community under Section 47 of the Act. In November 2010, RWE npower renewables published a Statement of Community Consultation (SOCC) which outlined how we will consult local people on our plans to develop Brechfa Forest West Wind Farm.

Comments made during the consultation process will be recorded and considered carefully by the project team. A consultation report will be prepared, setting out the comments and feedback that has been received and describing how the issues raised have been dealt with. The IPC must take into account the consultation report in its consideration of the application.

The Process

All applications made to the Infrastructure Planning Commission follow a prescribed route, set out below:

1. Pre-application stage – the IPC is notified of a proposal and it is added to the Commission’s Programme of Projects. The developer prepares the application and consults on it. RWE npower renewables’ plans for Brechfa Forest West Wind Farm are at the pre-application stage at the moment.

2. Acceptance stage – when RWE npower renewables submits its application for Brechfa Forest West to the IPC, the Commission will have 28 days to decide whether to accept the application for consideration or not. During this period, the IPC will assess whether the developer has consulted adequately, among other considerations.

3. Pre-examination stage – once the IPC has accepted the application, the general public will be able to provide their views on the proposals. Anybody wanting to have their say will need to register their interest via the IPC website (www.infrastructure.independent.gov.uk) or ask for the registration forms to be posted to them by calling the IPC Helpline (0303 444 5000) or by emailing [email protected]. Those that have registered to submit their views will be invited to attend a meeting on the application, chaired by an IPC Commissioner.

4. Examination stage – this stage lasts six months and those that have registered to submit their views will be given the opportunity to provide more details of their feedback in writing. Further meetings with the public may also be held.

5. Decision stage – the IPC may take three months to make its decision. Once a decision about an application has been issued any legal challenge must be made within six weeks. All decisions made by the IPC are published on its website, http://infrastructure.independent.gov.uk/. There is also further information on the website about the IPC and its role. Brechfa Forest West Wind Farm Consultation Report 279

APPENDIX L (CONT…)

Our consultation Giving your views

During the consultation period, we will be consulting local people, users of the forest and statutory consultees about Venues where documents will be available: the Brechfa Forest West Wind Farm project. The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 require us to consult on ‘preliminary environmental information’. For the purposes of this consultation, the Carmarthen Planning Office (9am to 5pm) Planning Services ‘preliminary environmental information’ is a full draft Environmental Statement for the site, setting out all of the Carmarthenshire County Council environmental work that has been completed at Brechfa Forest West to date. 40 Spilman Street Carmarthen, SA31 1LQ

A number of documents will be available for consideration during the consultation period: Carmarthen Library (Monday – Wednesday and Friday: 9.30am to 7pm, Thursday and Satur- • A full draft Environmental Statement which sets out the results of the assessment of likely impacts of the wind farm day: 9.30am – 5pm) development on the environment, including mitigation measures to minimise any predicted environmental impacts; St. Peters Street • A non-technical summary of the draft Environmental Statement- available in English and Welsh; Carmarthen SA31 1LN • A draft Planning Statement setting out the planning policy context for the proposed wind farm. Llandeilo Planning Office (9am – 5pm) We are now seeking opinions about the proposal, including ways in which it may be changed or improved. People may Planning Services Civic Offices like to comment on how the benefits of the scheme could be maximised or how impacts can be minimised. Llandeilo SA19 6HW It is important to be clear about what we are and what we are not consulting on. The following table provides a break- down of example subjects: Llandeilo Library (Tuesdays and Fridays 10am – 12noon, 1.30pm - 4.30pm, 5pm - 7pm; Wednesdays 1.30pm - 5.30pm; Saturdays 10am – 12noon) Crescent Road What we are consulting on What we are not consulting on Llandeilo SA19 6HN Turbine layout The need for renewable energy Siting of other infrastructure Suitabolity of the Brechfa Forest Strategic Search Areas for Brechfa Community Shop (Monday and Thursday 9am – 1pm, Tuesday and wind farm development Saturday 9am – 12noon) Brechfa Surveys undertaken The grid connection (subject to a separate application) Carmarthen Proposed mitigation Carmarthenshire SA32 7QY

How are we consulting? Pencader Post Office & Albion Stores (Opening hours: Monday – Saturday 6.30am – 8pm, Local consultation will take place as described in our SoCC, which is available on our website- Sunday 7am – 7pm) www.npower-renewables.com/brechfaforest Albion Stores Pencader Carmarthenshire Throughout the consultation period, the full consultation materials will be available at a number of local venues. In SA39 9ES addition, consultation exhibitions will take place in venues near to Brechfa Forest. The events will give local people The Old School Community Centre (only between 9am-4pm) the chance to find out more about the plans to develop a new wind farm at Brechfa Forest West and formally give their Llansawel Road views. Llanybydder SA40 9RN Consultation materials will also be available on our website- www.npower-renewables.com/brechfaforest and copies of Gwyddgrug Post Office (Opening hours: Monday – Saturday 7.30am - 8pm, the non-technical summary are available free of charge on request. If you wish to purchase a copy of the Environmental Sunday 9.30am – 8pm) Statement, DVD copies are available for £10. Gwyddgrug Pencader Carmarthenshire SA39 9AX Brechfa Forest West Wind Farm Consultation Report 280

APPENDIX L (CONT…)

The Environmental Statement (ES)

Protecting the environment is very important to us and we are committed to limiting the environmental impact of our activities – especially when developing a new wind farm.

Any company seeking planning consent to build a large wind farm must thoroughly investigate the effects of its proposals on the environment. An Environmental Statement (ES) providing details of these investigations and their conclusions must be submitted with the application for consent, forming a vital part of the planning process.

Building a new wind farm would be a major project and every effort would be made to keep any disruption that could be caused by construction and eventual operation to a minimum.

We are committed to constructing and operating all our projects in an environmentally sustainable way and would continue to work closely with the relevant authorities to achieve this goal.

RWE npower renewables has drafted an Environmental Statement (ES) for Brechfa Forest West Wind Farm, which assesses the potential impacts of the proposal, explains how these impacts would be mitigated and sets out any residual impacts.

These potential impacts were identified following an Environmental Impact Assessment (EIA), which was carried out by specialist consultants on behalf of RWE npower renewables. RWE npower renewables agreed which studies should be included in the EIA with Carmarthenshire County Council and a wide range of other interested parties.

The ES is based on the results of studies of the potential environmental impacts, and includes a description of how the studies were undertaken and any assumptions made during the assessment process. It sets out the results of the studies, including mitigation measures to minimise any predicted environmental impacts.

The areas assessed include:

• Historic Environment • Geology and Hydrology • Access, Traffic and Transportation • Infrastructure, Telecommunications, Television and Air Safeguarding Issues. • Public Access, Recreation and Socio-Economics • Land Use and Forestry • Non-Avian Ecology • Ornithology • Landscape and Visual Amenity • Noise and Vibration • Shadow Flicker. Brechfa Forest West Wind Farm Consultation Report 281

APPENDIX L (CONT…)

How impacts will be managed

Ecology Landscape Detailed ecological surveys have been undertaken to ensure that Brechfa Forest West Wind Farm RWE npower renewables has also commissioned a Landscape and Visual Impact Assessment to has been designed sensitively with a full understanding of the ecology within and around the consider the impact that the Brechfa Forest West Wind Farm development could have upon the site, to limit disturbance to wildlife as far as possible. landscape and the people who view that landscape. The Assessment forms part of the Environmental Statement. The following have been undertaken: The assessment is informed by current good practice guidance prepared by the Landscape • Habitat and vegetation surveys; Institute and the Institute of Environmental Management and Assessment (2002). • Breeding bird surveys; Photomontages have been prepared in accordance with Scottish Natural Heritage’s Visual • Wintering bird surveys; Representation of Windfarms Good Practice Guidance (2006). • Vantage point bird surveys; • Nightjar surveys; The assessment involved a desk study, field survey and computer modelling. The methodology • Raptor surveys; and choice of representative viewpoints for the assessment were adopted in • Bat surveys; response to comments received from surrounding Local Planning Authorities, the Countryside • Other mammal surveys (including badger, red squirrel, pine marten and dormouse); Council for Wales, and the National Trust. Photomontages and computer generated drawings • Great Crested Newt surveys. were produced for 31 viewpoints around the site to illustrate the likely nature of impacts.

Mitigation We have prepared this series of photomontages to illustrate how the Brechfa Forest West Wind Proposed mitigation measures include (please refer to ES for further information): Farm could look from a series of nearby viewpoints.

• Provision of an archaeological watching brief during construction in order to minimise potential impacts upon archaeological remains • Implementation of good pollution prevention practices during construction in order to minimise the potential for water pollution • Implementation of a Traffic Management Plan during construction to minimise traffic impacts • Installation of infra-red lighting on turbines to avoid disruption to military aircraft • Targeted bryophyte survey and translocation of at-risk populations as necessary to avoid the loss of county rarity bryophyte species • Surveying for Goshawk nest sites during the year of construction and stopping construction within 500m of any nest site during the breeding season to avoid disturbance of breeding.

An assessment of all these impacts can be found in the ES and in a Non Technical Summary of the ES. Please ask one of the RWE npower renewables team if you would like to view a copy today. We can also give you details of the website address where you can review the documents. Brechfa Forest West Wind Farm Consultation Report 282

APPENDIX L (CONT…)

Community Benefits from Brechfa Forest West

If we are successful in gaining consent for Brechfa Forest West Wind Farm, RWE npower Case Study – Bears Down Wind Farm - supporting environmental education renewables intends to offer a community benefits package to specifically meet the needs of the local community. Subject to the final installed capacity of the site we expect the Supporting environmental education Poltair School in Cornwall used their annual donation community benefit package to be worth around £350,000 each year that the site is from the Bears Down Wind Farm Community Fund to help fund an environmental project to operational. increase the students’ awareness of the world around them and help reduce CO2 emissions at the school – the Green Team. We expect this package would include: The Green Team has involved local children in activities such as planting trees, growing fruit • A one-off payment to support environmental education and energy efficiency activities in and vegetables, building a new pond, harnessing solar power, recycling and local schools; composting, harvesting rainwater and creating wildlife corridors in the school grounds. • Allocation of funding to cover the costs of administering the package; • The main package itself, which will be defined following local consultation. “The Green Team enables our students to actually put their ideas to the test on ways to reduce the school’s Carbon Footprint and make our school more sustainable,” said science teacher, The community benefit package would fulfil the guidelines laid out in the Welsh Assembly Mr Martin. “The students are doing a brilliant job and have already introduced a number of Government’s Technical Advance Note 8: projects that are making a real difference.”

• Benefits should be negotiated with appropriate and representative persons or bodies; Case study - Carno Wind Farm - saving lives • Benefits should be channelled through a regulated and properly constituted body or trust (this could include the local authority); Carno First Responder volunteers provide vital life saving treatment within the first minutes of • Benefits should be utilised for an agreed range of appropriate uses that would all fall an emergency before the emergency services arrive. within the definition of sustainable development; • At least part of any annual payment benefits should be invested in measures in the local A £2,000 grant from the Carno Wind Farm Community Fund helped the group to purchase a community. life saving defibrillator and oxygen set, protective clothing for volunteers and training equipment.

First Responders said “The grant from the Wind Farm Carno Community Fund has been invaluable in helping us purchase the equipment we need to carry out our work. It will be with us whenever needed and could help us to save lives in our community.” Brechfa Forest West Wind Farm Consultation Report 283

APPENDIX L (CONT…)

Brechfa Forest East Wind Farm Plans for Brechfa Forest East Wind Farm

RWE npower renewables is bringing forward proposals for two wind farms on separate sites in the Brechfa Forest – Brechfa Forest West, on which we are consulting here today, and Brechfa Forest East.

Located on Banc Llywelau in the Afon Pib Valley, Brechfa Forest East Wind Farm would have 12 turbines with an installed capacity of between 24 and 36MW. The average annual generation expected at the site would be equivalent to the needs of up to 15,700 average UK households. (1)

An exhibition on the plans was held in March 2010. In December 2010, RWE npower renewables submitted a planning application to Carmarthenshire County Council, for consideration under the Town and Country Planning Act.

Carmarthenshire County Council is currently carrying out its statutory consultation on this application. Members of the public are able to submit their comments to the Council. Any comments should be made in writing, and quoting the application reference number (E/24195), to Head of Planning, Planning Services, Carmarthenshire County Council, 40 Spilman Street, Carmarthen, SA31 1LE.

Additional information can be requested by the local authority if needed, and once it is satisfied that it has sufficient information, Carmarthenshire County Council will make a decision about the application. It may decide to attach conditions to the consent if it is granted.

(1)This figure is based on an annual electricity consumption per home of 4700 kWh and is supported by recent domestic electricity Turbines at RWE npower renewables’ Ffynnon Oer Wind Farm in South Wales. (Image is not intended to consumption data available from The Digest of UK Energy Statistics, as well as household estimates and projections from the UK Statistics represent the appearance of the proposed Brechfa Forest West and Brechfa Forest East Wind Farms). Authority. Brechfa Forest West Wind Farm Consultation Report 284

APPENDIX L (CONT…)

Have your say How to respond to the consultation

RWE npower renewables has launched its formal consultation period for the Brechfa Forest West Wind Farm proposal. The consultation period started on 10 February and will last for 56 days.

RWE npower renewables requests that people respond in writing. Comments can be made by filling in a feedback form with a number of set questions which is available on our website and can be picked up at the exhibitions today or can be sent out on request. Alternatively, you can write to us or email us with your feedback on the proposals. We request that any responses include contact information including a name and an address to which any correspondence relating to the consultation can be sent.

Any comments received during this consultation will be provided in the consultation report to the IPC, including names and addresses.

Please note that your feedback will be passed onto Carmarthenshire County Council and the Infrastructure Plan- ning Commission (IPC). Your comments and contact details may be made public in a Consultation Report that will document all comments received and how they have been acted upon. This report will be submitted to the IPC as part of the Brechfa Forest West planning application.

Consultation responses must be received by 5pm on 6th April.

Contact us: Brechfa Forest West Consultation, RWE npower renewables Unit 22: Technium, Central Avenue, Baglan Energy Park, Port Talbot, SA12 7AX

Email: [email protected]

Phone (for information only): 01639 816180 Turbines at RWE npower renewables’ Ffynnon Oer Wind Farm in South Wales. (Image is not intended to represent the appearance of the proposed Brechfa Forest West and Brechfa Forest East Wind Farms). Brechfa Forest West Wind Farm Consultation Report 285

APPENDIX L (CONT…)

Croeso i’r arddangosfa Mae arnon ni eisiau clywed eich barn

Diben yr arddangosfa hon yw rhoi cyfle i chi ddysgu mwy am ein cynlluniau ni fel y gallwch ymateb a’n helpu i lunio ein cais ar gyfer Fferm Wynt Gorllewin Coedwig Brechfa.

Bydd yr arddangosfa’n esbonio’r cynllun, gyda lluniau i roi syniad i chi sut fyddai’r fferm wynt yn edrych, ynghyd a gwybodaeth gyffredinol am ynni adnewyddadwy a pholisïau’r Llywodraeth ym maes datblygu ffermydd gwynt yng Nghymru.

Hefyd, hoffwn ni rhoi cyfle i chi siarad â ni a gofyn cwestiynau. Mae croeso i chi ddod at un ohonon ni wrth i chi fynd o gwmpas yr arddangosfa.

Byddai’n dda cael eich adborth. Gallwch lenwi ffurflen ymateb i ddweud eich barn ac i gynnig awgrymiadau am y prosiect a’r arddangosfa. Bydd unrhyw sylwadau a gawn yn ystod yr ymgynghoriad yn cael eu cyflwyno i’r Comisiwn Cynllunio Seilwaith (IPC) yn adroddiad yr ymgynghoriad, yn cynnwys enwau a chyfeiriadau.

Gan y bydd y fferm wynt yn gallu cynhyrchu dros 50 megawat (MW), yr IPC fydd yn penderfynu ar y cais cynllunio o dan Ddeddf Cynllunio 2008 (y Ddeddf).

O dan y Ddeddf, mae’n ofynnol i ymgeiswyr gynnal ymgynghoriad ar y cynllun datblygu cyn gwneud y cais cynllunio. Ymhlith y grwpiau y mae’n rhaid ymgynghori â nhw mae’r awdurdodau lleol, rhestr benodol o gyrff cyhoeddus a chyrff rheoleiddio, a pherchenogion a phobl sydd â buddiant yn y tir y mae’r prosiect yn effeithio arno.

Yn ogystal, mae’n rhaid i RWE npower renewables, sef yr ymgeisydd, ymgynghori â’r gymuned leol o dan Adran 47 o’r Ddeddf. Ym mis Tachwedd 2010, cyhoeddodd RWE npower renewables Ddatganiad ynghylch Ymgynghori â’r Gymuned (SoCC) yn amlinellu’r ffordd y byddwn yn ymgynghori â’r bobl leol ar ein cynlluniau i ddatblygu Fferm Wynt Gorllewin Coedwig Brechfa.

Caiff y sylwadau a wneir yn ystod y broses ymgynghori eu cofnodi a’u hystyried yn ofalus gan dîm y prosiect. Caiff adroddiad ei lunio ar yr ymgynghoriad, yn nodi’r sylwadau a’r adborth a gafwyd ac yn disgrifio sut y deliwyd â’r materion a godwyd. Bydd raid i’r IPC dalu sylw i adroddiad yr ymgynghoriad wrth ystyried y cais. Tyrbinau Fferm Wynt Trysglwyn RWE npower renewables yn Ne Cymru (Ni fwriedir i’r lluniau o ffermydd gwynt gweithredol gynrychioli ymddangosiad, maint na graddfa Fferm Wynt arfaethedig Coedwig Brechfa). Diolch am gymryd yr amser i ddod i’r arddangosfa. Brechfa Forest West Wind Farm Consultation Report 286

APPENDIX L (CONT…)

Gair am RWE npower renewables Un o brif gwmnïau ynni adnewyddadwy Cymru a’r Deyrnas Unedig.

Rydym yn ymroi i ddatblygu, adeiladu a gweithredu cynlluniau ynni adnewyddadwy o safon uchel ar raddfa fasnachol ledled y Deyrnas Unedig.

Mae gennym enw da am gydweithio’n agos â’r cymunedau lle mae ein prosiectau. Pan fyddwn yn gweithio ar brosiect fferm wynt newydd, byddwn yn magu perthynas â’r gymuned leol o’r dechrau ac yn cadw cysylltiad ar ôl i’r fferm wynt ddechrau gweithio.

Mae Datganiad Polisi Ynni Llywodraeth Cynulliad Cymru yn dweud bod rhaid diwallu anghenion cymdeithas fodern am ynni o ffynonellau adnewyddadwy, carbon isel. Oherwydd ein harbenigedd a’n hymrwymiad i fuddsoddi yng Nghymru, rydym ar flaen y gad yn helpu i wireddu’r uchelgais hwn.

Rydym yn buddsoddi mewn technolegau adnewyddadwy newydd yn cynnwys biomas, tonnau, y llanw, a chynlluniau adnewyddadwy bach.

Rydym hefyd yn cefnogi datblygiad y gadwyn gyflenwi Gymreig – ym mis Ionawr eleni, fe drefnom gyfarfod datblygu’r gadwyn gyflenwi ar gyfer dros 160 o bobl fusnes o Gymru gyda Llywodraeth Cynulliad Cymru. Ym mis Medi 2010, dyfarnwyd contract gwerth £15 miliwn gennym i gwmni ceblo o Wrecsam.

Yng Nghymru, rydym yn rhedeg saith fferm wynt ar y tir a dwy ar y môr, ac mae gennym chwe gwaith pŵer trydan dŵr. Ledled y Deyrnas Unedig, mae gennym 43 o brosiectau ynni adnewyddadwy.

Mae’r prosiectau hyn i gyd yn cyfrannu at ddiwallu galw’r DU am ynni ac yn cyflwyno ynni glân, adnewyddadwy yn lle dulliau o gynhyrchu trydan sy’n allyrru carbon. Rydyn ni’n cynhyrchu cyfran sylweddol o ynni adnewyddadwy Cymru ar hyn o bryd.

Mae RWE npower renewables yn gweithredu portffolio o ynni dŵr a ffermydd gwynt ar y tir ac ar y môr ar draws Cymru. Brechfa Forest West Wind Farm Consultation Report 287

APPENDIX L (CONT…)

Nodyn Cyngor Technegol (TAN) 8 Meysydd polisi

Mae Llywodraeth Cynulliad Cymru wedi cyhoeddi nifer o Nodiadau Cyngor Technegol (TANs) ar wahanol feysydd polisi ac mae TAN 8, a fabwysiadwyd yn 2005, yn ymwneud ag Ynni Adnewyddadwy.

Yn TAN 8, mae Llywodraeth y Cynulliad yn cydnabod y bydd gan ynni’r gwynt ran amlwg i’w chwarae yn y frwydr yn erbyn newid yn yr hinsawdd. Daw i’r casgliad y dylid datblygu ffermydd gwynt mawr mewn rhannau penodol o Gymru, yn yr hyn y mae’n eu galw yn Ardaloedd Chwilio Strategol (SSAs).

Mae holl dyrbinau gwynt Fferm Wynt arfaethedig Gorllewin Coedwig Brechfa tu mewn i ffiniau SSA G, sydd â tharged cynhyrchu o 90MW. Byddai Fferm Wynt Gorllewin Coedwig Brechfa’n gwneud cyfraniad sylweddol at darged Cymru o gynhyrchu saith awr terawat (TWh) o drydan o ffynonellau adnewyddadwy erbyn 2020, ac at ddyhead y genedl o gynhyrchu cymaint o drydan o ffynonellau adnewyddadwy ag y mae’n ei ddefnyddio bob blwyddyn.

Yn TAN 8, mae Llywodraeth y Cynulliad yn nodi’r meini prawf ar gyfer dewis yr Ardaloedd Chwilio Strategol, yn cynnwys:

o ardaloedd â digon o wynt

o ardaloedd o dir uchel sy’n cynnwys llwyfandir

o ardaloedd prin eu poblogaeth ar y cyfan

o tir sy’n cynnwys, yn bennaf, blanhigfeydd conwydd a/neu rostir wedi’i wella/dirywio

o dim dynodiadau gwarchod natur na thirwedd hanesyddol, yn gyffredinol

o digon o le i gynnwys datblygiadau dros 25MW, er mwyn gallu cynhyrchu o leiaf 70MW a chyrraedd y targed cynhyrchu

o yn gyffredinol, ardaloedd sydd heb eu heffeithio gan signalau darlledu, radar, Ardal Hyfforddiant Tactegol y Weinyddiaeth Amddiffyn yn y Canolbarth, na chyfyngiadau eraill. Brechfa Forest West Wind Farm Consultation Report 288

APPENDIX L (CONT…)

Fferm Wynt Gorllewin Coedwig Brechfa Y manylion

Bydd Fferm Wynt Gorllewin Coedwig Brechfa yn cynnwys codi 28 o dyrbinau gwynt, creu lonydd mynediad newydd ac uwchraddio rhai o’r lonydd mynediad presennol. Bydd yr ardal ddatblygu gyfan yn cynnwys 750 hectar o Goedwig Brechfa sy’n mesur 5,700 hectar ond bydd ôl troed y tyrbinau a’r eitemau seilwaith eraill gryn dipyn yn llai.

Gallai’r fferm wynt arfaethedig gynhyrchu rhwng 56 ac 84 megawat (MW). Byddai disgwyl i’r safle gynhyrchu digon o drydan mewn blwyddyn ar gyfartaledd i gyflenwi anghenion domestig hyd at 39,700 o gartrefi cyffredin.(1)

Dyma brif elfennau’r cynllun:

• Gosod 28 tyrbin gwynt (pob un yn mesur dim mwy na 145 metr (475.72 troedfedd) o uchder i diwedd y llafn);

• Creu tua 9.1km o lonydd mynediad newydd ar y safle ac uwchraddio 12.7km o’r lonydd mynediad sydd yno eisoes;

• Gosod is-orsaf ar y safle, darnau o lawr caled, newidyddion allanol, ceblau tanddaearol ac un mast parhaol i fonitro’r gwynt;

• Creu dwy iard adeiladu dros dro;

• Cloddio un pwll benthyg newydd i dynnu cerrig.

Os ceir caniatâd cynllunio gan y Comisiwn Cynllunio Seilwaith, mae’n debygol y gwneir y gwaith adeiladu dros gyfnod o 22 mis, sef pedwar mis o waith clirio’r tir a pharatoi a 18 mis yn adeiladu’r fferm wynt. Cyn hyn, byddai angen cyfnod o gwympo coed.

Amcangyfrifir y gallai hyd at 150 o bobl fod yn gweithio’n uniongyrchol ar y safle yn ystod y cyfnod adeiladu o 22 mis. (Ffynhonnell: Datganiad Amgylcheddol Gorllewin Coedwig Brechfa, Chwefror 2011)

Mae’r fferm wynt wedi’i dylunio ar gyfer oes weithredol o 25 mlynedd. Ar ddiwedd y cyfnod hwn, caiff y tyrbinau eu tynnu i lawr a’u symud o’r safle os na wneir cais am ganiatâd cynllunio pellach. Amcangyfrifir y Tyrbinau Fferm Wynt Ffynnon Oer RWE npower renewables yn Ne Cymru (Ni fwriedir i’r lluniau o ffermydd gwynt bydd gwaith dadgomisiynu’r fferm wynt yn cymryd tua 12 mis. gweithredol gynrychioli ymddangosiad, maint na graddfa Fferm Wynt arfaethedig Coedwig Brechfa). (1) Wrth gyfrif y ffigwr hwn, cymerir bod pob cartref yn defnyddio 4700kWh o drydan y flwyddyn. Mae’r ffigwr yn cyfateb i’r data diweddar am swm y trydan a ddefnyddir mewn cartrefi yn y Digest of UK Energy Statistics ac amcangyfrifon ac amcanestyniadau gan Awdurdod Ystadegau’r DU. Brechfa Forest West Wind Farm Consultation Report 289

APPENDIX L (CONT…)

Comisiwn Coedwigaeth Cymru

Mae Comisiwn Coedwigaeth Cymru’n gweithredu ar ran Llywodraeth Cynulliad Cymru i sicrhau bod datblygu ffermydd gwynt ar yr ystâd goed yn gyfreithlon, yn ddiogel ac yn ymarferol.

Bu Comisiwn Coedwigaeth Cymru’n gweithio gydag adnoddau adnewyddadwy ers ei sefydlu dros 90 mlynedd yn ôl. Yn awr, wrth i Gymru a gweddill y byd wynebu her newid yn yr hinsawdd, mae Llywodraeth Cynulliad Cymru wedi ymddiried yng Nghomisiwn Coedwigaeth Cymru i ystyried mathau newydd o adnoddau adnewyddadwy a fydd yn ychwanegu at y cyflenwadau ynni sydd gennym eisoes.

Gofynnodd Gweinidogion Llywodraeth Cynulliad Cymru i Gomisiwn Coedwigaeth Cymru ddewis cwmnïau addas i gael cynnig opsiynau i ddatblygu ffermydd gwynt ar dir a reolir ar ran Llywodraeth y Cynulliad. Gwnaed hyn er mwyn galluogi’r Llywodraeth i gyrraedd ei thargedau ar gyfer Ynni Adnewyddadwy mewn Ardaloedd Chwilio Strategol (SSAs) a ddewiswyd o dan Nodyn Cyngor Technegol 8 (TAN 8).

Sefydlwyd y Rhaglen Ynni Gwynt (Rhaglen Ffermydd Gwynt yr Ystâd Goedwig Genedlaethol) ym mis Rhagfyr 2005 i gyflawni hyn.

Y Rhaglen:

• Hwyluso ymgysylltu a chyfathrebu clir a chyson gyda rhanddeiliaid mewnol ac allanol i’w galluogi i ddeall rôl y Comisiwn o ran datblygu ffermydd gwynt.

• Gofalu bod y Comisiwn yn cyflawni ei gyfrifoldebau statudol fel rheolwr tir cyhoeddus pan ddatblygir ffermydd gwynt.

• Ac er nad oes gan y Dîm ddylanwad ar ganlyniad y broses gynllunio na chyfrifoldeb amdano, mae’r Tîm yn cydweithio â datblygwyr er mwyn sicrhau bod ceisiadau cynllunio’n dderbyniol gan Gomisiwn Coedwigaeth Cymru ac yn unol â chyfrifoldebau’r Comisiwn ac agweddau perthnasol eraill ar bolisi cyhoeddus.

Yn 2008, llofnodwyd Cytundebau Opsiynau gyda nifer o ddatblygwyr yn cynnwys RWE npower renewables (RWE NRL). Yng Nghoedwig Brechfa, mae’r cytundeb yn rhoi’r hawl i RWE NRL wneud cais am ganiatâd cynllunio i ddatblygu ffermydd gwynt yn SSA G ac opsiwn i ymrwymo i brydles 25 mlynedd os rhoddir caniatâd a caiff y fferm wynt ei adeiladu.

Roedd rhan allweddol o’r tendr a weinyddwyd gan y Rhaglen Ynni Gwynt yn pwysleisio y bwriedir i ffermydd gwynt ar dir a reolir gan Gomisiwn Coedwigaeth Cymru fod yn rhan integredig o’r goedwig. Hynny yw, tyrbinau gwynt mewn coetiroedd yn hytrach na ffermydd gwynt yn cymryd lle coetiroedd.

Mae’r safleoedd ar gyfer ffermydd gwynt sy’n cael eu hystyried yng Nghoedwig Brechfa yn llawer llai na’r goedwig. Mae hyn yn golygu y caiff y datblygiadau eu crynhoi mewn blociau bychan, gan leihau’r effaith ar y goedwig.

Bydd y Comisiwn Coedwigaeth yn cydweithio’n agos gyda RWE NRL i geisio sicrhau na cheir newidiadau yn y defnydd o’r tir a’r hyn a nodir yng Nghynlluniau Dyluniad Coedwigoedd (FDPs) hirdymor Coedwig Brechfa. Gellir gwneud hyn, er enghraifft, trwy roi tyrbinau mewn llecynnau agored addas; mewn ardaloedd lle llwyrgwympwyd y coed yn ddiweddar neu trwy roi tyrbinau mewn mannau yn y goedwig lle gellir cwympo cyn lleied o goed ag y bo modd.

NI fydd coed yng Nghoedwig Brechfa’n cael eu llwyrgwympo i wneud lle ar gyfer ffermydd gwynt. Brechfa Forest West Wind Farm Consultation Report 290

APPENDIX L (CONT…)

Proses yr IPC Y Comisiwn Cynllunio Seilwaith (IPC)

Mae RWE npower renewables yn dymuno codi fferm wynt sy’n cynnwys 28 o dyrbinau o’r enw Fferm Wynt Gorllewin Coedwig Brechfa yng Nghoedwig Brechfa, Sir Gaerfyrddin. Bydd hyn yn cynnwys codi 28 tyrbin gwynt, creu tua 9.1km o lonydd mynediad newydd ac uwchraddio tua 12.7km o’r lonydd mynediad presennol. Bydd elfennau eraill y fferm wynt yn cynnwys is-orsaf ar y safle, darnau o lawr caled, newidyddion allanol, ceblau tanddaearol ac un mast parhaol i fonitro’r gwynt.

Gan fydd y fferm wynt yn gallu cynhyrchu dros 50 megawat (MW), y Comisiwn Cynllunio Seilwaith (IPC) fydd yn penderfynu ar y cais cynllunio o dan ddarpariaethau Deddf Cynllunio 2008 (y Ddeddf).

O dan y Ddeddf, mae’n ofynnol i ymgeiswyr gynnal ymgynghoriad ar y cynllun datblygu cyn gwneud y cais cynllunio. Ymhlith y grwpiau y mae’n rhaid ymgynghori â nhw mae’r awdurdodau lleol, rhestr benodol o gyrff cyhoeddus a chyrff rheoleiddio, a pherchenogion a phobl sydd â buddiant yn y tir y mae’r prosiect yn effeithio arno.

Yn ogystal, mae’n rhaid i RWE npower renewables, sef yr ymgeisydd, ymgynghori â’r gymuned leol o dan Adran 47 o’r Ddeddf. Ym mis Tachwedd 2010, cyhoeddodd RWE npower renewables Ddatganiad ynghylch Ymgynghori â’r Gymuned (SoCC) yn amlinellu’r ffordd y byddwn yn ymgynghori â’r bobl leol ar ein cynlluniau i ddatblygu Fferm Wynt Gorllewin Coedwig Brechfa.

Caiff y sylwadau a wneir yn ystod y broses ymgynghori eu cofnodi a’u hystyried yn ofalus gan dîm y prosiect. Caiff adroddiad ei lunio ar yr ymgynghoriad, yn nodi’r sylwadau a’r ymateb a gafwyd ac yn disgrifio sut y deliwyd â’r materion a godwyd. Bydd raid i’r IPC dalu sylw i adroddiad yr ymgynghoriad wrth ystyried y cais.

Y Broses

Mae’r holl geisiadau a wneir i’r Comisiwn Cynllunio Seilwaith yn dilyn llwybr penodol a nodir isod:

1. Y cyfnod cyn gwneud y cais – mae’r IPC yn cael gwybod am y bwriad ac yn ei ychwanegu at ei Raglen o Brosiectau. Mae’r datblygwr yn paratoi’r cais ac yn ymgynghori arno. Mae cynlluniau RWE npower renewables ar gyfer Fferm Wynt Gorllewin Coedwig Brechfa yn y cyfnod cyn gwneud cais ar hyn o bryd.

2. Y cyfnod derbyn – ar ôl i RWE npower renewables gyflwyno’i gais am Fferm Wynt Gorllewin Coedwig Brechfa i’r IPC, bydd gan y Comisiwn 28 diwrnod i benderfynu a yw am dderbyn y cais i gael ei ystyried neu beidio. Yn ystod y cyfnod hwn, bydd yr IPC yn asesu a yw’r datblygwr wedi ymgynghori’n ddigonol, ymhlith ystyriaethau eraill.

3. Y cyfnod cyn archwilio – pan fydd yr IPC wedi derbyn y cais i gael ei ystyried, bydd y cyhoedd yn cael cynnig eu barn am y cynlluniau. Bydd angen i bawb sy’n dymuno dweud eu dweud nodi eu diddordeb ar wefan yr IPC (www.infrastructure.independent.gov.uk) neu ofyn am gael copi o’r ffurflenni cofrestr trwy’r post trwy ffonio Llinell Gymorth yr IPC (0303 444 5000) neu trwy e-bostio [email protected]. Bydd y rhai sydd wedi cofrestru i gyflwyno’u barn yn cael eu gwahodd i gyfarfod i drafod y cais, o dan gadeiryddiaeth un o Gomisiynwyr yr IPC.

4. Y cyfnod archwilio – mae’r cyfnod hwn yn para am chwe mis a bydd y rhai sydd wedi cofrestru i roi eu barn yn cael cyfle i gyflwyno rhagor o sylwadau ysgrifenedig. Mae’n bosib y cynhelir rhagor o gyfarfodydd gyda’r cyhoedd hefyd.

5. Y cyfnod penderfynu – gall yr IPC gymryd tri mis i benderfynu. Ar ôl i benderfyniad ar y cais gael ei gyhoeddi, os bydd her gyfreithiol, mae’n rhaid ei gwneud cyn pen chwe wythnos. Caiff yr holl benderfyniadau a wneir gan yr IPC eu cyhoeddi ar ei wefan, http://infrastructure.independent.gov.uk/. Ceir rhagor o wybodaeth am yr IPC a’i waith ar y wefan hefyd. Brechfa Forest West Wind Farm Consultation Report 291

APPENDIX L (CONT…)

Ein ymgynghoriad Rhoi’ch barn

Yn ystod y cyfnod ymgynghori, byddwn yn ymgynghori â phobl leol, defnyddwyr y goedwig ac ymgyngoreion statudol Mannau lle bydd y dogfennau ar gael: am Fferm Wynt Gorllewin Coedwig Brechfa. O dan y Rheoliadau Cynllunio Seilwaith (Asesu Effeithiau Amgylcheddol) 2009, mae’n ofynnol i ni ymgynghori ar ‘wybodaeth amgylcheddol ragarweiniol’. At ddibenion yr ymgynghoriad hwn, Swyddfa Gynllunio Caerfyrddin (9yb – 5yh) Gwasanaethau Cynllunio mae’r ‘wybodaeth amgylcheddol ragarweiniol’ yn golygu Datganiad Amgylcheddol drafft llawn ar gyfer y safle, yn nodi’r Cyngor Sir Caerfyrddin holl waith amgylcheddol a wnaed yng Ngorllewin Coedwig Brechfa hyd yma. 40 Heol Spilman Caerfyrddin, SA31 1LQ

Bydd nifer o ddogfennau ar gael i’w hystyried yn ystod y cyfnod ymgynghori: Llyfrgell Caerfyrddin (Llun – Mercher a Gwener: 9.30yb - 7yh, Iau a Sadwrn: 9.30yb – 5yh) • Datganiad Amgylcheddol drafft llawn yn nodi canlyniadau’r gwaith o asesu effeithiau tebygol datblygu’r fferm wynt Heol San Pedr ar yr amgylchedd, yn cynnwys camau lliniaru i leihau unrhyw effeithiau amgylcheddol disgwyliedig; Caerfyrddin • Crynodeb annhechnegol o’r Datganiad Amgylcheddol drafft – ar gael yng Nghymraeg a Saesneg; SA31 1LN • Datganiad Cynllunio drafft yn nodi cyd-destun cynllunio’r fferm wynt arfaethedig. Swyddfa Gynllunio Caerfyrddin (9yb – 5yb) Gwasanaethau Cynllunio Rydym wrthi’n gofyn am barn pobl am y cynllun, yn cynnwys ffyrdd y gellir ei newid neu ei wella. Efallai y bydd pobl yn Swyddfeydd y Cyngor Llandeilo dymuno awgrymu sut y gall fanteision y cynllun cael eu ehangu neu sut i leihau unrhyw effeithiau niweidiol. SA19 6HW

Mae’n bwysig deall yn iawn beth yr ydym yn ymgynghori arno a beth nad ydym yn ymgynghori arno. Mae’r tabl isod yn Llyfrgell Llandeilo (Mawrth a Gwener 10yb – 12, 1.30yh – 4.30yh, 5yh – 7yh; Mercher 1.30yh – rhoi enghreifftiau o’r pynciau: 5.30yh; Sadwrn 10ybm – 12) Heol Cilgant Llandeilo Yn ymgynghori ar Ddim yn ymgynghori ar SA19 6HN

Gosodiad y tyrbinau Yr angen am ynni adnewyddadwy Siop Gymunedol Brechfa (Llun a Iau 9yb – 1yh, Mawrth a Sadwrn 9yb – 12) Lleoliad seilwaith arall Addasrwydd Coedwig Brechfa fel safle ar gyfer fferm wynt Brechfa Caerfyrddin Arolygon a gynhaliwyd Y cysylltiad â’r grid (Bydd angen gwneud cais arall ar gyfer Sir Gaerfyrddin hyn) SA32 7QY Camau lliniaru posibl Swyddfa Bost a Siop yr Albion Pencader (Oriau agor: Dydd Llun – Sadwrn 6.30yb – 8yh, Dydd Sul 7yb – 7yh) Sut yr ydym yn ymgynghori Byddwn yn ymgynghori’n lleol fel y disgrifir yn ein SoCC sydd i’w weld ar ein gwefan - Siop yr Albion www.npower-renewables.com/brechfaforest Pencader Sir Gaerfyrddin SA39 9ES Trwy gydol y cyfnod ymgynghori, bydd y defnyddiau ymgynghori i gyd ar gael mewn nifer o ganolfannau lleol. Yn ogystal, bydd arddangosfeydd mewn canolfannau ger Coedwig Brechfa. Bydd y rhain yn gyfle i bobl leol gael gwybod Canolfan Gymuned yr Hen Ysgol (dim ond rhwng 9yb a 4yh) Heol Llansawel mwy am y cynlluniau i ddatblygu fferm wynt newydd yng Ngorllewin Coedwig Brechfa ac i roi eu barn yn ffurfiol. Llanybydder SA40 9RN Bydd defnyddiau ymgynghori ar gael ar ein gwefan hefyd - www.npower-renewables.com/brechfaforest ac mae copïau o’r crynodeb annhechnegol ar gael am ddim os gofynnwch amdanynt. Os hoffech brynu copi o’r Datganiad Amgylched- Gwyddgrug Swyddfa’r Post (Oriau agor: Dydd Llun – Sadwrn 7.30yb – 8yh, Dydd Sul 9.30yb – 8yh) dol, mae copïau ar DVD ar gael am £10. Gwyddgrug Sir Gaerfyrddin SA39 9AX Brechfa Forest West Wind Farm Consultation Report 292

APPENDIX L (CONT…)

Y Datganiad Amgylcheddol (DA)

Mae gwarchod yr amgylchedd yn bwysig iawn i ni ac rydym yn gwneud ein gorau i leihau effaith amgylcheddol ein gweithgareddau – yn enwedig wrth ddatblygu fferm wynt newydd.

Mae’n rhaid i unrhyw gwmni sy’n gwneud cais cynllunio i adeiladu fferm wynt fawr ymchwilio’n drwyadl effeithiau’r cynllun ar yr amgylchedd. Mae’n rhaid cyflwyno Datganiad Amgylcheddol (DA) yn rhoi manylion yr ymchwiliadau hyn a’u casgliadau gyda’r cais am ganiatâd. Mae hyn yn rhan hanfodol o’r broses gynllunio.

Byddai adeiladu fferm wynt newydd yn brosiect mawr a byddai pob ymdrech yn cael ei gwneud i sicrhau bod y gwaith adeiladu a’r gwaith o redeg y fferm yn achosi cyn lleied o drafferth â phosib.

Rydym yn gwneud ein gorau i adeiladu a rhedeg ein holl brosiectau mewn ffordd eco-gyfeillgar a byddem yn dal i gydweithio’n agos â’r awdurdodau perthnasol er mwyn cyrraedd y nod hwn.

Mae RWE npower renewables wedi drafftio Datganiad Amgylcheddol (ES) ar gyfer Fferm Wynt Gorllewin Coedwig Brechfa, sy’n asesu effeithiau posibl y cynllun, yn esbonio pa gamau lliniaru a gâi eu cymryd ac yn nodi unrhyw effeithiau gweddillol.

Nodwyd yr effeithiau posibl hyn yn dilyn Asesiad o’r Effaith Amgylcheddol (AEA) a gynhaliwyd gan ymgynghorwyr arbenigol ar ran RWE npower renewables. Fe gytunodd RWE npower renewables gyda Chyngor Sir Caerfyrddin a nifer o bobl a sefydliadau perthnasol eraill pa astudiaethau y dylid eu cynnwys yn yr AEA.

Seiliwyd y DA ar ganlyniadau astudiaethau o’r effeithiau amgylcheddol posibl ac mae’n cynnwys disgrifiad o’r ffordd y cynhaliwyd yr astudiaethau ac unrhyw dybiaethau a wnaed yn ystod y broses asesu. Mae’n nodi canlyniadau’r astudiaethau, yn cynnwys camau lliniaru i leihau unrhyw effeithiau amgylcheddol a ddisgwylir.

Dyma rhai o’r meysydd a aseswyd: • Yr Amgylchedd Hanesyddol • Daeareg a Hydroleg • Mynd a Dod, Traffig a Chludiant • Materion yn ymwneud â Seilwaith, Telathrebu, Teledu a Diogelu’r Awyr • Mynediad i’r Cyhoedd, Hamdden a Materion Economaidd-Gymdeithasol • Defnydd Tir a Choedwigaeth • Ecoleg Rhywogaethau heblaw Adar • Adar • Y Dirwedd ac Amwynderau Gweledol • Sŵn a Dirgrynu • Cryndod Cysgodion. Brechfa Forest West Wind Farm Consultation Report 293

APPENDIX L (CONT…)

Sut y rheolir yr effeithiau

Ecoleg Y Dirwedd Cynhaliwyd arolygon ecolegol manwl i sicrhau bod Fferm Wynt Gorllewin Coedwig Brechfa wedi’i Yn ogystal, mae RWE npower renewables wedi comisiynu Asesiad o’r Effaith ar y Dirwedd a’r dylunio mewn ffordd sensitif, gyda dealltwriaeth lawn o ecoleg y safle a’r ardal o’i gwmpas, er Effaith Weledol er mwyn ystyried effaith bosibl Fferm Wynt Gorllewin Coedwig Brechfa ar y mwyn amharu cyn lleied â phosib ar fywyd gwyllt. dirwedd a’r bobl sy’n gweld y dirwedd honno. Mae’r Asesiad yn rhan o’r Datganiad Amgylcheddol. Cynhaliwyd yr arolygon a canlynol: • Arolygon o gynefinoedd a llystyfiant; Mae’r asesiad wedi’i seilio ar ganllawiau arferion da cyfredol a baratowyd gan y Sefydliad • Arolygon o adar sy’n bridio yno; Tirwedd a’r Sefydliad Rheoli ac Asesu Amgylchedd (2002). Paratowyd montages ffotograffig yn • Arolygon o adar sy’n gaeafu yno; unol â Visual Representation of Windfarms Good Practice Guidance gan Scottish Natural Heritage • Arolygon adar i asesu tebygolrwydd gwrthdrawiadau; (2006). • Arolygon o’r troellwr mawr; • Arolygon adar ysglyfaethus; Roedd yr asesiad yn cynnwys astudiaeth ddesg, arolwg maes a modelu cyfrifiadurol. Cafodd y • Arolygon ystlumod; fethodoleg a’r dewis o safbwyntiau cynrychioliadol ar gyfer yr asesiad eu mabwysiadu mewn • Arolygon o famaliaid eraill (yn cynnwys y mochyn daear, y wiwer goch, y bele a’r pathew); ymateb i sylwadau a gafwyd gan Awdurdodau Cynllunio Lleol cyfagos, Cyngor Cefn Gwlad Cymru • Arolygon o’r Fadfall Ddŵr Gribog. a’r Ymddiriedolaeth Genedlaethol. Cafodd montages ffotograffig a lluniau cyfrifiadurol eu cynhyrchu ar gyfer 31 o olygfannau o gwmpas y safle i ddangos natur debygol yr effeithiau.

Camau Lliniaru Rydym wedi paratoi’r gyfres hon o montages ffotograffig i ddangos sut y gallai Fferm Wynt Dyma rhai o’r camau lliniaru y bwriedir eu cymryd (ceir rhagor o wybodaeth yn y DA): Gorllewin Coedwig Brechfa edrych o nifer o olygfannau cyfagos. • Darparu briff gwylio archaeolegol yn ystod y gwaith adeiladu er mwyn lleihau’r effeithiau bosibln ar olion archaeolegol • Dilyn arferion da i atal llygredd yn ystod y gwaith adeiladu er mwyn lleihau’r perygl y caiff dŵr ei lygru • Cael Cynllun Rheoli Traffig yn ystod y gwaith adeiladu i leihau’r effaith ar y drafnidiaeth • Gosod goleuadau is-goch ar y tyrbinau rhag i’r datblygiad darfu ar awyrennau milwrol • Cynnal arolwg o bryoffytau a symud poblogaethau sydd mewn perygl os oes angen rhag i ni golli rhywogaethau prin o bryoffytau • Cadw golwg am nythod Gwalch Marth yn ystod y flwyddyn o waith adeiladu a pheidio ag adeiladu o fewn 500m o unrhyw safle nythu yn ystod y tymor bridio rhag i’r gwaith darfu ar y bridio.

Mae asesiad o’r holl effeithiau hyn i’w weld yn y Datganiad Amgylcheddol ac mewn Crynodeb Annhechnegol o’r DA. Holwch aelod o dîm RWE npower renewables os hoffech weld copi heddiw. Gallwn roi cyfeiriad gwefan i chi hefyd lle gallwch weld y dogfennau. Brechfa Forest West Wind Farm Consultation Report 294

APPENDIX L (CONT…)

Manteision Cymunedol Fferm Wynt Gorllewin Coedwig Brechfa

Os cawn ganiatâd cynllunio ar gyfer Fferm Wynt Gorllewin Coedwig Brechfa, mae RWE npower Astudiaeth Achos – Fferm Wynt Bears Down – cefnogi addysg amgylcheddol renewables yn bwriadu cynnig pecyn o fanteision cymunedol gyda’r nod o ddiwallu anghenion penodol y gymuned leol. Yn dibynnu faint o drydan y gall y safle’i gynhyrchu, Defnyddiodd Ysgol Poltair yng Nghernyw eu cyfraniad blynyddol o Gronfa Gymunedol Fferm disgwyliwn i’r pecyn manteision cymunedol fod yn werth tua £350,000 bob blwyddyn y bydd Wynt Bears Down i helpu i ariannu prosiect amgylcheddol i godi ymwybyddiaeth y disgyblion y safle’n gweithio. o’r byd o’u cwmpas ac i helpu i ostwng allyriadau CO2 yr ysgol – The Green Team.

Disgwyliwn i’r pecyn gynnwys: Mae’r Green Team wedi cynnwys plant lleol mewn gweithgareddau fel plannu coed, tyfu ffrwythau a llysiau, creu pwll newydd, harneisio ynni solar, ailgylchu a chompostio, casglu dŵr • Taliad unigol ar gyfer gweithgareddau addysg amgylcheddol ac arbed ynni mewn glaw a chreu coridorau bywyd gwyllt ar dir yr ysgol. ysgolion lleol; • Arian i dalu am weinyddu’r pecyn; “Mae’r Green Team yn helpu ein myfyrwyr i roi eu syniadau ar waith – maen nhw’n meddwl am • Y prif becyn ei hunan, a ddiffinnir ar ôl ymgynghori’n lleol. ffyrdd o leihau Ôl Troed Carbon yr ysgol a’i gwneud yn fwy cynaliadwy,” meddai Mr Martin, sy’n athro gwyddoniaeth yno. “Mae’r myfyrwyr yn gwneud gwaith gwych. Maen nhw wedi cyflwyno nifer o brosiectau sy’n gwneud gwahaniaeth yn barod.” Byddai’r pecyn manteision cymunedol yn dilyn y canllawiau a bennwyd yn Nodyn Cyngor Technegol 8 Llywodraeth Cynulliad Cymru: Astudiaeth achos – Fferm Wynt Carno – achub bywydau

• Dylid trafod y pecyn manteision gyda’r bobl neu’r cyrff priodol a chynrychioliadol; Mae gwirfoddolwyr Ymatebwyr Cyntaf Carno yn cynnig triniaeth achub bywyd hanfodol yn • Dylid sianelu’r manteision trwy gorff neu ymddiriedolaeth a reoleiddir ac iddo ystod munudau cyntaf argyfwng cyn i’r gwasanaethau brys gyrraedd. gyfansoddiad priodol (gallai hyn gynnwys yr awdurdod lleol); • Dylid defnyddio’r manteision at wahanol ddibenion priodol y cytunir arnynt ac sy’n dod o Bu grant o £2,000 gan Gronfa Gymunedol Fferm Wynt Carno yn help i’r grŵp brynu set fewn y diffiniad o ddatblygu cynaliadwy; deffibriliwr ac ocsigen i achub bywydau, dillad diogelwch i wirfoddolwyr ac offer hyfforddi. • Dylid buddsoddi o leiaf ran o unrhyw becyn ariannol blynyddol mewn camau i’w cymryd yn y gymuned leol. Meddai’r Ymatebwyr Cyntaf, “Mae’r grant gan Gronfa Gymunedol Fferm Wynt Carno wedi bod o gymorth amhrisiadwy i ni brynu’r offer y mae arnon ni ei angen i wneud ein gwaith. Bydd gyda ni trwy’r amser a gallai ein helpu i achub bywydau yn y gymuned.” Brechfa Forest West Wind Farm Consultation Report 295

APPENDIX L (CONT…)

Fferm Wynt Dwyrain Coedwig Brechfa Cynlluniau ar gyfer Fferm Wynt Dwyrain Coedwig Brechfa

Mae RWE npower renewables yn cyflwyno cynigion ar gyfer dwy fferm wynt ar wahanol safleoedd yng Nghoedwig Brechfa – Gorllewin Coedwig Brechfa, yr un yr ydym yn ymgynghori arni yma heddiw, a Dwyrain Coedwig Brechfa.

Byddai Fferm Wynt Dwyrain Coedwig Brechfa ar Fanc Llywelau yn nyffryn Afon Pib. Byddai’n cynnwys 12 tyrbin a gallai gynhyrchu rhwng 24 a 36MW. Byddai disgwyl i’r safle gynhyrchu digon o drydan mewn blwyddyn ar gyfartaledd i gyflenwi anghenion hyd at 15,700 o gartrefi cyffredin. (1)

Cynhaliwyd arddangosfa o’r cynlluniau ym mis Mawrth 2010. Ym mis Rhagfyr 2010, cyflwynodd RWE npower renewables gais cynllunio i Gyngor Sir Caerfyrddin i gael ei ystyried o dan y Ddeddf Cynllunio Gwlad a Thref.

Mae Cyngor Sir Caerfyrddin wrthi’n cynnal ymgynghoriad statudol ar y cais hwn. Caiff aelodau’r cyhoedd gyflwyno’u sylwadau i’r Cyngor. Dylid cyflwyno unrhyw sylwadau mewn ysgrifen, gan nodi cyfeirnod y cais (E/24195), i’r Pennaeth Cynllunio, Gwasanaethau Cynllunio, Cyngor Sir Caerfyrddin, 40 Heol Spilman, Caerfyrddin, SA31 1LE.

Gall yr awdurdod lleol ofyn am ragor o wybodaeth os bydd angen a, phan fydd o’r farn fod ganddo ddigon o wybodaeth, bydd Cyngor Sir Caerfyrddin yn dod i benderfyniad am y cais. Gall benderfynu rhoi amodau ar y caniatâd os caniateir y cais.

(1)Wrth gyfrif y ffigwr hwn, cymerir bod pob cartref yn defnyddio 4700kWh o drydan y flwyddyn. Mae’r ffigwr yn cyfateb i’r data Tyrbinau Fferm Wynt Ffynnon Oer RWE npower renewables yn Ne Cymru (Ni fwriedir i’r lluniau o ffermydd diweddar am swm y trydan a ddefnyddir mewn cartrefi yn y Digest of UK Energy Statistics ac amcangyfrifon ac amcanestyniadau gan gwynt gweithredol gynrychioli ymddangosiad, maint na graddfa Fferm Wynt arfaethedig Coedwig Brechfa). Awdurdod Ystadegau’r DU. Brechfa Forest West Wind Farm Consultation Report 296

APPENDIX L (CONT…)

Dweud eich dweud Sut i ymateb i’r ymgynghoriad

Mae RWE npower renewables wedi lansio’i gyfnod ymgynghori ffurfiol ar gyfer gynllun Fferm Wynt Gorllewin Coedwig Brechfa. Cychwynnodd y cyfnod ymgynghori ar 10 Chwefror a bydd yn para am 56 diwrnod.

Mae RWE npower renewables yn gofyn i bobl ymateb mewn ysgrifen. Gellir cyflwyno sylwadau trwy lenwi ffurflen ymateb sy’n cynnwys nifer o gwestiynau. Mae’r ffurflen i’w chael ar ein gwefan, neu gallwch gymryd copi mewn arddangosfa neu gallwn ni anfon copi atoch os dymunwch. Neu, gallwch ysgrifennu atom neu anfon neges e-bost yn cyflwyno’ch ymateb i’r cynlluniau. Gofynnwn i chi roi eich manylion cysylltu ar eich ymateb, yn cynnwys enw a chyfeiriad lle gallwn anfon gohebiaeth am yr ymgynghoriad.

Bydd unrhyw sylwadau a gawn yn ystod yr ymgynghoriad yn cael eu cyflwyno i’r Comisiwn Cynllunio Seilwaith (IPC) yn adroddiad yr ymgynghoriad, gydag enwau a chyfeiriadau.

Caiff eich ymateb ei basio ymlaen at Gyngor Sir Caerfyrddin a’r Comisiwn Cynllunio Seilwaith (IPC). Mae’n bosibl y caiff eich sylwadau a’ch manylion cysylltu eu cyhoeddi mewn Adroddiad ar yr Ymgynghoriad a fydd yn nodi’r holl sylwadau a ddaeth i law a sut yr ymatebwyd iddynt. Caiff yr adroddiad hwn ei gyflwyno i’r IPC fel rhan o gais cynllunio Gorllewin Coedwig Brechfa.

Rhaid derbyn ymatebion i’r ymgynghoriad erbyn 5yh ar 6 Ebrill.

Cysylltwch â ni: Ymgynghoriad Gorllewin Coedwig Brechfa RWE npower renewables Uned 22: Technium Central Avenue Baglan Energy Park Port Talbot SA12 7AX

Ebost: [email protected] Tyrbinau Fferm Wynt Ffynnon Oer RWE npower renewables yn Ne Cymru (Ni fwriedir i’r lluniau o ffermydd Ffôn (am gwybodaeth yn unig): 01639 816180 gwynt gweithredol gynrychioli ymddangosiad, maint na graddfa Fferm Wynt arfaethedig Coedwig Brechfa). Brechfa Forest West Wind Farm Consultation Report 297

Appendix M

Your Feedback

RWE npower renewables is developing a proposal to construct and operate a wind farm at Brechfa Forest north west of Brechfa (the Brechfa Forest West Wind Farm). It is intended that the application for a Development Consent Order will be made to the Infrastructure Planning Commission (IPC) later in 2011.

This consultation exercise is taking place to inform people about RWE npower renewables’ plans for the Brechfa Forest West Wind Farm and to gather feedback. We invite you to use this form to record any comments or suggestions.

Please complete the form and leave it in the box as you leave one of our exhibitions.

Alternatively, you can email your feedback to [email protected] or post it to us at Brechfa Forest West consultation, RWE npower renewables Unit 22: Technium, Central Avenue, Baglan Energy Park, Port Talbot, SA12 7AX.

You can request copies of this form by calling us on 01639 816180 and you can also download from our website: www.npower-renewables.com/brechfaforest

Please ensure we receive your feedback by 5pm 6 April 2011

1. What is your nearest town or village?

2. Are you representing a group or organisation? If so, please provide details below.

3. How did you learn about this consultation exercise? (please circle all that apply):

Newsletter Press notice other media coverage Via your community council Via the Community Liaison Group Poster other – please state: Brechfa Forest West Wind Farm Consultation Report 298

Appendix M (cont…)

4. If you are completing this form at an exhibition. How did you travel here today? (please circle all that apply):

Car Bus Bicycle on foot on horseback other – please state:

The purpose of this consultation exercise is to present information on the project together with the preliminary environmental information- in the form of a draft Environmental Statement. This consultation exercise is an important stage in the process of making an application for the Brechfa Forest West Wind Farm. It enables us to capture your views at a time when you can still influence the final form of the proposals before we submit the final application to the IPC. You will also be able to make representations about the final application to the IPC.

5. When developing the final application for the Brechfa Forest West Wind Farm, which elements do you feel are most important for RWE npower renewables to consider? Please circle your three main priorities:

archaeology combating climate change creation of jobs ensuring security of energy supply impacts on the forest impact on water supply maximising the distance from homes minimising impacts on plant and animal habitats minimising visual impact recreation or public access impacts transportation and access

6. Please provide any further detail that you think should be considered:

a. archaeology

Brechfa Forest West Wind Farm Consultation Report 299

Appendix M (cont…)

6. Please provide any further detail that you think should be considered: (cont…)

b. combating climate change

c. creation of jobs

d. effects on the forest

e. effects on water supply

f. ensuring security of energy supply

g. maximising the distance from homes

h. minimising effects on plant and animal habitats

i. minimising visual effects

j. recreation or public access effects

k. transportation and access

Brechfa Forest West Wind Farm Consultation Report 300

Appendix M (cont…)

7. Is there anything else that you think should be considered?

8. If you think the project will have positive effects, how could these be enhanced or maximised?

9. If you have concerns about the project, how do you think these could be avoided or minimised?

10. Please provide us with any particular comments you have about the following elements of the project:

a. the turbine layout

b. siting of infrastructure

c. surveys that have been undertaken

d. proposed mitigation measures

Brechfa Forest West Wind Farm Consultation Report 301

Appendix M (cont…)

11. Please provide us with any further comments you wish to make about RWE npower renewables’ proposals for development:

We will keep you up-to-date with the consultation and how your feedback has been considered either via email or post. Please note that we will only provide full feedback after the consultation has finished so it may be a couple of months before you receive a response.

Please leave your preferred contact details below:

Name:

Address:

Email:

Please note that your feedback will be passed onto Carmarthenshire County Council and the Infrastructure Planning Commission (IPC). Your comments and contact details may be made public in a Consultation Report that will document all comments received and how they have been acted upon. This report will be submitted to the IPC as part of the Brechfa Forest West application for Development Consent. Brechfa Forest West Wind Farm Consultation Report 302

Appendix M (cont…)

Eich Adborth

Mae RWE npower renewables yn datblygu cais i adeiladu a gweithredu fferm wynt yn Coedwig Brechfa sydd wedi ei lleoli gogledd-orllewin o Brechfa (y Fferm Wynt Gorllewin Coedwig Brechfa). Y bwriad yw y bydd y cais am Ganiatâd Datblygu yn cael ei wneud i’r Comisiwn Cynllunio Seilwaith (CCS) yn hwyrach yn 2011.

Mae’r ymarfer ymgynghori yn cael ei gynnal i roi gwybod i bobl am gynlluniau RWE npower renewables ac i gasglu adborth am y Fferm Wynt Gorllewin Coedwig Brechfa. Rydym yn eich gwahodd i ddefnyddio’r ffurflen hon i gofnodi unrhyw sylwadau neu awgrymiadau.

Llenwch y ffurflen a’i adael yn y blwch wrth i chi adael un o’n arddangosfeydd.

Fel arall, gallwch e-bostio eich adborth i [email protected] neu ei bostio atom ni at Ymarfer Ymgynghori Fferm Wynt Gorllewin Coedwig Brechfa, RWE npower renewables Uned 22: Technium, Central Avenue, Parc Ynni Baglan, Port Talbot, SA12 7AX.

Gallwch wneud cais am gopïau o’r ffurflen hon drwy ffonio ni ar 01639 816180 a gallwch hefyd lawrlwytho oddi ar ein gwefan: www.npower-renewables.com/brechfaforest

Gwnewch yn siŵr byddwn yn derbyn eich adborth erbyn 5yh 6 Ebrill, 2011

1. Beth yw eich dref neu pentref agosaf?

2. A ydych yn cynrychioli grŵp neu sefydliad? Os felly, rhowch fanylion isod.

3. Sut cawsoch chi wybod am yr ymarfer ymgynhori hwn? (rhowch gylch o gwmpas bob u’n sy’n berthnasol)

Cylchlythyr Datganiadau I’r hysbysiad yn y cyfryngau Sylwadau eraill yn y cyfryngau Trwy eich cyngor cymunedol Trwy Grwp Cyswllt Cymunedol Poster Arall – ehangwch os gwelwch yn dda: Brechfa Forest West Wind Farm Consultation Report 303

Appendix M (cont…)

4. Os ydych yn llenwi’r ffurflen hon mewn arrddangosfa. Sut wneathoch chi deithio yma heddiw?

Car Bws Beic Ar droed Ar geffyl Arall – ehangwch os gwelwch yn dda:

Pwrpas yr ymarfer ymgynghori hwn yw cyflwyno gwybodaeth am y prosiect, ynghyd â’r wybodaeth ragarweiniol-amgylcheddol ar ffurf Datganiad Amgylcheddol (drafft). Mae’r ymarfer ymgynghori hwn yn gam pwysig yn y broses o wneud cais am y Fferm Wynt Gorllewin Coedwig Brechfa. Mae’n ein galluogi i gasglu eich barn ar adeg pan gallwch barhau i ddylanwadu ar ffurf derfynol y cynigion cyn i ni gyflwyno’r cais terfynol i’r CCS. Byddwch hefyd yn gallu gwneud sylwadau ynghylch y cais terfynol i’r CCS.

5. Wrth ddatblygu’r cais terfynol ar gyfer y Coedwig Brechfa Gorllewin Fferm Wynt, pa elfennau ydych chi’n teimlo sydd bwysicaf i RWE npower renewables eu hystyried? Rhowch gylch o gwmpas eich tair prif flaenoriaeth:

archeoleg brwydro yn erbyn newid yn yr hinsawdd creu swyddi effaith ar y coedwig effaith ar gyflenwad dwr sicrhau diogelwch cyflenwad ynni gwneud ymdrech I sicrhau bod digon o bellter o gartrefi lleihau’r effeithiau ar gyfinoedd planhigion ac anifeiliaid lleihau effaith weledol effaith ar hamddena neu mynediad Ir cyhoedd cludiant a mynediad

6. Rhowch unrhyw fanylion pellach y credwch y dylid eu hystyried:

a. archeoleg

Brechfa Forest West Wind Farm Consultation Report 304

Appendix M (cont…)

6. Rhowch unrhyw fanylion pellach y credwch y dylid eu hystyried:

b. brwydro yn erbyn newid yn yr hinsawdd

c. creu swyddi

d. effaith ar y coedwig

e. effaith ar gyflenwad dwr

f. sicrhau diogelwch cyflenwad ynni

g. gwneud ymdrech I sicrhau bod digon o bellter o gartrefi

h. lleihau’r effaith ar gyfinoedd planhigion ac anifeiliaid

i. lleihau effaith weledol

j. effaith ar hamddena neu mynediad ir cyhoedd

k. cludiant a mynediad

Brechfa Forest West Wind Farm Consultation Report 305

Appendix M (cont…)

7. A oes rhywbeth arall y dylech feddwl cale eu hystyried?

8. Os ydych yn meddwl y bydd y prosiect yn cael effaithiau positif, sut y gellid eu gwella neu eu eithaf?

9. Os oes gennych bryderon am y prosiect, sut ydych chi’n meddwl y gallai’r rhain gael eu hosgoi neu eu lleihau?

10. Rhowch unrhyw sylwadau penodol sydd gennych am elfennau canlynol y prosiect

a. Gosodiad y tyrbynnau gwynt

b. Lleoliad seilwaith

c. Arolygon sydd wedi cael eu cynnal

d. Mesurau lliniaru arfaethedig

Brechfa Forest West Wind Farm Consultation Report 306

Appendix M (cont…)

11. Rhowch unrhyw sylwadau pellach yr hoffech eu gwneud am gynlluniau datblygu RWE npower renewables:

Byddwn yn eich ddiweddaru ymhellach ynglun ar ymarfer ymgynghori a sut mae eich adborth wedi cael ei ystyried naill ai drwy e-bost neu’r post. Sylwch y byddwn ond yn darparu adborth llawn ar ôl ir ymarfer ymgynghori ddod i ben, felly gall fod ychydig o fisoedd cyn i chi gael ymateb.

Gadewch eich manylion cyswllt isod:

Enw:

Cyfeiriad:

Ebost:

Sylwch y bydd eich adborth yn cael eu trosglwyddo i Gyngor Sir Caerfyrddin ac y Comisiwn Cynllunio Seilwaith (CCS). Efallai y bydd eich sylwadau a manylion cyswllt ar gael i’r cyhoedd mewn Adroddiad Ymgynghori, sef dogfen sydd yn manylu’r holl sylwadau a dderbyniwyd a sut y maent wedi cael eu weithredu. Bydd yr adroddiad hwn yn cael ei gyflwyno i’r CCS fel rhan o’r y cais am Ganiatâd Datblygu ar gyfer Fferm Wynt Gorllewin Coedwig Brechfa. Brechfa Forest West Wind Farm Consultation Report 307

APPENDIX N

Section 48 notice

Section 48, Planning Act 2008 – the construction of a temporary electrical compound Gwyddgrug Post Office, Gwyddgrug, Carmarthenshire, 8. Copies of the draft Environmental Statement and – the temporary stopping up of public footpaths, during SA39 9AX (Opening hours: Monday – Saturday 7.30am - Non-Technical Summary can be obtained from: Regulation 4, Infrastructure Planning the construction of the works 8pm, Sunday 9.30am – 8pm) – the compulsory purchase of land and rights in land to RWE npower renewables (Applications: Prescribed Forms and facilitate construction of the proposed wind farm. The Old School Community Centre, Llansawel Road, Unit 22 Technium Sustainable Technologies Llanybydder, Carmarthenshire, SA40 9RN (Opening Baglan Energy Park Procedure) Regulations 2009 4. The proposed application is ‘EIA development’ for the hours: 9am – 4pm) Central Avenue purposes of The Infrastructure Planning (Environmental Port Talbot Notice of proposed application for Impact Assessment) Regulations 2009. This means that SA12 7AX development consent to construct the proposed works constitute development for which 7. Public Exhibitions an Environmental Impact Assessment is required. and The draft Environmental Statement is available at a cost and operate a wind farm within the proposed application will therefore be accompanied Friday 18 February 2011: 2pm – 8pm of £250 in hard copy format or on DVD (price £10). Brechfa Forest, Carmarthenshire. by an Environmental Statement. Brechfa Church Hall The draft Non-Technical Summary of the Environmental St. Teilo, Brechfa Statement is available free of charge. 5. The documents, plans and maps listed in paragraph Carmarthenshire 1. Notice is hereby given that RWE Npower Renewables 8 below and showing the nature and location of the SA32 7BL 9. If you wish to respond about the proposals please Limited of Auckland House, Lydiard Fields, Great Western proposed wind farm together with copies of the draft contact us by: Way, Swindon, Wiltshire, SN5 8ZT intends to apply for Environmental Statement (ES) and the Non-Technical Saturday 26 February 2011: 10am – 3pm development consent to the Infrastructure Planning Summary (NTS) which include the information so far Llanybydder Community School Post: Brechfa Forest West consultation Commission (‘IPC’) under section 37 of the Planning Act compiled about the environmental impacts (‘preliminary Llanybydder RWE npower renewables 2008 (‘the 2008 Act’) for the above-mentioned wind environmental information’), are available for download Carmarthenshire Unit 22 farm (‘the proposed application’). from our website: www.npower-renewables.com/ SA40 9RP Technium Sustainable Technologies brechfaforest. Those documents are also available for Central Avenue 2. RWE npower renewables constructs and operates viewing free of charge from the 10th February 2011 until Monday 28 February 2011: 2pm – 8pm Baglan Energy Park wind farms in the UKand is proposing to build a wind 6th April 2011 at the places and times set out below: Llanllwni Church Community Hall Port Talbot farm comprising 28 wind turbines with a generating Llanllwni, Pencader SA12 7AX capacity of between 56 and 84 megawatts (MW). The 6. Carmarthen Planning Office, Planning Services, Carmarthenshire proposed wind farm (to be known as Brechfa Forest Carmarthenshire County Council, 40 Spilman Street, SA39 9DR Email: [email protected] West Wind Farm) is located within Brechfa Forest in Carmarthen, SA31 1LQ (Opening hours: 9am to 5pm) Carmarthenshire. Because the generating capacity of the Thursday 10 March 2011: 2pm – 8pm Feedback forms are available on our website, or on wind farm is over 50 MW, application for development Carmarthen Library, St. Peters Street, Carmarthen, Llanpumsaint Memorial Hall request from RWE npower renewables: consent is required to be made to the IPC under the SA31 1LN (Opening hours: Monday – Wednesday and Friday: Heol Y Neuadd provisions of the 2008 Act. 9.30am to 7pm, Thursday and Saturday: 9.30am – 5pm) Llanpumsaint Tel: 01639 816180 Carmarthenshire 3. The proposed application to the IPC seeks development Llandeilo Planning Office, Planning Services, Civic SA33 6BZ Website: www.npower-renewables.com/brechfaforest consent for the construction and operation of a wind Offices, Llandeilo, SA19 6HW (Opening hours: 9am – 5pm) farm within Brechfa Forest, Carmarthenshire comprising Saturday 19 March 2011: 12pm – 5pm All responses must be received by 5pm on Wednesday the following development: Llandeilo Library, Crescent Road, Llandeilo, SA19 6HN Llanllwni Church Community Hall 6th April 2011. (Opening hours: Tuesdays and Fridays 10am – 12noon, Llanllwni – the construction of 28 wind turbines 1.30pm - 4.30pm, 5pm - 7pm; Wednesdays 1.30pm - Pencader RWE npower renewables requests that any response – approximately 9.1km of new access tracks 5.30pm; Saturdays 10am – 12noon.) Carmarthenshire which you wish to make indicates who is making – the upgrade of approximately 12.7km of existing SA39 9DR the response and provide an address to which any access tracks Brechfa Community Shop Brechfa,, Carmarthen, correspondence relating to the response may be sent. – the construction of an onsite substation Carmarthenshire, SA32 7QY (Monday and Thursday 9am – Saturday 26 March 2011: 12pm – 5pm Please note that responses will be made public. – the construction of hardstanding areas 1pm, Tu e s d ay and Saturday 9am – 12noon) Brechfa Church Hall – the construction of external transformers St. Teilo, Brechfa – the laying of underground cabling Pencader Post Office & Albion Stores, Albion Stores, Carmarthenshire – the construction of a permanent wind monitoring mast Pencader, Carmarthenshire, SA39 9ES (Opening hours: SA32 7B RWE npower renewables Limited – the construction of a temporary construction compound Monday – Saturday 6.30am – 8pm, Sunday 7am – 7pm) February 2011

Adran 48, Deddf Cynllunio 2008 – y pryniant gorfodol o dir a hawliau mewn tir i hwyluso Gwyddgrug Swyddfa’r Post, Gwyddgrug, 8. Gellir cael copïau o’r Datganiad Amgylcheddol (drafft) ac adeiladu’r fferm wynt arfaethedig. Sir Gaerfyrddin, SA39 9AX Crynodeb Annhechnegol ar gael gan: Rheoliad 4 Cynllunio Seilwaith (Oriau agor: Dydd Llun – Sadwrn 7.30am – 8pm, 4. Mae’r cais arfaethedig yn ‘ddatblygiad EIA’ at Dydd Sul 9.30am – 8pm) RWE npower renewables (Ceisiadau: Ffurfiau Rhagnodedig a ddibenion Deddf Cynllunio Seilwaith (Asesu Effeithiau Uned 22 Technium Amgylcheddol) 2009. Mae hyn yn golygu bod Asesiad Y Ganolfan Gymunedol Hen Ysgol, Heol Llansawel, Technolegau Cynaliadwy Gweithdrefn) 2009 o’r Effaith Amgylcheddol o effiathiau y cais arfaethedig Llanybydder, Sir Gaerfyrddin, SA40 9RN Ffordd Canolog yn ofynnol. Bydd y cais arfaethedig felly yn dod gyda (Oriau agor: 9am - 4pm) Parc Ynni Baglan Rhybudd o gais arfaethedig am Datganiad Amgylcheddol. Port Talbot ganiatâd i ddatblygu, adeiladu a SA12 7AX 5. Mae’r dogfennau, cynlluniau a mapiau a restrir 7. Arddangosfeydd Cyhoeddus gweithredu fferm gwynt o fewn ym mharagraff 8 isod yn dangos natur a lleoliad Bydd y Datganiad Amgylcheddol (drafft) ar gael ar Coedwig Brechfa, Sir Gaerfyrddin. y fferm wynt arfaethedig, ynghyd â chopïau o’r Dydd Gwener 18 Chwefror 2011: 2:00yh – 8:00yh gost o £ 250 ar ffurf copi caled neu ar DVD (pris £10). drafft Datganiad Amgylcheddol (ES) a’r Crynodeb Neuadd Eglwys Brechfa Mae’r Crynodeb Annhechnegol (drafft) o’r Datganiad Annhechnegol (CA) sy’n cynnwys y wybodaeth St Teilo, Brechfa Amgylcheddol ar gael yn rhad ac am ddim. 1. Hysbysir bod RWE Npower Renewables Limited o a gasglwyd hyd yn hyn ynghylch yr effeithiau Sir Gaerfyrddin Auckland House, Lydiard Fields, Great Western Way, amgylcheddol (‘gwybodaeth ragarweiniol SA32 7BL 9. Os ydych yn dymuno ymateb am y cynigion gwnewch Swindon, Wiltshire, SN5 8ZT yn bwriadu gwneud cais amgylcheddol’), ar gael i’w lawrlwytho oddi ar ein hynny yn ysgrifenedig at: am ganiatâd datblygu i’r Comisiwn Cynllunio Seilwaith gwefan-www.npower-renewables.com/brechfaforest. Dydd Sadwrn 26 Chwefror, 2011: 10yb – 3yh (‘CCS’) o dan adran 37 o Ddeddf Gynllunio 2008 (‘y Mae’r dogfennau hyn hefyd ar gael i’w gweld yn rhad Ysgol Gymunedol Llanybydder Post: ymgynghoriad Coedwig Gorllewin Brechfa Deddf 2008’) ar gyfer y fferm wynt uchod (‘y cais ac am ddim o’r 10fed o Chwefror 2011 tan 6ed o Ebrill, Llanybydder RWE npower renewables arfaethedig’). 2011 yn y mannau a’r amseroedd a nodir isod: Sir Gaerfyrddin Uned 22 SA40 9RP Technium Technolegau Cynaliadwy 2. Mae RWE npower renewables yn adeiladu a gweithredu 6. Swyddfa Cynllunio Caerfyrddin, Gwasanaethau Central Avenue ffermydd gwynt yn y DU ac yn bwriadu adeiladu fferm Cynllunio, Cyngor Sir Caerfyrddin, 40 Heol Spilman, Dydd Llun 28 Chwefror 2011: 2:00yh – 8:00yh Parc Ynni Baglan wynt yn cynnwys 28 tyrbin gwynt sy’n gallu gynhyrchu Caerfyrddin, SA31 1LQ Neuadd Eglwys Llanllwni Gymunedol Port Talbot rhwng 56 a 84 megawat (MW). Bydd y fferm wynt (Oriau agor: 9yb hyd at 5yh) Llanllwni SA12 7AX arfaethedig (i’w hadnabod fel Fferm Wynt Gorllewin Pencader Coedwig Brechfa) yn cael ei leoli o fewn Coedwig Llyfrgell Caerfyrddin, Heol San Pedr, Caerfyrddin, Sir Gaerfyrddin E-bost: neu drwy e-bost at [email protected] Brechfa yn Sir Gaerfyrddin. Gan fydd y fferm gwynt y SA31 1LN SA39 9DR gallu gynhyrchu y dros 50 MW mae’n ofynnol bod y (Oriau agor: Dydd Llun - Dydd Mercher a dydd Gwener: Ffurflenni adborth ar gael ar ein gwefan, neu ar gais gan cais am ganiatâd datblygu yn cael ei wneud i’r CCS dan 9.30am i 7pm, Iau a dydd Sadwrn: 9.30 am - 5 pm) Dydd Iau 10 Mawrth 2011: 2:00yh – 8:00yh RWE npower renewables: ddarpariaethau y Deddf 2008. Neuadd Goffa Llanpumsaint Swyddfa Cynllunio Llandeilo, Llandeilo Gwasanaethau Heol Y Neuadd Ffôn: 01639 816180 3. Mae’r cais arfaethedig i’r CCS sydd yn ceisio cael Cynllunio, Swyddfeydd Dinesig, SA19 6HW Llanpumsaint caniatâd datblygu ar gyfer adeiladu a gweithredu (Oriau agor: 9am - 5pm) Sir Gaerfyrddin Y We: www.npower-renewables.com/brechfaforest fferm wynt o fewn Coedwig Brechfa, Sir Gaerfyrddin yn SA33 6BZ cynnwys y datblygiad canlynol: Llyfrgell Llandeilo, Heol Cilgant, Llandeilo SA19 6HN Rhaid i’r holl ymatebion cael ei dderbyn erbyn 5yh (Oriau agor:. Dydd Mawrth a Dydd Gwener 10am - 12 Sadwrn 19 Mawrth 2011: 12:00yh – 5:00yh ddydd Mercher 6ed o Ebrill 2011. – adeiladu o 28 tyrbinau gwynt canol dydd, 1.30pm - 4.30pm, 5pm - 7pm; 13:30 Neuadd Eglwys Llanllwni Gymunedol – tua 9.1km o lwybrau mynediad newydd Dydd Mercher - 5.30pm; Dydd Sadwrn 10am - 12 Llanllwni Mae RWE npower renewables yn gofyn bod unrhyw – y uwchraddio o tua 12.7km o draciau mynediad presennol canol dydd) Pencader ymateb yr ydych yn dymuno gwneud yn nodi pwy sy’n – adeiladu o is-orsaf ar y safle Sir Gaerfyrddin gwneud yr ymateb ac yn rhoi manylion cyfeiriad lle mae – y gwaith o adeiladu ardaloedd caled Bryn Stores, Brechfa, Caerfyrddin, Dyfed, SA32 7QY SA39 9DR unrhyw ohebiaeth sy’n ymwneud â’r ymateb yn cael ei – adeiladu newidyddion allanol (Oriau agor: Dydd Llun a Iau 9am - 1pm, dydd Mawrth anfon. Nodwch y bydd yr ymatebion ar gael i’r cyhoedd. – gosod ceblau tanddaearol a dydd Sadwrn 9am - 12 hanner dydd.) Dydd Sadwrn 26 Mawrth 2011: 12:00yh-5:00yh – adeiladu mast monitro gwynt parhaol Neuadd Eglwys Brechfa – adeiladu cyfansoddyn adeiladu dros dro Swyddfa Bost a Siop Pencader Albion, Stores Albion, St Teilo, Brechfa – adeiladu cyfansoddyn trydanol dros dro Pencader, Sir Gaerfyrddin, SA39 9ES Sir Gaerfyrddin – cau llwybrau troed cyhoeddus dros dro, yn ystod y (Oriau agor: Dydd Llun - Sadwrn 6.30am – 8pm, Dydd SA32 7BL RWE npower renewables Limited gwaith adeiladu Sul 7am – 7pm) Chwefror 2011