Gwent Farmers’ Community Solar Scheme October 2016
Planning, Design and Access Statement
Gwent Farmers’ Community Solar Scheme
www.savills.co.uk
Project: Gwent Levels Community Solar Scheme
Client: Gwent Farmers’ Community Solar Partnership Ltd
Job Number: SG 1480
File Origin: Internal
Document Checking:
Prepared by: Nick Beddoe Signed: :
Checked by: Peter Grubb Signed:
Verified by: Peter Grubb Signed:
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Contents
1.0 Executive Summary ...... 1
2.0 Background Information ...... 4
2.1 Site area and Description ...... 4
3.0 Development Proposals ...... 7
3.1 Overview ...... 7
3.2 Proposed Biodiversity Areas and Landscaping ...... 10
3.3 Proposed Stock Proof Fencing ...... 10
4.0 Planning Policy Context ...... 12
4.1 Introduction ...... 12
4.2 National level commitments and guidance ...... 12
4.3 Energy Wales: A low Carbon Transition ...... 14
4.4 Planning Policy Wales (Edition 8, 2016) ...... 14
4.5 Technical Advice Notes ...... 18
4.6 Practice Guidance: Planning for Renewable and Low Carbon Energy - A Toolkit for Planners ... 19
4.7 Newport Local Development Plan 2011 – 2026 ...... 21
4.8 Newport Local Development Plan – Proposals and Constraints Maps ...... 26
4.9 Renewable and Low Carbon Energy Assessment: Torfaen County Borough Council and Newport
City Council ...... 28
5.0 Relevant Statutory Designations ...... 32
5.1 Overview ...... 32
5.2 SSSI Designations ...... 32
5.3 Gwent Levels Historic Landscape In Wales ...... 34
5.4 Severn Estuary Designations ...... 36
6.0 Principle of Development ...... 39
6.1 Overview ...... 39
7.0 Assessment of proposals against planning policy ...... 41
7.1 Ecology and Biodiversity ...... 41
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7.2 Heritage ...... 42
7.3 Landscape and Visual Impact ...... 43
7.4 Impact on Agricultural Land ...... 44
7.5 Flood risk and hydrology ...... 45
7.6 Traffic Management ...... 46
7.7 Impact on Amenity and Rights of Way...... 48
8.0 Sustainability Credentials ...... 49
8.1 Introduction ...... 49
8.2 Economic Sustainability ...... 49
8.3 Social Sustainability ...... 51
8.4 Environmental Sustainability ...... 52
9.0 Conclusions ...... 55
9.1 Summary ...... 55
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1.0 Executive Summary
The renewable energy hub seeks to provide green energy for over 15,000 homes and save over 21,000
tonnes of CO2 per annum. It will enable a group of nine local landowners to diversify their agricultural
enterprise and help secure their livelihood during uncertain times for farming communities.
The site is located on the Gwent Levels, to the south of the former Llanwern Steelworks site which
closed in 2001. The land is of poor agricultural value and the scheme would provide an enhancement
to the biodiversity of the area. Sheep would graze the site, which would maintain the agricultural use of
the land. The incorporation of a battery storage area will allow for the energy captured during the day
to be stored and re-used during times when energy is in greater demand and make the most of the
energy generated by a renewable source as well as helping to make it a viable proposal at a time when
subsidy has been removed.
The site has some unique advantages. The first is the high irradiation which the site benefits from
which will drive high levels of solar generation. The coastline in South Wales has a high solar irradiation
(1230 kWh/m² vs UK average of 1100 kWh/m²) and its location on a south facing coastline it benefits
from secondary irradiation or “bounce” where light “bounces” off the sea up into the atmosphere and is
then reflected down by particles in the air.
The second is the capacity of the local electricity network to accommodate a substantial new generator.
Elsewhere in the UK the electricity grid is under severe constraint and is rarely able to accommodate
new large generators without substantial and costly upgrades to the network which then make the
projects unviable. Llanwern and the area around it benefits from very large scale electricity
transmission assets which have considerable spare capacity. These were in the main put in to serve
the requirements of heavy industries which once existed along this coastline but are now no longer in
operation.
The third is that the land around Llanwern on the Gwent Levels is drained salt marsh of low agricultural
worth in relatively small parcels. Most of the farms on the Levels are less than 100 acres, so are lacking
the critical mass of larger farms and the quality of land to produce high yields. The land here is Grade
3b and grade 4, the latter of which is defined as “Land with severe limitations which significantly restrict
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the range of crops and / or level of yields.” It can be easily seen why this is a rural community in need
of investment and economic diversification.
The scheme covers around 345 acres (139 hectares) shared by farmers on the peninsular and an
application for planning permission is submitted to the Planning Inspectorate as a Development of
National Significance (DNS). The development will generate a consistent and reliable ground rent for
the farmers that will supplement their farm businesses and allow the continuation of the enterprise for
future generations.
In addition a proportion of the revenue from the scheme may be diverted towards local Parish Councils,
to be spent on local community projects which are in the early stages of discussion, including the Living
Levels scheme.
The Welsh Government is committed to renewable energy and has tough European targets to meet.
Ground Mounted Solar PV are a small but important part of the energy mix and this proposal will provide
enough green energy to power over 15,000 homes. To put this in perspective, the new community of
Glan Llyn (on the former Llanwern steelworks site) is planned to contain 4,000 new homes upon the
completion of the redevelopment in 2026–28.
The application is supported by a full Environmental Impact Assessment (EIA), the results of which
have helped to inform the design of the proposals. All of the conclusions that are reached in relation to
environmental impact are based on several years of environmental assessment.
Solar farms assimilate easily into the landscape as they are lower than the height of hedges and are
totally static. The site on the Gwent Levels is flat and largely set back from the local road and cycle
network. The site does not adjoin any houses and the villages of Whitson and Goldcliff are well
screened from the site. The submitted EIA demonstrates that the proposal would not give rise to any
unacceptable impacts to the local or wider landscape.
The scheme lies wholly within the Gwent Levels Outstanding Landscape of Historic Interest. As such,
the proposal has been informed by rigorous heritage assessment work including for above ground and
below ground heritage assets. Overall the project during its operational phase will have a minor adverse
to negligible effect on the value, coherence, legibility and significance of the historic landscape. The
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preservation by record of any archaeological deposits impacted by the Scheme will mitigate any
impacts to the archaeological resource where discovered.
The site and adjoining areas have been subject to long periods of ecological survey work for a full suite
of biodiversity, including birds and invertebrates. The results have helped to shape the proposals and
enabled a suitable mitigation scheme to be devised. The proposals will not lead to a significant adverse
effects to local biodiversity and it is in fact well documented that solar farms can serve to enhance local
biodiversity by creating large areas of undisturbed land free from intensive agriculture and regular
human contact.
The site lies within the flood plain, which is one of the factors that has led to the economic issues in the
area. However, solar arrays are flood resilient and only consume a tiny fraction of the flood storage
capacity of the area (less than 1%).
In terms of traffic, the scheme will attract less traffic than agricultural activity on the land. There will
inevitably be a short period of construction and as such a construction management plan has been
devised to manage this process and ensure there is no disruption on local roads in the short term.
A website has been set up by the applicant to enable interested parties to access the supporting
information and keep up to date with progress.
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2.0 Background Information
2.1 Site area and Description
The site is located on agricultural land on the Gwent levels in south Wales and lies within the local plan
area for Newport City Council. At a local level, the site lies within the Llanwern ward and the Goldcliff
Community Council Boundary.
The site occupies a distinctively flat area of land to the south of the former Llanwern steelworks site
and is shown below in Error! Reference source not found.. It is split into six distinct parcels of land,
hich have been carefully selected to provide significant buffers from the local settlements of Whitson
and Goldcliff.
The wider area is characterised by the distinctively flat landscape which is divided by reens and
interspersed with small settlements.
Figure 1: Levels landscape
The area hosts a large electricity substation known as the Magor Substation, from which extend
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numerous large pylons carrying 132 kv lines. The substation is shown on the map below.
Substation
Figure 2: Magor substation
The substation building itself and the pylons are dominating features to the north of the site and inform
the character of the area. One of the 132 KV lines would facilitate a connection to the electricity grid.
Figure 3: View of site showing electrical pylons
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The eastern edge of the site is bound by an elevated pipeline, which helps to physically obscure the site from the east.
Figure 4 View of the pipeline
There are a number of public rights of way that cross the levels. These can be seen on the map below and have been taken into account in laying out the development proposals.
Figure 5: Network of PROW
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3.0 Development Proposals
3.1 Overview
This statement accompanies a planning application for the development of a renewable energy hub
comprising a 49.9MW solar farm (export capacity), 200 battery storage units and associated
infrastructure on land at Llanwern on the Gwent Levels. The proposals seek to provide green energy
for over 15,000 homes and save over 21,000 tonnes of CO2 per annum.
The development requires a site of around 345 acres and is spread over six distinct parcels of land
which make up the site area. The eastern most part of the site adjoins an elevated pipeline. Figure 6
shows the location and configuration of the site in relation to the nearby settlements and the Whitson
sub-station.
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Figure 6 Site location
The proposal is for a ground mounted solar farm with arrays set out in rows and mounted on a
framework system which is either screwed or driven in to the ground.
The proposals include supporting infrastructure and a battery storage area which will allow for the
energy captured during the day to be stored and re-used during times when energy is in greater
demand, making the most of the energy generated by a renewable source and helping to make the
scheme viable and flexible to meet the demands of the grid.
The grid connection hub is located to the north of the between two pylon lines approaching the Whitson
Sub-station. It will sit alongside the battery storage area and be immediately accessed via a track
connecting the site with North Row. The closure of the steel works has resulted in spare capacity on
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the existing grid infrastructure, which is an unusual position at a time where most grid infrastructure is
at capacity.
The proposals will be temporary for a period of 30 years after which the site could be returned to its
current condition, with a positive legacy of planting and landscape management retained for the benefit
of the area.
Sheep would be grazed between the panels. While providing an additional income for the landowners
they also serve to maintain the grassland.
The proposed development includes supporting infrastructure comprising inverter cabins, transformers,
grid connection hub, stock proof fence, CCTV, underground cabling, temporary vehicle tracks, access
and landscaping.
Solar PV panels silently convert sunlight to electrical energy. They generate direct current (DC) that is
converted by the inverter hardware to alternating current (AC) that can be used by the electricity grid.
PV systems are rated for capacity in watts (or kW or MW) with the designation 'peak' (e.g. kWp, MWp).
The peak capacity of individual panels is established by measuring their performance under
internationally recognised standard conditions that include temperature and wavelength of sunlight.
The actual output of a system will be determined by latitude, local weather and site conditions.
The proposals would export 49.9 MW of electricity. The export of electricity would be controlled by the
inverters. In accordance with guidance outlined by the Solar Trade Association1 this would offset around
21,208 tonne tonnes of Co2 per annum, and 636,240 tonnes over the life of the scheme. This
(conservatively) equates to enough electricity to serve the total power needs of around 15,000 average
UK households per annum.
To put this in perspective, the new community of Glan Llyn (on the former Llanwern steelworks site) is
planned to contain 4,000 new homes upon the completion of the redevelopment in 2026–28. Based
upon an notional density of 35 dwellings per hectare (which is considered typical for modern housing
developments), this would provide enough electricity for a development of 428 hectares. The whole of
the former Llanwern steelworks site (shown below in Figure ) covers an area of 415 hectares,
1 Solar Trade Association 2016: Resource Centre - http://www.solar-trade.org.uk/solar-farms/
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demonstrating the sheer capacity of the proposed scheme to provide a substantial amount of renewable
energy.
Figure 7 Area covered by former Llanwern steelworks site
3.2 Proposed Biodiversity Areas and Landscaping
The site has been surveyed in detail to understand the location and species of animals, insects, trees
and plants that currently exist on the site. Existing hedges and trees are to be maintained and habitats
are to be conserved and enhanced through the implementation of biodiverse areas around the field
boundaries. There will be a buffer of at least 7m from all reens and 12m to main rivers (see FCA). This
will serve to enhance the important reen habitats for which the SSSI is designated and will supported
the protected species identified in the completed Ecology surveys.
3.3 Proposed Stock Proof Fencing
There would be a stock proof fence around the perimeter of the solar farm development. The fence is
agricultural in nature and can be provided under permitted development up to 2m. The fence would be
used for security purposes and to guard against potential damage by livestock and wildlife; however, it
will be screened by the existing trees and hedges, and by additional planting. The fence will also allow
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for the passage of small mammals through and under it and as such will leave a gap from the ground
of around 50mm. The fence would not be used within individual field parcels but would be routed around
the periphery of each site parcel.
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4.0 Planning Policy Context
4.1 Introduction
This section outlines the relevant planning policy context to the proposals. It refers to government
strategies, practice guidance and planning documents at both the local and national levels.
At the National level, Planning Policy Wales Edition 8 (PPW) (January 2016), as well as a range of
supplementary Technical Advice Notes (TANs) and Practice Guidance are relevant considerations.
Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires than an application for
planning permission should be determined in accordance with the Development Plan, unless material
considerations indicate otherwise. To this end, the Newport Local Development Plan 2011 – 2026 and
the associated Supplementary Planning Guidance (SPG) constitute the statutory development plan
against which the proposals must accord.
This section will first consider the National Level Policy context before outlining the relevant Local
Planning policies and guidance.
4.2 National level commitments and guidance
Stemming from its obligation to the legally-binding targets set by the European Union2, the UK
government has committed to supplying 15% of its energy from renewable sources by 2020.
In planning to meet this target, DECC published the UK Renewable Energy Roadmap (2011), which
set out a comprehensive suite of targeted, practical actions to accelerate renewable energy in the UK.
The publication of this document was followed by a surge in the growth and success of the Solar PV
industry, which was acknowledged within the updated Energy Roadmap in 2013.
This success prompted DECC to form a Solar PV Strategy Group and prepare a specific Solar PV
Strategy Roadmap. The Roadmap has been published in two parts, the first in October 2013 and the
second in April 2014. Part One established the general principles and vision for the solar industry, whilst
Part Two set out the particular ambitions for deployment in relation to each market area, including large-
2 European Union (EU) 2020 Climate Change and Energy Package
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scale ground mounted schemes.
The Solar PV Strategy Group is comprised of 5 ‘Task forces’, which deal with the specific issues facing
the industry in relation to; Land Use, Engagement, Grid, Innovation and Finance. These issues reflect
the various constraints related to the deployment of Solar PV and Part 2 of the Roadmap reflects the
on-going work of these five Task Forces.
The Land Use Task Force is chaired by the NFU who have worked with the Solar Trade Association
(STA) to develop “10 Commitments” of good practice in solar farm development. These are recognised
as a set of industry best practice guidelines to ensure the quality of solar farms built and managed in
the UK. These state that developers should seek to fulfil the following duties:
1. Focus on non-agricultural land or land which is of lower agricultural quality.
2. Be sensitive to nationally and locally protected landscapes and nature conservation areas,
and we welcome opportunities to enhance the ecological value of the land.
3. Minimise visual impact where possible and maintain appropriate screening throughout the
lifetime of the project managed through a Land Management and/or Ecology plan.
4. Engage with the community in advance of submitting a planning application, including
seeking the support of the local community and listening to their views and suggestions.
5. Encourage land diversification by proposing continued agricultural use or incorporating
biodiversity measures within our projects.
6. Do as much buying and employing locally as possible.
7. Act considerately during construction, and demonstrate ‘solar stewardship’ of the land for the
lifetime of the project.
8. Offer investment opportunities to communities in their local solar farms where there is local
appetite and where it is commercially viable.
9. Commit to using the solar farm as an educational opportunity, where appropriate.
10. At the end of the project life, return the land to its former use.
The supporting notes to these guidelines explains that ground-mounted solar schemes should:
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“Ideally utilise previously developed land, brownfield, contaminated land, industrial land and
preferably agricultural land of classification 3a, 3b, 4, and 5 (in most instances avoiding use of the
‘Best and Most Versatile’ cropland where possible). Land selected should aim to avoid affecting the
visual amenity of landscapes, maintaining their natural beauty, and should be predominantly flat, well
screened by hedges, tree lines, etc., and not unduly impact upon nearby domestic properties or
roads.”
4.3 Energy Wales: A low Carbon Transition
This document sets out the principles of delivering energy policies in Wales, with the expressed aim to
‘create a sustainable, low carbon economy for Wales’.
In outlining the aims for delivering renewable energy, the document states that it wants to be;
“Making the best use of commercially proven renewable energy sources – such as onshore and
offshore wind, solar, bio-energy and hydro – we want to facilitate appropriate deployment to deliver
against our low carbon objectives, contribute to wider UK and EU aims and realise the significant
wealth-generating opportunities Wales has.
We want to ensure that following best practice engagement of our communities, the appropriate
technology is deployed at the appropriate sites in a way that delivers for business, benefits communities
and supports the long term prosperity of Wales. In so doing we expect to achieve an energy mix across
energy sectors and different scales – with greater contributions from micro and community scale
developments alongside developments at a larger scale.”
4.4 Planning Policy Wales (Edition 8, 2016)
The Welsh Government is has a distinctive statutory duty in relation to sustainable development as
established by the Well-being of Future Generations (Wales) Act 2015. The Act places a duty on public
bodies (including Welsh Ministers) that they must carry out sustainable development. and the planning
system is seen as a “necessary and central” tool to achieving this goal.
Planning Policy Wales (Edition 8, July 2016), sets out the national tier of land use planning policies for
Wales and is supplemented by a series of Technical Advice Notes (TANs). The document translates
the Welsh Government’s “commitment to sustainable development into the planning system so that it
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can play an appropriate role in moving towards sustainability”.
As such, sustainable development is central to PPW and is a fundamental objective of the policies and
visions which it contains. Indeed, paragraph 4.2.2 explains that “The planning system provides for a
presumption in favour of sustainable development to ensure that social, economic and environmental
issues are balanced and integrated, at the same time”.
Paragraph 4.1 explains what is meant by ‘sustainable development in this context and states:
“Sustainable development” means the process of improving the economic, social, environmental and
cultural well-being of Wales by taking action, in accordance with the sustainable development principle,
aimed at achieving the well-being goals”.
Planning For Sustainability
Chapter 4 of PPW sets out the specific planning policies for achieving sustainable development across
Wales. Paragraph 4.4.3 sets out the key aims of this national policy to:
“Support the need to tackle the causes of climate change by moving towards a low carbon economy.
This includes facilitating development that reduces emissions of greenhouse gases in a sustainable
manner, provides for renewable and low carbon energy sources at all scales and facilitates low and
zero carbon developments.”
Paragraph 4.5 explains that the Government has made a “commitment to tackling climate change
resolving that the Government and people of Wales will play the fullest possible part in reducing its
carbon footprint”.
Paragraph 4.5.7 relates to the Planning measures taken to minimise the causes of climate change. It
explains that “decisive action is required to move towards a low carbon economy by proactively
reducing the demand for energy, facilitating the delivery of new and more sustainable forms of energy
provision at all scales and minimising the emissions of greenhouse gases to the atmosphere.”
Paragraph 4.6.4 acknowledges that “the countryside is a dynamic and multi-purpose resource”. It
recognises that whilst it should be conserved and enhanced, the countryside also “plays a role in
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reducing the causes of climate change through the protection of carbon sinks and as a sustainable
energy source”.
Paragraph 4.9.1 states that “Previously developed (or brownfield) land (see Figure 4.3) should,
wherever possible, be used in preference to greenfield sites, particularly those of high agricultural or
ecological value. The Welsh Government recognises that not all previously developed land is suitable
for development. This may be, for example, because of its location, the presence of protected species
or valuable habitats or industrial heritage, or because it is highly contaminated. For sites like these it
may be appropriate to secure remediation for nature conservation, amenity value or to reduce risks to
human health.”
Paragraph 4.10.1 explains that development plan policies and development management decisions
should give ‘considerable weight’ to protecting agricultural land of grades 1, 2 and 3a from
development, because of their special importance.
Conserving and Improving Natural Heritage and the Coast
Chapter 5 (Conserving and Improving Natural Heritage and the Coast) sets out The Welsh
Government’s objectives for the conservation and improvement of the natural heritage.
Paragraph 5.1.3 states that the planning system must ensure that “society’s land requirements are met
in ways which do not impose unnecessary constraints on development whilst ensuring that all
reasonable steps are taken to safeguard or enhance the environment”. It continues to explain that
“conservation and development can often be fully integrated. With careful planning and design, not only
can the potential for conflict be minimised, but new opportunities for sustainable development can also
be created”.
Within paragraph 5.2.8 it is stated that “The planning system has an important part to play in meeting
biodiversity objectives by promoting approaches to development which create new opportunities to
enhance biodiversity, prevent biodiversity losses, or compensate for losses where damage is
unavoidable...”
Paragraph 5.3.2 states that “local planning authorities should have regard to the relative significance
of international, national and local designations in considering the weight to be attached to nature
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conservation interests and should take care to avoid placing unnecessary constraints on development”.
Paragraph 5.5.1 highlights the important need “to balance conservation objectives with… wider
economic needs” and that “Where development does occur it is important to ensure that all reasonable
steps are taken to safeguard or enhance the environmental quality of land”.
It is stated within paragraph 5.5.8 that “With regard to SSSIs… the Wildlife and Countryside Act, as
amended… places a duty on all public bodies (including local planning authorities) to take reasonable
steps… to further the conservation and enhancement of the features by reason of which a SSSI is of
special interest.”
Conserving the Historic Environment
The principal objective of Chapter 6 is to protect the historic environment encompassing archaeology
and ancient monuments, listed buildings, conservation areas and historic parks, gardens and
landscapes.
Paragraph 6.1.2 states that “Local planning authorities have an important role in securing the
conservation of the historic environment while ensuring that it accommodates and remains responsive
to present day needs. This is a key aspect of local authorities’ wider sustainable development
responsibilities”.
Infrastructure and Services
Paragraph 12.8.2 of PPW states that “Planning policy at all levels should facilitate delivery of both the
ambition set out in Energy Wales: A Low Carbon Transition and UK and European targets on renewable
energy”.
Paragraph 12.9.7 states that “the potential for renewable and low carbon energy development within
urban/industrial brownfield sites remains largely untapped and that there may be further opportunities
for the development of wind or other renewable energy schemes on urban/industrial brownfield sites.”
Chapter 12.10 relates to the Development Management of renewable energy developments and sets
out a criteria which authorities must consider in determining such applications. These include, but are
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not limited to;
The contribution a proposal will play in meeting identified national, UK and European targets
and potential for renewable energy, including the contribution to cutting greenhouse gas
emissions;
The wider environmental, social and economic benefits and opportunities from renewable
and low carbon energy development;
The impact on the natural heritage, the Coast and the Historic Environment;
The need to minimise impacts on local communities to safeguard quality of life for existing
and future generations;
Ways to avoid, mitigate or compensate identified adverse impacts;
The impacts of climate change on the location, design, build and operation of renewable and
low carbon energy development. In doing so consider whether measures to adapt to climate
change impacts give rise to additional impacts;
Grid connection issues where renewable (electricity) energy developments are proposed
Paragraph 12.10.3 states that “Developers for renewable and low carbon energy developments
should seek to avoid or where possible minimise adverse impacts through careful consideration of
location, scale, design and other measures”.
4.5 Technical Advice Notes
The Planning Policies set out within Planning Policy Wales (Edition 8, 2016) are supplemented by a
series of topic based Technical Advice Notes (TANs), which provide detailed planning advice on
specific matters.
TAN 5 Nature Conservation and Planning, sets out the key principles of planning for nature
conservation in relation to development proposals.
Under Paragraph 5.1.6 of this note it is explained that:
“Local planning authorities, along with other public bodies, have a duty to take reasonable steps,
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consistent with the proper exercise of their functions, to further the conservation and enhancement
of the features by reason of which SSSIs are of special scientific interest” [own emphasis]
TAN 6 Planning for Sustainable Rural Communities, provides practical guidance on the role of the
planning system in supporting the delivery of sustainable rural communities.
The introduction to the note explains that “Simultaneously, the planning system must respond to the
challenges posed by climate change, for example by accommodating the need for renewable energy
generation.”
Paragraph 3.7.2 states that many economic activities can be sustainably located on farms and that the
production of non-food crops and renewable energy, are likely to be appropriate uses.
TAN 8 Renewable Energy, provides guidance on land use planning in relation to onshore renewable
energy technologies and how renewable energy should be accounted for as part of development plans,
development management and monitoring processes.
Under Paragraph 1.4 the advice note reiterates the Welsh Government’s target to generate 7 Terawatt
hours (TWh) of electricity by 2020. Statistics published by DECC3 reveal that in 2015 Wales generated
just 5.1 TWh, leaving a significant shortfall to be made up in order to achieve the Government’s target.
TAN 8 does not make specific reference to the deployment of ground-mounted solar PV and instead
focuses on roof-top installations. In this respect the advice note is somewhat out of date and does not
provide a useful source of planning policy guidance in relation to these proposals.
4.6 Practice Guidance: Planning for Renewable and Low Carbon Energy - A Toolkit for Planners
The Welsh Government has commissioned the preparation of a Planning guidance document
(‘Toolkit’), in order to support local authorities in planning for the development required to meet stringent
energy and emissions targets. The document sets out “how a local authority can prepare a robust
evidence base to underpin a number of LDP spatial policies that can support and facilitate the
deployment of renewable and low carbon energy systems”.
3 DECC (2016) Energy Trends March 2016
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The outcome of this toolkit is an evidence base, comprising an assessment of the potential for
renewable and low carbon energy generation, at different scales, and at different levels of detail.
The Guidance explains that “Local Authorities have several key roles to play that can facilitate the use
and generation of renewable and low carbon energy”. The Development Management process is
identified as fulfilling one of these roles via the following means:
“Taking decisions on planning applications submitted to the local planning authority for development;
as well as preparing Local Impact Assessments for schemes which are determined by the Planning
Inspectorate”
Despite outlining this role, the toolkit is primarily focused on planning policy and not Development
Management. In this respect, it is explained that the document is not intended for use in assessing
development proposals, but should instead be used to guide LPAs on how to prepare an evidence base
to support renewable and low carbon energy policies and site allocations in their LDPs.
To this end, the Toolkit provides a methodology for LPAs to follow in order to identify and allocate areas
for potential PV Farm projects. It is intended that this methodology will enable a high level assessment
of the potential solar resource from ground-mounted PV considering the likely constraints presented by
a range of land-based designations. This is a process known as constraints mapping.
As a relatively new phenomena, the toolkit notes that there is currently no standard agreed method to
constraints mapping for Solar PV Farms. Consequently, the toolkit presents only one ‘potential
approach’ which is not enshrined by any means within planning policy, nor binding to the Local
Authorities using the guidance.
Moreover, the toolkit is intended only to enable a visual overview of potential sites locations which are
in general terms less ‘constrained’ than other locations in the plan area. It acknowledges that the
process of constraints mapping will not automatically identify sites which are suitable for the deployment
of PV and that consideration of a wider range of factors will be required in order to determine such
suitability. Indeed, the guidance explains that:
. . “detailed assessment of a particular site may reveal proposed PV farm impacts to be
manageable and to meet regulatory and policy requirements
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Conversely, land indicated as suitable through GIS mapping may prove to be technically
and/or financially unviable”
This is due to the specific challenges of solar PV farm development and the range of additional
considerations which are not factored within the toolkit’s proposed methodology for a high level
assessment. The guidance notes that such considerations include the requirement for an
economically viable (relatively short distance from the solar array to an appropriate connection point)
grid connection, practical access to sites required for development, landowner willingness for
development to proceed, and the likely impact on landscape character.
4.7 Newport Local Development Plan 2011 – 2026
Provisions made through Section 38(6) of the Planning and Compulsory Purchase Act (2004) indicate
that for any application for planning permission made to the local authority, the determination must be
made in accordance with the development plan unless material considerations indicate otherwise.
Despite the application being made as a Development of National Significance (DNS), this legislation
establishes the primacy of the development plan in the determination of the planning application.
For the purposes of this application, the pertinent development plan is the Newport Local Development
Plan 2011 – 2026 which was formally adopted in January 2015.
It is explained within the Foreword to the LDP that “Sustainability is at the heart of the Plan” and that
“Newport City Council is very keen to support development”. In this respect, the plan presents itself as
a ‘sustainable development strategy’ which has been prepared in the “context of the growing awareness
of the need to produce and use energy in more sustainable ways”.
In setting out is strategic vision the plan outlines 10 specific objectives which seek to address the key
issues facing Newport and the wider agenda for Wales.
Objective 1 refers to the Sustainable Use of Land and aims “to ensure that all development makes the
most efficient use of natural resources by seeking to locate development in the most sustainable
locations, minimise the impact on the environment and make a positive contribution to local
communities”.
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Objective 2 outlines the plan’s objective to tackling Climate Change. It states:
“To ensure that development and land uses in Newport make a positive contribution to minimising,
adapting to or mitigating against the causes and impacts of climate change by incorporating the
principles of sustainable design, changes to travel behaviour, managing the risks and consequences
of flooding, and improving efficiency in the use of energy, waste and water.”
Objective 6 relates to the Conservation of the Natural Environment. The objective aims “To protect and
enhance the quality of the natural environment, including… protected habitats and species of principal
importance for biodiversity in Wales (regardless of greenfield or brownfield status) and the protection
of controlled waters”.
Policy SP1 – Sustainability states that ‘Proposals will be required to make a positive contribution to
sustainable development… reducing energy consumption, increasing energy efficiency and the use of
low and zero carbon energy sources’.
Policy SP5 relates to development in the countryside and explains that such development “will only be
permitted where the use is appropriate in the countryside, respects the landscape character and
biodiversity of the immediate and surrounding area and is appropriate in scale and design… rural
diversification and rural enterprise uses, beyond settlement boundaries, will only be appropriate where
they comply with national planning policy.
Policy CE10 [Renewable Energy] states that renewable energy schemes will be “considered
favourably, subject to there being no over-riding environmental and amenity considerations.” It further
states that “large scale proposals may be more appropriately located outside of the defined settlement
boundary if no appropriate brownfield sites exist” and that the “cumulative impacts of renewable energy
schemes will be an important consideration”.
Paragraph 4.51 of the supporting text to the policy explains that particular care should be taken when
assessing proposals for renewable energy projects in sensitive, designated areas, such as areas of
high landscape quality, and areas of nature conservation, or archaeological or historical importance. It
continues to state that:
“The Gwent Levels are recognised as an internationally important resource in terms of landscape
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and heritage and nationally important for ecology. Proposals which affect the special qualities of the
Gwent Levels, or any other protected site, will be resisted unless it can be demonstrated that there
will be no significant adverse effects.”
As a starting point Paragraph 4.55 explains that:
“Brownfield sites within the settlement boundary will be favourably considered and where possible,
should be considered before greenfield options“. However, it continues to state that:
“Development of larger scale renewable energy schemes may be acceptable on greenfield sites
where it can be demonstrated that there will be no significant adverse impacts on the environment
and local communities.“
In accordance with the planning guidance set out within the ‘Toolkit’ the Council has undertaken a
Renewable Energy Assessment, which sets out the potential for renewable energy resources and
technologies within the plan area. The Development Plan states that this assessment should be
considered when evaluating renewable energy proposals.
The application site lies within the Gwent Levels, which is one of four Archaeologically Sensitive Areas
designated under the local development plan. As such the following extract of Policy CE6 Archaeology
is relevant to the proposals:
“Development proposals will normally be required to undertake an archaeological impact assessment
before the proposal is determined:
i. Where groundworks and/or the installation of services are proposed within the
Archaeologically Sensitive Areas of Caerleon, the Levels, Lower Machen and the City
Centre”
Adopted Supplementary Planning Guidance to this policy explains that this designation highlights the
archaeological potential of these areas and the need to seek professional archaeological advice to
ascertain the true significance of a site. It further states that:
“The designation of an ASA is not intended to introduce new policies or restrictions to development
but to indicate to developers, areas where it is likely that the effect of the development on the
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archaeological resource may become an issue during the determination of a planning application.”
The site lies within the Caldicot Levels Special Landscape Area as designated on the basis of the
LANDMAP assessment process. Special Landscape Areas (SLAs) are a non-statutory local landscape
designation used by Local Planning Authorities to define areas of landscape importance. Below, Figure
1 shows the boundary of this SLA and the location of the application site within the area.
Figure 1 Caldicot Levels Special Landscape Area with site location shown as inset
Policy SP8 explains that proposals in these areas “will be required to contribute positively to the area
through high quality design, materials and management schemes that demonstrate a clear appreciation
of the area’s special features”.
NCC have prepared a ‘Topic Paper’ which provides a background to the policies contained within the
Local Development Plan on the subject of Special Landscape Areas (SLAs) within the plan area.
The paper outlines the primary landscape qualities and features for the Caldicot Levels Area as follows:
“(The) SLA forms part of the extensive area of reclaimed marsh and wetlands that extends from
Cardiff to Chepstow. Reaching up to 10 metres AOD, the area is characterised by its network of
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drainage ditches (reens) which vary in form and character. The eastern edge of the SLA is
characterised by a regular, rectilinear pattern, whereas around Whitson and Caldicot the pattern is
more sinuous.”
Conversely, the “main visual detractors to the SLA” are also identified and are described as “the
interface with the Llanwern Steelworks site on its northern boundary and the cluster of overhead power
lines that focus upon Uskmouth power station.”
The site also lies within the Gwent Levels area of the ‘Undeveloped Coastal Area’. As such it subject
to the requirements of Policy CE9 Coastal Zone, which states that:
“Development will not be permitted in the coastal area or adjoining the tidal river unless:
i. In the undeveloped coastal area such development is required to be on the coast to meet an
exceptional need which cannot reasonably be accommodated elsewhere;
ii. the area is not itself at risk nor will the proposed development exacerbate risks from erosion,
flooding or land instability”
In the supporting text to this policy, Paragraph 4.45 explains that the undeveloped coastal area will:
“Rarely be appropriate for major development. Proposals for such development will need to
demonstrate that such a location is essential and that the proposal is acceptable having regard to
other Policies of this Plan. Sufficient information will be required to demonstrate that the proposed
development can be carried out without significant adverse effects.”
In specific reference to the Gwent Levels and the Severn Estuary, the supporting text describes how
numerous statutory and non-statutory designations afford the area a variety of protection against
inappropriate development.
The site is located within an area recognised for its importance to local wildlife and spans two Sites of
Special Scientific Interest (SSSI). As such GP5 General Development Principles – Natural Environment
is of relevance to the proposals. This states that:
“Development will be permitted where, as applicable:
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i. the proposals are designed and managed to protect and encourage biodiversity and
ecological connectivity, including through the incorporation of new features on or off site to
further the UK, Welsh and/or Newport biodiversity action plans;
ii. the proposals demonstrate how they avoid, or mitigate and compensate negative impacts to
biodiversity, ensuring that there are no significant adverse effects on areas of nature
conservation interest including international, European, National, Welsh section 42 and local
protected habitats and species, and protecting features of importance for ecology;
iii. the proposal will not result in an unacceptable impact on water quality; the proposal should
not result in the loss or reduction in quality of high quality agricultural land (grades 1, 2 and
3a);
iv. there would be no unacceptable impact on landscape quality;
v. the proposal includes an appropriate landscape scheme, which enhances the site and the
wider context including green infrastructure and biodiversity networks;
4.8 Newport Local Development Plan – Proposals and Constraints Maps
Figure 2 and Figure 3 respectively show the Proposals and Constraints maps in relation to the Local
Development Plan. The maps show the relevant Local Planning Policy and Statutory designations
which apply to the site and the wider geographic area.
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Figure 2 NCC Proposals Map showing site area
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Figure 3 NCC Local Plan Constraints Map
4.9 Renewable and Low Carbon Energy Assessment: Torfaen County Borough Council and
Newport City Council
A joint study into the potential for the deployment of low carbon energy in Newport and Torfaen was
completed in 2013 by consultants Verco Global. The study provides an evidence base for the two local
authorities and help to facilitate renewable energy generation the pertinent local planning policies
(Policy CE10 in Newport).
The study aims to develop an understanding of local renewable resources, constraints and
opportunities, and to identify opportunities to include renewable energy schemes, district heating and
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combined heat and power into development proposals. However, it is explained within the document
that:
“The spatial elements of this study are not intended for use by development management officers to
assess individual planning applications for either strategic new development sites that are
incorporating renewable energy, or for stand-alone renewable energy generating systems. Further
detailed survey work would need to be undertaken to assess development potential and viability.”
The methodology for the study accords with the guidance set out within the Welsh Government’s
Planning for Renewable and Low Carbon Energy – A Toolkit for Planners (July 2010) which has been
described within Paragraph 4.6 of this document.
Capacity
The study identifies the existing and proposed capacity of renewable energy and fossil fuel generation
within the NCC plan area at the time in which the study was undertaken (2013). At the time of writing,
the existing renewable energy capacity totalled 14.6MW with a further 42.8MW proposed through the
planning system. This comprised an estimated installed capacity of 5.5MW by Solar PV (including an
estimated 3MW of domestic rooftop solar) and a further proposal for a 2MW solar farm at Clearwell
Farm.
Since the time of this study an application for a solar farm with a generating capacity of 3.9MW was
approved in the plan area, on land to the west of Park Farm, Malthouse Lane, Caerleon (ref 15/0902).
Another application for a 5.3 MW solar farm was withdrawn on the 13th October 2013 (ref 14/0531).
There is also likely to have been a further increase in capacity from rooftop solar, although the level of
this increase is difficult to estimate.
The study also identifies the presence of two large fossil fuel generating plants within the plan area; the
Uskmouth Power Station, a 360MW coal-fired power station and Severn Power, a 850MW gas-fired
power station. Therefore, despite these increases in renewable energy capacity, the study has shown
that the area’s generating capacity from renewable sources continues to fall far short of the its non-
renewable capacity.
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Targets
Projections made within the study indicate that by the end of the plan period (2026) electricity demand
within the NCC plan area will be 863 GWh/yr.
In terms of supply, the study identifies the ‘renewable energy potential’ for each renewable technology,
based upon the analysis completed to appraise the associated constraints an opportunities for their
deployment. For ground-mounted solar PV the total ‘Potential accessible resource’ is estimated at 17
GWh whilst the combined total potential all renewable technologies is projected at 338 GWh.
In accordance with guidance set out in the Planning for Renewable and Low Carbon Energy Toolkit the
study outlines ‘High’ and ‘Low’ target scenarios for how much of this potential might actually be realised
within the period to 2026. Assuming a ‘High’ (75%) take up of this theoretical potential, the total possible
supply from renewable sources would be 237 GWh. This would provide 27% of the projected demand
by 2026. A ‘Low’ (50%) take up would provide 152 GWh, meeting just 18% of the projected demand.
Identified Opportunities
The study continues to form an assessment of the potential for ground mounted PV, based upon a GIS
analysis of the following land based constraints:
Grade 4 and 5 Agricultural land only
Areas of Outstanding Natural Beauty
Nature conservation designations:
o Sites of Special Scientific Interest (SSSIs), Special Protection Areas (SPAs), Special
Areas of Conservation (SACs), Ramsar Sites, National Nature Reserves (NNRs),
Local Nature Reserves (LNRs)
Sites of Historic Interest:
o World Heritage Sites, Scheduled Ancient Monuments, Registered Parks and
Gardens
Common Land
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5m Buffer Zones around rights of way
Figure 4 shows the mapped outcome of this analysis for the Newport area and has been annotated to
show the approximate location of the application site. The areas shown in yellow are those which are
considered to possess technical potential for ground-mounted PV based upon the GIS analysis of the
abovementioned ‘constraints’.
Figure 4 Ground-mounted solar PV constraints and technical potential - Verco Renewable and Low Carbon Energy Assessment
It is important to note that the mapped constraints present only a basic and high-level representation
of the areas which are least constrained by the above designations. Indeed, the study itself
acknowledges that only a small proportion of the total available land would actually be suitable.
Therefore, it assumes that only 1% of the unconstrained land could be used for the deployment of solar
PV. It is then explained that although this is a somewhat arbitrary figure, it is deemed to reflect the
various other constraints, which will further influence the potential of the land. These include the fact
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that solar farms will have to compete with other land uses, need an economic grid connection and will
require unshaded flat land or land inclined to the south.
5.0 Relevant Statutory Designations
5.1 Overview
The site lies within an area that is subject to the following designations, which are explained in more
detail below:
1) Across two Sites of Special Scientific Interest (SSSI)
2) Within the Gwent Levels Historic Landscape of Outstanding Historic Interest in
Wales.
It also lies in close proximity to the Severn Estuary area which is subject to designation as a Special
Protection Area (SPA), a Special Area of Conservation (SAC) and a Ramsar site.
5.2 SSSI Designations
The site is subject to two Sites of Special Scientific Interest (SSSI) designations. The western area of
the site lies within the Nash and Goldcliff SSSI whilst the eastern area is located within the Whitson
SSSI. The boundaries for each of these areas are shown below in Figure 5 and Figure 6.
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Figure 5 Map showing boundary of Nash and Goldcliff SSSI
Figure 6 Map showing boundary of Whitson SSSI
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The Countryside Council for Wales (CCW) have released guidance to explain the special features of
these SSSIs set out in documents titled ‘Your Special Site and its Future’. Within these documents both
the Whitson and the Nash and Goldcliff SSSIs are notified for the having three features of special
interest as follows:
Reen and ditch habitat
Insects and other invertebrates
Shrill Carder Bee
In addition to these features, both SSSIs are noted to comprise other habitats that contribute to the
special wildlife interest in the areas. These include green lanes, hedgerows and flower rich ditch banks
which are important for a wide range of species. The CCW guidance explains that the management of
these sites should aim to look after these habitats as well as the listed features of interest.
It is explained within each of the related guidance documents that CCW are working with the Council,
developers, owners and other relevant bodies “to ensure that where development does take place the
special interests of the SSSI are conserved and enhanced”.
Paragraph 3.24 of the supporting text to Local Plan Policy GP5 (General Development Principles –
Nature Conservation) explains that SSSI sites “will require the fullest regard to the intrinsic value of
the site and their nature conservation value. Development with the potential to affect a recognised
site will be closely scrutinised for any direct or indirect effects. The developer must demonstrate the
case for development and why it could not be located on a site of less significance for nature
conservation”.
5.3 Gwent Levels Historic Landscape In Wales
The site area also lies within the Gwent Levels Historic Landscape Area as shown on Figure 7 as
designated under the Register of Landscapes, Parks and Gardens of Outstanding Historic Interest in
Wales.
The area comprises discrete and extensive areas of alluvial wetlands and intertidal mudflats and
represent a 'hand-crafted' landscape having been recurrently inundated and reclaimed from the sea
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since the Roman period. The areas have distinctive patterns of settlement, enclosure and drainage
systems belonging to successive periods of use.
This Area is further broken down into 21 ‘character areas’ which reflect the locally distinctive features
within the area as shown on Figure 7.
Figure 7 Gwent Levels Historic Landscape Area
The application site stretches across the ‘Nash and Goldcliff’, ‘Christchurch/Nash/Whitson Back-Fen’,
‘Porton’ and ‘Whitson’ Character areas. These areas are described within the Historic Landscape
Character record and are briefly characterised as follows:
Nash and Goldcliff: Complex "irregular landscape" in higher coastal area, with small irregular fields,
sinuous lanes and dispersed settlement.
Christchurch/Nash/Whitson Back-Fen: low-lying back-fen with simpler "intermediate" landscape
Porton: Unusual "intermediate" type landscape by the coast.
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Whitson: Unique, planned village.
5.4 Severn Estuary Designations
The application site lies to the north of the Severn Estuary which is widely recognised for its
environmental importance as reflected by its International designation as an SPA, SAC and a Ramsar
site. The site does not fall within the boundaries of these designations, but given their significance
and their proximity to the site, it has been important to consider the potential impact of the proposals
in this regard.
Resulting from its designation as an SPA and an SAC, the area is also defined as a European Marine
Site (EMS) in accordance with the Conservation of Habitats and Species Regulations 2010. A
‘European Marine Site’ is not itself a statutory site designation but is essentially a management unit
for those parts of Natura 2000 sites in the UK which extend beyond the Site of Special Scientific
Interest (SSSI) /Area of Special Scientific Interest (ASSI) designations.
The Severn Estuary Special Protection Area (SPA) and Ramsar site designations refer to the same
habitat types and therefore share the same boundary as shown on Figure 8. The Severn Estuary
Special Area of Conservation (SAC) captures a wider assemblage of species and habitats and covers
the whole Severn Estuary area as shown on Figure 9.
Its designation as an SPA is facilitated through legislation set out within the European Commission’s
‘Birds Directive’ (2009/147/EC). The ‘qualifying interest features’ are detailed within the ‘Regulation
33 Advice’ published by CCW and Natural England in 2009. These are noted to comprise a range of
bird species within three ‘supporting habitats’; Intertidal mudflats and sandflats, Saltmarsh and hard
substrate habitats.
The SAC is designated on the basis that it supports occurrences of habitat types and species listed
in Annexes I and II respectively of the Habitats Directive. These include an overarching “estuaries”
feature within which subtidal sandbanks, intertidal mudflats and sandflats, Atlantic salt meadows and
reefs and three species of migratory fish are defined as both features in their own right and as sub-
features of the estuary feature.
The qualifying interest features of the Severn Estuary Ramsar Site overlap with those of the Severn
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Estuary SPA and the SAC in order to facilitate the development of integrated objectives across the
designations. Ramsar sites are, as a matter of policy, subject to the same legal protection as
European designated nature conservation sites, but without recourse to the EU courts.
In terms of the development plan policies that relate to these designations it is necessary to refer to
Local Plan Policy GP5 (General Development Principles – Natural Environment), which is cited in
Paragraph 4.7.24 of this report.
Paragraph 3.23 of the supporting text to this policy states that “Nature conservation sites designated,
or proposed to be designated, under European or international legislation are subject to the highest
level of protection and therefore require rigorous examination”. It is further stated that “where
proposals have the potential to impact upon a European protected designation, the competent
Authority will be required to undertake a Habitat Regulations Assessment”.
Figure 8 Map showing location of Severn Estuary Special Protection Area
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Figure 9 Severn Estuary Special Area of Conservation (SAC)
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6.0 Principle of Development
6.1 Overview
Local Planning Authorities (LPAs) are not required to allocate land for renewable energy development.
Following the methodology outlined in the Welsh Government’s Planning for Renewable and Low
Carbon Energy Toolkit, NCC have completed an exercise of constraints mapping for ground mounted
Solar PV. This identifies areas which are unconstrained by land based designations but does not
allocate sites for solar farm development.
A rural location is a suitable location for a solar farm scheme as a large area of land is required to
accommodate the development. There is no policy requirement for the scheme to be located within or
adjoining an existing settlement. Moreover, a location within or near to a settlement is not required on
the usual grounds of sustainability because the proposals attract only a low level number of traffic
movements per year. The proposed development does not therefore require a site within close
proximity to local services and is highly sustainable despite being located in open countryside.
The panels are extremely low maintenance; the grass underneath could be grazed by livestock and the
panels cleaned down annually. The panels would be monitored remotely via a CCTV link.
The development is entirely in line with planning policy at the local and national levels
The key attributes of the proposed development are as follows:
The proposals seek to provide green energy for over 15,000 homes and save over 21,000
tonnes of CO2 per annum.
Solar PV arrays have a low profile, no moving parts, and do not generate noise;
The site has been assessed by professional consultants to ensure there are no significant
adverse impacts upon landscape or visual amenity.
The development will bring about significant biodiversity enhancements to benefit the special
qualities of the two SSSIs in which the site is located
The land will maintain its agricultural function through the grazing of sheep
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Once operational, it will require only Infrequent vehicle maintenance visits
The incorporation of an integrated battery storage area will allow for the optimum use of the
renewable energy to match peak levels of demand
Contributes to the UK and Wales’ renewable energy and carbon reduction objectives.
The development will place no additional pressure on local infrastructure such as roads or the
drainage network
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7.0 Assessment of proposals against planning policy
7.1 Ecology and Biodiversity
The site lies within two SSSIs and as such great care has been taken to ensure that the special qualities
of these areas would be preserved and, where possible enhanced through the proposed development.
A full suite of ecology surveys have been completed and the associated reporting is detailed within the
accompanying Environmental Statement and standalone reports. This reporting has assessed the
impact of the proposed development upon the range of habitats and species identified within the area.
Specific attention has been paid to the assemblage of species for which the two SSSI sites are
designated.
In accordance with pre-application guidance received from Natural Resources Wales (NRW) the
scheme proposes to observe the appropriate buffer zones around the reen habitats on the site. These
are; 12.5m from all reens and 7ms from field ditches. Within these areas it is proposed that the growth
of vegetation will be carefully managed in order to facilitate increased biodiversity and an enhancement
in the ecological value of the entwined reen and grassland habitats.
Around each of the six larger site ‘parcels’ a stock proof fence would be installed at the edge of these
buffer zones to protect the areas from grazing livestock. The fence would allow for the passage of small
mammals through and under it and would not limit affect overland flow of water during heavy rainfall or
flood events.
Existing hedgerows will all be retained and two distinct sections of additional planting is proposed (along
Chapel Road and around battery storage units). This responds to pre-application consultation with the
Gwent Wildlife Trust which revealed an important local perspective on the site in this regard. Through
this consultation it was explained that hedgerow planting in this area actually has the potential to disrupt
the aquatic reen habitats and to affect the drainage of water through this complex system. Such planting
is typically required as a means of mitigating against visual impact. However, due to the setting and
topography of the site, only minimal planting is required for this purpose and therefore any potential
impacts on this system will be negligible.
During the construction phase, a strategy for the installation of the panels and associated infrastructure
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will ensure minimal disruption to ecology. Detailed drawings have been submitted, which show how
underground cabling will be bored below ditches/reens in order to entirely avoid any contact with this
environment.
A construction traffic management plan (CTMP) has been prepared which demonstrates how the
panels and equipment will be delivered to the site. The site will be accessed from four main points and
where required, panels will be decanted into smaller vehicles in order to allow the installation to proceed
without the need for extensive roads or tracks to be laid. A relatively small track will need to be laid to
allow access to the gridyard.
Once operational the proposed development will not create any adverse environmental impacts. The
panels themselves are non-moving, inert and produce virtually no noise or emissions.
The proposals will not therefore result in any significant harm to ecology and will actually result in a net
benefit, which is compliant with all levels of planning policy.
7.2 Heritage
A thorough assessment of the impact of the scheme on the historic environment has been undertaken
by Savills’ Heritage team in support of this application. This identifies and evaluates heritage assets
within the Application site and surrounding study area, and assesses how the Scheme might affect
these heritage assets. Details relating to this assessment’s methodology and findings can be found in
the accompanying Environmental Statement.
Using the professional judgement of the Heritage Consultant and the thorough application of the
archaeological assessment and ASIDOHL2 process it has been concluded that whilst there will be
some unavoidable short-term moderate to minor adverse effects during the construction phase of the
project (largely from noise and increased traffic movements, and potential impacts to buried
archaeological deposits), overall the project during its operational phase will have a minor adverse to
negligible effect on the value, coherence, legibility and significance of the historic landscape. The
preservation by record of any archaeological deposits impacted by the Scheme will mitigate any
impacts to the archaeological resource where discovered. If no archaeological remains are present
then the residual effect of the Scheme will be None.
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7.3 Landscape and Visual Impact
The site lies on the Gwent Levels and within the Caldicot Levels Special Landscape Area as designated
under the Newport Local Development Plan. Policy CE10 [Renewable Energy] of the plan sets out the
relevant policy tests against which proposals for renewable energy schemes in these areas must be
assessed. Paragraph 4.51 of the supporting text to this policy explains that:
“Proposals which affect the special qualities of the Gwent Levels, or any other protected site, will be
resisted unless it can be demonstrated that there will be no significant adverse effects.”
The site lies approximately at sea level, is extremely flat and is not overlooked by rising topography
in the immediate vicinity. In England, the siting of large-scale solar farms is addressed within the
National Planning Practice Guidance (NPPG). This guidance favours flat sites over ‘undulating
landscapes’ due to the lower level of visual impact that arises in such locations (Paragraph: 013
Reference ID: 5-013-20150327).
Furthermore, the existing trees, hedge lines and vegetation will provide a significant degree of
screening to the installed panels and associated infrastructure. In light of the topography of the site
and the surrounding area, the visual impact of the proposed development is limited.
A Landscape and Visual Impact Assessment (LVIA) has been prepared and accompanies the
submission of this application. This has identified and assessed the likely effects on the landscape of
the proposed development. Overall, this report has concluded that:
“The proposed development would not have any major adverse effects on either landscape character,
or visual receptors“
More specifically, the impact of the proposals are assessed to reduce with increased proximity from the
site as follows:
The development would result in a moderate adverse impact on the immediate rural character
of the site context
Between approximately 100-500m away there will be reduced impact to minor adverse as the
changes are restricted by the flat landscape, and the well vegetated nature of the reens
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surrounding the site boundaries
In the wider landscape the change would be negligible as views of any part of the development
are limited or obscured from more than 500m away.
The development of the site is considered to have a negligible impact on the landscape setting of the
Landscape of Outstanding Historic Interest and the corresponding Special Landscape Area as the
development is not a widely perceptible element from within the wider landscape. Impacts on listed
buildings and scheduled monuments are considered to be negligible-none.
The conclusions of this report demonstrate that if the proposed development is implemented there will
be no significant adverse effects upon the special qualities of the Gwent Levels area. It follows that the
proposals satisfy the requirements of Policy CE10 and are acceptable in planning terms.
7.4 Impact on Agricultural Land
At a national level, DECC have prepared a specific Solar PV Strategy Roadmap, which sets out 10
industry best practice guidelines to ensure the quality of solar farms built and managed in the UK. The
first of these guidelines states that developers should:
“Focus on non-agricultural land or land which is of lower agricultural quality”. It is further explained
within the supporting notes to these guidelines that ground-mounted solar schemes should:
“Ideally utilise previously developed land, brownfield, contaminated land, industrial land and preferably
agricultural land of classification 3a, 3b, 4, and 5 (in most instances avoiding use of the ‘Best and Most
Versatile’ cropland where possible).
This preference for utilizing low quality agricultural land is echoed within Planning Policy Wales under
Paragraph 4.10. where it is stated that best and most versatile land should be “conserved as a finite
resource for the future”.
A detailed survey of the site’s agricultural land classification has been undertaken by a qualified rural
surveyor. Through completed his assessment, the surveyor was of the considered opinion that “the
land is classified as grade 3b to 4 on the Agricultural Land Classification Map of England and Wales
and as such is not considered to be “best and most versatile” agricultural land.“
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In this respect, the proposals comply with national level planning policy and best-practice guidance.
7.5 Flood risk and hydrology
Technical Advice Note 15 (TAN 15) provides the relevant guidance on flood risk in relation to these
proposals. The site is located within Flood Zone C1 In accordance with the categories set out within
this document. This means that it sits within an area of the floodplain which is developed and served
by significant infrastructure, including flood defences. This designation is used to indicate that
development can take place subject to the application of a justification test, including acceptability of
consequences.
To this end a Flood Consequences Assessment (FCA) has been prepared which considers the impact
of the proposed development on hydrology in the area. The document also details the specific
mitigation measures which would be incorporated in association with the built infrastructure including
solar panels, battery storage units and ancillary equipment.
With regards to the installation of the solar panels (which make up the bulk of the proposed
development), these will be individually spaced to allow thermal expansion and more even dispersal of
rainwater.
The report identifies specific changes brought about through the proposals which will affect surface
water drainage. These include:
Change in agricultural use of the land:
o Reduced grazing intensity
o Reduced use of machinery on the land
o No harvesting, or seeding of new crop
Longer grass and increased biodiversity in vegetation on site, particularly in buffer zone areas
adjacent to reens and ditches
The consequences of these changes have been assessed within the report and the following
conclusions have been drawn:
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Soil compaction will be reduced resulting in an overall improvement in the soil condition and
reduced surface water runoff
Increased capacity for surface water attenuation
The fields will be better able to naturally manage rainfall
Consequently the report has concluded that the proposed development will bring “significant betterment
in terms of improved infiltration reduced flood risk off-site and improved water quality, and is therefore
in accordance with the guidance given in TAN 15”.
7.6 Traffic Management
Once operational, the solar farm would generate fewer traffic movements than agricultural traffic and
as such there are no impacts from traffic movements once the solar farm is built.
All development will require construction traffic and deliveries during the construction process. Solar
farm proposals have the benefit of being capable of being constructed very quickly compared, for
example with housing developments. The construction process in this case is likely to take around 3 –
4 months.
During this period, deliveries will be made and carefully managed. The accompanying Traffic
Management Plan explains that the construction traffic will be directed to three distinct areas (defined
as sites A, B and C under the CTMP), each having separate access routes. The routes to these areas
are displayed on Figure 10.
Traffic from the M4 will access Site A via Broad Street Common, Nash Road and the A48. Traffic to the
remaining two areas (Sites B and C) will be via North Row and the A4810, eventually connecting to the
M4. The panels themselves will be transferred to smaller vehicles within the indicative site yards shown
on the plan and will be distributed from these locations to each field via existing agricultural tracks within
the site.
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Figure 10 Proposed construction traffic access routes
These routes are preferred as road surveys demonstrate that the local carriageways are able to
accommodate the proposed construction traffic and minimise potential conflict between delivery
vehicles and other highway users.
Sufficient vehicular access arrangements are proposed and these are supported by swept path
analysis, which demonstrates that either a 16.5m max legal articulated vehicle, 10m rigid vehicle, or
7.5t box van can successfully access each area of the site. During the peak period of construction the
three development Areas could generate up to 20 HGV movements per day (in the worst case).
There are currently no inherent safety issues on the local highway network in the vicinity of the site and
the proposals would not impact on the existing highway safety.
A number of additional traffic management measures are proposed to reduce the impact of construction
traffic on the local highway network and minimise the impact on local residents. These measures are
detailed within the CTMP and would be agreed via an appropriate planning condition.
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7.7 Impact on Amenity and Rights of Way
The proposed development is located in excess of 130m from the nearest dwelling and importantly,
lies on flat land and is well screened by existing hedgerows and vegetation.
The site largely avoids public rights of way in the area as shown below in Figure 11. Where rights of
way do cross the site, these generally run along the edge of the panelled areas and would be retained
as part of the proposals. Access across the areas would therefore be unaffected and pedestrian links
between the villages of Whitson and Goldcliff would remain in place.
Figure 11 Public rights of way around the site
The Wales Coast Path runs along the coastal embankment to the south of the site. The accompanying
LVIA has assessed the impact of the proposals upon the users of this footpath. The assessment has
concluded that only a minor adverse impact would arise as a result of the development. This is because
the panels would largely be screened by the existing vegetation along the southern site boundary and
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would be set back at a distance of 1.0km from the path.
8.0 Sustainability Credentials
8.1 Introduction
Paragraph 4.2.2 of PPW explains that “The planning system provides for a presumption in favour of
sustainable development to ensure that social, economic and environmental issues are balanced and
integrated, at the same time”. This establishes that there are three strands to sustainable development
which are indivisible, and which are set out above; these are economic, social and environmental.
This vision for sustainable development is reflected in the Newport LDP which is the pertinent
development plan against which these proposals should be assessed. As such, proposals for
sustainable development should be determined in line with the presumption in favour of sustainable
development and the policies set out within the LDP.
This chapter will now demonstrate how the proposals amount to sustainable development in economic,
social and environmental terms.
8.2 Economic Sustainability
The site will be eligible to pay business rates to the Local Authority. Given the scale of the site, this will
provide a significant financial income for the Council, with income filtering down to local communities.
The proposal will still enable the site to be grazed, which will provide additional agricultural income for
the landowners and help to support the local rural economy.
The local parish will benefit directly by a community benefit package to be delivered through a legal
agreement and administrated by the Community Council. This will help to fund specific local projects.
The amount and the specific projects have yet to be agreed, but all parish councils in the local area
have expressed an interest in this proposal.
The community partnership will seek to obtain the planning consent. The site would then be built by a
specialist EPC (Engineer, Procure and Construct). It would then be operated by a specialist company
and the community partnership would receive a fixed ground rent for the 30 year term, to help subsidise
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their farming enterprises. The whole process is driven by the community group.
The EPC will look to use local contractors for the construction process wherever possible, as well as
local suppliers for key items such as aggregate, fencing and landscaping. The applicant would be willing
to enter into a Local Labour Agreement to secure benefits to local businesses.
The revenue generated for the community group will enable the local farmers to reinvest in their farms
and will result in increased spending in the local economy as well as the potential for longer term job
creation resulting from more locally successful farming enterprises subsidised by the solar farm income.
The proposal will ensure that the local farmers can secure their farms for future generations and guard
against going out of business, at a time where the single farm payment is being reduced, farmers are
reliant on subsidy to keep otherwise marginal farming operations viable and in an area where climate
change can pose a real threat, including in respect of flooding.
As set out above, the Best Practice Guidance for solar farms produced by BRE provides a number of
case studies which illustrate this point:
Eastacombe Farm, Holsworthy, Devon
“This farm has been in the Petherick family for four generations, but they were struggling to survive with
a small dairy herd. In 2011/12, a solar developer helped them convert eight hectares of the lower-grade
part of their land into a 3.6 megawatt solar farm with sheep grazing, which has diversified the business,
guaranteeing its future for the next generation of farmers.”
Newlands Farm, Axminster, Devon
“Devon sheep farmer Gilbert Churchill chose to supplement his agricultural enterprise by leasing 13
hectares of grazing land for a 4.2 megawatt solar PV development, which was completed in early 2013.
According to Mr Churchill, the additional income stream is “a lifeline” that “will safeguard the farm’s
survival for the future”.
As set out in the Solar Strategy Part II, the renewable energy sector is a major employer in the UK and
the proposal will contribute positively towards employment in this sector. Employment will include short
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term jobs for installation, longer term jobs for site maintenance and security and indirect (but
nevertheless important) jobs for the service and manufacturing industry which supports the growth of
the renewable energy sector. The table below sets out the range of jobs associated with the sector:
General Management, Sales Manufacturing and Design Installation and Maintenance and Admin
Design engineers, systems Planning and environmental Sales/purchase engineers, production consultants, electricians, administrators, sales and managers, production instrumentation engineers, business development teams, supervisors, electrical controls and electrical systems logistics – drivers, packers, engineers, laboratory technicians, installation warehouse staff, marketing technicians, quality assurance, engineers, installation teams. assembly line personnel, supervisors, scaffolders, chemists, surveyors, materials service engineers, panel scientists, warehousing/logistics cleaners, security. personnel.
Table 1: Summary of employment sectors supporting the solar industry
It is therefore evident that the proposal will play a major role in supporting economic development
through the creation of new jobs.
8.3 Social Sustainability
There is potential for engagement with local schools, educational establishments, and community
groups relating to both biodiversity enhancements and clean energy production & use. There is also
the opportunity to demonstrate the co-production of both energy and food in harmony.
The Department for Energy and Climate Change (DECC) has tracked public opinion on energy issues
in a quarterly ‘public attitudes tracking survey’ since 2012. This survey is now in its 17th iteration
(‘wave’) and the survey findings reveal that Support for renewable energy has remained consistently
high during the tracker at around 75-80%. The most recent survey has shown 81% expressing support
for the use of renewables, whilst Opposition to renewables was very low at 4%, with only 2% strongly
opposed.
Within the renewables sector, support for solar was particularly high, with 95% of respondents
expressing their support for solar energy development.
When respondents were asked if they would be happy to have a large scale renewable energy
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development in their area, 75% or respondents agreed that they would be happy.
This evidence demonstrates that there is strong public support for renewable energy and that solar
energy in particular is the most strongly supported.
The proposal will also help to reduce the UKs reliance on imported fossil fuels and help the UK gain
more control over its energy provision and therefore more control over future energy prices and more
energy security going forward. This is particularly important considering the projected sharp rise in
energy prices over the next 5 years.
8.4 Environmental Sustainability
The most significant benefit of the proposals is the contribution towards the national and European
renewable energy targets and helping to facilitate a transition to a low carbon economy.
The proposals will provide enough renewable ‘green’ energy to power around 15,000 homes and offset
over 21,000 tonnes of CO2 annually. This represents a significant contribution towards the fight against
climate change. The environmental benefit of the proposals are therefore of great significance.
The benefits of the proposals in this regard are set against the context that the UK is one of the poorest
deliverers of renewable energy in the EU and is on course to miss its delivery targets and face large
fines.
Within the UK Wales has consistently generated a lower proportion of its electricity from renewable
sources than the UK average, as shown revealed by Figure 12, which shows the percentage of
electricity generated by renewable sources in each UK country. The chart shows that in 2013 Wales
generated the lowest percentage of electricity from renewable sources within the UK.
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Figure 12 Welsh Government Statistical Bulletin: Energy Consumption and Generation for Wales 2013.
Solar farms are a simple and proven technology providing a source of safe, locally produced renewable
energy for many years after construction, with no by-products that cannot simply be recycled.
The land used for this solar farm will create a place for nature and wildlife to thrive, protected from
human contact. The land around the panels will be grassland with hedging retained, enhanced and
managed and newly planted around the fence. These environments provide better habitats than
intensively farmed land and are akin to a nature reserve.
The ground beneath and around the panels will also be used to graze sheep and to grow grass and
wildflowers to encourage invertebrates including butterflies as demonstrated by Figure 13 Photograph
showing grassland and wildflowers beneath solar panels.
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Figure 13 Photograph showing grassland and wildflowers beneath solar panels
Resting the land from intensive grazing use for a period of 30 years will have significant benefits in
terms of allowing native grassland species to re-establish and for the land to restore fertility for future
farming use after the solar farm has been removed. The development will also mean the land is no
longer subjected to intensive use of pesticide or fertilizer, to the benefit of local soil and fluvial
environments which can lead to utrification of watercourses.
Intensive grazing by cattle and intensive arable use tends to result in compacted soil and much more
bare soil more of the time. This accelerates run off to watercourses. The solar farm will allow a rich mix
of plant and grassland species to become established which will help retain water and slow run off
rates, to the benefit of the area in respect of flood risk. The proposal will also provide new biodiverse
areas around the edges of the reens and ditches, which will encourage local biodiversity to thrive.
The potential ecological impacts of the proposed scheme have been comprehensively assessed
through a suite detailed surveying and reporting which can be viewed within the accompanying
Environmental Impact Assessment. This reporting has concluded that “the low ecological value of the
affected area in combination with the proposed ecological enhancements, such as the creation of
planted biodiversity areas and species rich grassland areas, means that the scheme has potential to
have a net benefit to biodiversity during the operational phase”.
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The reporting also demonstrates that the special qualities of the two SSSI sites (in which the site is
located) would be preserved and where possible enhanced through the implementation of the scheme.
The proposals are fully reversible and temporary for a period of 30 years. There would therefore be no
long term impacts from the development. The land can be quickly restored back to its former use.
9.0 Conclusions
9.1 Summary
This Statement supports a planning application made under the Developments of National Significance
regime for a solar energy hub and associated infrastructure on land on the Gwent Levels in south
Wales. The site extends to circa 345 acres of grade 3b and 4 agricultural land and the development
will produce around 49MW of renewable electricity.
The proposal is sustainable in terms of the environmental, economic and social strands of sustainability
set out in Planning Policy Wales.
It is demonstrated that the proposals wholly comply with planning policies at national and local levels.
The proposals bring about numerous and significant environmental, economic and social benefits
without giving rise to any unacceptable harm. Accordingly, the proposals should be fully supported.
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Savills (UK) Ltd York House, Blackbrook Business Park, Taunton, TA1 2PX t 01823 445030 f 01823 445031 e [email protected] www.savills.co.uk