ALL-OHL-POE-03

The Mid Wales (Powys) Conjoined Public Inquiry into 5 Windfarm Proposals and a 132kV overhead Electric Line Connection

Session Three Alliance Proof of Evidence Brett Kibble CEng MIMechE BSc(Hons)

Cultural Heritage

Alliance Session 3 Proof of Evidence - Cultural Heritage

Introduction

1. The Alliance judges that the proposed line will have a profound effect upon the historic landscapes through which it passes that are of acknowledged outstanding importance. It will further significantly affect the setting of, and views from, a large number of nationally designated sites, buildings and historic parks and gardens. For these reasons alone it should not be granted permission.

CONTEXT

Landmap Historic Landscape Aspect

2. As acknowledged in the SP Manweb updated ES 1, the Landmap Historic Landscape Aspect is particularly relevant to cultural heritage, though the Cultural Landscape Aspect does create some overlap in relation to the historic landscape. The importance of using Landmap is spelt out in Welsh Planning Policy PPW 5.

3. The proposed line passes predominantly through seven Historic Landscape Aspects each one of which is rated as High or Outstanding. From Welshpool to Bryn Dadlau these are:

a) Lower Severn Valley MNTGMHL 441 (Welshpool substation to near Cilcewdd). This area is rated as OUTSTANDING on overall, survival, rarity, and potential criteria.

The Landmap justification for this overall evaluation cites: ‘Regularly enclosed floor of Severn valley. Ostensibly a post-medieval and medieval farming landscape but also contains nationally important earlier prehistoric ritual complexes, a Roman fort and military settlement, Offa’s Dyke and Cistercian Abbey, as well as numerous lesser archaeological sites all of which contribute to its high scores.’

1 SP Manweb Updated Environmental Statement (UES) Oct 2013 Volume 1 para 8.4.42 1 Alliance Session 3 Proof of Evidence - Cultural Heritage

b) Forden / Trelystan MNTGMHL 514 (Cilcewdd to Woodlands). This area is rated as HIGH for overall, integrity, survival, condition and potential criteria.

The Landmap justification for overall evaluation cites: ‘Gently undulating land above the eastern side of the Severn valley, characterised by irregular fields surrounding high status medieval and later farms and houses, minor medieval (and later) settlements, and overlying later prehistoric defended enclosures and the course of Offa’s Dyke. Complex Landscape. c) Salt Bridge MNTGMHL 980 (Woodlands to near Caerhowel). This area is rated as HIGH overall but has OUTSTANDING survival, rarity, and potential criteria.

The Landmap justification for overall evaluation cites: ‘Area of regular fields occupying gently sloping grounds to the north and west of Montgomery. Contains important motte & bailey castle at Hen Domen and surviving elements of Saxon & medieval field systems as well (as) most of the site of the Civil War battle of 1644. A complex multi- period context contributes to its score.’ d) Ffrydd Faldwyn MNTGMHL 541 (near Caerhowel to Goron-ddu). This area is rated as HIGH on overall, integrity, survival and potential criteria.

The Landmap justification for overall evaluation cites: ‘Irregular fieldscapes occupying rising shoulder of east facing land above Montgomery. Post medieval and earlier agriculture predominates but also contains a single hillfort and a large number of smaller later prehistoric defended enclosures, which help to raise its score. e) Cefn-y-Coed MNTGMHL 617 (Caerhowel to Upper Maenllwyd). This area is rated as OUTSTANDING for overall, survival, rarity, and potential criteria.

The Landmap justification for overall evaluation cites ‘Dominated by medieval and later agriculture with high (and lower) status farms and

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houses, and medieval settlement foci, but also a large number of later prehistoric defended settlements which significantly increase its scores.’

f) Upper Mule MNTGMHL 630 (Upper Maenllwyd to near Kerry Hill). This area is rated as OUTSTANDING for overall, rarity and potential criteria.

The Landmap justification for overall evaluation cites ‘Dominated by medieval and later agriculture with high status farms and houses and minor settlements, but also a large numbers of earlier prehistoric burial monuments and later prehistoric defended settlements (hillforts and enclosures), and medieval defensive works. Of exceptional interest.’ (our emphasis)

g) Kerry Hills MNTGMHL 124 (near Kerry Hill to near Bryn Dadlau). This area is rated as OUTSTANDING for overall, rarity and potential criteria.

The Landmap justification for overall evaluation cites ‘A prehistoric landscape of key importance containing significant numbers of burial monuments and ritual sites with domestic activity being indicated by a large number of prehistoric finds. Overlain by medieval and later farming evidence and with significant early medieval influence.’

4. A map illustrating the preponderance of OUTSTANDING evaluations and showing that some 70% of the proposed line traverses such areas, is available.2 27% of the line is in areas evaluated as HIGH.

Registered Historic Landscape

5. The Vale of Montgomery Registered Historic Landscape (VMRHL) is listed as OUTSTANDING in the Register of Landscapes of Historic Interest in Wales. The proposed line passes for approximately 6.5 km 3 through the VMRHL. The ASIDOHL undertaken by SP Manweb shows that, although its effect would be moderate over the VMRHL as a whole, locally it would be severe.4 The VMRHL in the area where the line passes through corresponds very closely with the Landmap Cultural Aspect area of the Vale of Montgomery.

2 SP Manweb UES Oct 2013 Volume 3a Appendix 06a Fig 20 3 SP Manweb UES Oct 2013 Chapter 8 page 19 para 8.4.37 4 SP Manweb UES Oct 2013 Chapter 8 page 46 para 8.8.4 3 Alliance Session 3 Proof of Evidence - Cultural Heritage

This is ranked as OUTSTANDING particularly for the evidence of the Vale having been the centre of conflict and military struggle. The group value is cited as OUTSTANDING because: ‘The range of defensive/aggressive works present in the landscape span several millennia, thus contributing to this evaluation of group value.’ It also says this is of National recognition. We demonstrate below that the proposed line passes through, and visually ‘splits’, a particularly sensitive part of the VMRHL.

6. It is noteworthy that the part of the VMRHL that is relevant to the Llandinam Line is almost coterminous with these two Landmap Historic Aspect areas of Forden / Trelystan and Saltbridge which are rated as High. This demonstrates that the High Landmap rating must be of considerable value and therefore the Outstanding areas that the rest of the line passes through must be of at least comparable value to the Registered Historic Landscape.

7. Thus, as measured against two officially accepted criteria for historical relevance, the line would be almost entirely located in landscapes rated as OUTSTANDING. Again the Alliance judges that this demonstrates the unsuitability of the proposed route.

ANALYSIS

Effect upon designated cultural heritage assets

8. As the UES points out the proposed line produces Significant visual effects upon 28 SAMs, 35 Listed Buildings, 1 Registered Park and Garden and 3 Conservation Areas 5 as well as upon the Vale of Montgomery Registered Historic Landscape. It is important to note that this analysis only includes a ‘representative sample’ 6 of grade II listed buildings in the study area although they are to be accorded as high a value as grade I and II* rated properties.

9. To avoid merely producing a long list of reasons why the Alliance believes that the effect upon all these assets is too great, we can illustrate this more succinctly by considering four particular groupings of assets.

5 SP Manweb UES 2013 Chapter 8 page 37 table 8.15 6 SP Manweb UES 2013 Chapter 8 page 4 para 8.3.19 4 Alliance Session 3 Proof of Evidence - Cultural Heritage

10. Leighton Hall and Park area

a) The map in the UES showing designated assets within 2km of the proposed overhead line 7 illustrates the Leighton Registered Historic Park and Garden 8 in a light pink colour about 1km south of the Welshpool Grid Substation.

b) This Historic Park and Garden is rated as Grade I on the CADW Register i.e. the highest category. The overhead line would approach within 300 m of the Park.9

c) Leighton Hall is itself Grade I listed 10 and its tower is separately listed as a Grade I building 11. There are three bridges in the garden listed as grade II* 12. This cluster can be seen on the map 13 in the western part of the Registered Park and Garden. It is also recognised as the Leighton Park Conservation Area.

d) An extremely important model farm was constructed at Leighton Hall in the second half of the 19th century and this is recognised by the 16 buildings each being listed as Grade II* 14 with the whole complex being the Leighton Centre Conservation Area.15 The cluster of buildings can be seen on the map16 near the northern end of the Registered Park and Garden.

e) Also linked as part of the broader landscape with respect to the Hall is Holy Trinity Church at Leighton (grade II*) 17 with its particularly prominent tall spire acting as an ‘indicator’ of the position of the complex.

7 SP Manweb UES 2013 Volume 6 page 29 Fig 8.2 8 PGW (Po) 34 9 SP Manweb UES 2013 Volume 1 Chapter 8 page 32 para 8.5.100 10 LB 8663. SP Manweb UES 2013 Volume 1 Chapter 8 page 30 para 8.5.73 11 LB 19523. SP Manweb UES 2013 Volume 1 Chapter 8 page 30 para 8.5.73 12 LB 15627,15628,19531. SP Manweb UES 2013 Volume 1 Chapter 8 page 30 para 8.5.73 13 SP Manweb UES 2013 Volume 6 page 29 Fig 8.2 14 LB 8670-17, 19507-17, 19519 15 SP Manweb UES 2013 Volume 1 Chapter 8 page 30 para 8.5.76 16 SP Manweb UES 2013 Volume 6 page 29 Fig 8.2 17 LB 8668. SP Manweb UES 2013 Volume 1 Chapter 8 page 30 para 8.5.79 5 Alliance Session 3 Proof of Evidence - Cultural Heritage

f) As the map 18 shows, the Scheduled Ancient Monuments 19 of Offa’s Dyke are closely associated with this area and the proposed line comes to within 700 metres of the Dyke. The Dyke is considered by many professional archaeologists in Wales and the Borders to be an asset of international importance.20

g) The UES analyses the effect upon the setting and the views both to and from all the above extremely important heritage assets 21 and they are all deemed to experience significant effects. The Alliance believes this to be unacceptable.

11. Montgomery – River Severn military axis

a) As shown on the map 22 there is an important collection of heritage assets near the town of Montgomery and in the area north west of the town across to the river Severn. This comprises a continuum of heritage assets that provided defensive/aggressive capabilities and this is recognised in the Group Value of the Vale of Montgomery RHS (see above).

b) A multi-ramparted late Iron Age hillfort, Ffridd Faldwyn (with a possible much earlier Neolithic predecessor) 23 was established just to the west of the present town of Montgomery and is shown on the map as MG015. This position commands extensive views to the north east and north west where the line will be visible. It is a Scheduled Ancient Monument MG 015.

c) Forden Gaer Roman fort and vicus (Scheduled Ancient Monument MG012) 24 was an important and sizeable Roman establishment

18 SP Manweb UES 2013 Volume 6 page 29 Fig 8.2 19 MG 034, 035, 036, 037, 138, 139, 152, 153, 217, 224. SP Manweb UES 2013 Volume 1 Chapter 8 page 26 & 27, para 8.5.32 & 8.5.33 20 SP Manweb UES 2013 Volume 1 Chapter 8 page 13 para 8.4.35 21 SP Manweb UES 2013 Volume 1 Chapter 8 pages 26 - 32 22 SP Manweb UES 2013 Volume 6 page 29 Fig 8.2 23 SP Manweb UES 2013 Volume 1 Chapter 8 page 14 item MG015 24 SP Manweb UES 2013 Volume 1 Chapter 8 page 26 para 8.5.23 6 Alliance Session 3 Proof of Evidence - Cultural Heritage

adjacent to the Severn and is shown on the map as MG012. The line will be visible from the fort. d) Hen Domen is a mediaeval earthwork castle important because of its early Norman origins and subsequent extensive excavations making it one of the best understood sites of its type in the UK.25 This is designated MG 013 (SAM number) on the map. e) Hen Domen was positioned to guard a strategically highly important ford across the Severn at Rhydwhyman 0.6 kms north west of Hen Domen. The ford is described in the Historic Environment Register (under PRN 176): ‘From around 1258 to 1275 the ford was the most important ‘customary’ meeting place for representatives of the English crown, including the king and his son, with Llywelyn ap Gruffydd, prince of Gwynedd and later Wales. It is generally accepted that it was here in 1267 that the Treaty of Montgomery, which formally recognised Llywelyn ap Gruffydd as prince of Wales, was concluded and here where Llywelyn did homage for his principality and swore fealty to Henry.’ The location is thus extremely important in its own right as regards Welsh and English history and its relationship to its ‘guarding’ fort of Hen Domen is special. The Historic Landscape Characterisation (HLCA 1070) carried out by CPAT states: ‘The castle at Hen Domen became important by guarding the ford across the River Severn at Rhydwhyman by acting as a means of controlling the areas which had been deserted due to Welsh incursions before the Norman conquest’ f) The proposed overhead line slices through the intervening land between these two importantly linked sites. Even the UES considers the effect upon Hen Domen from the west as significant and of large/very large scale.26

25 SP Manweb UES 2013 Volume 1 Chapter 8 page 14 item MG013 26 SP Manweb UES 2013 Volume 1 Chapter 8 page 26 para 8.5.24 7 Alliance Session 3 Proof of Evidence - Cultural Heritage

g) Rhydwhyman Crossing Cottage (map ref 87275) 27, a listed building near the ford juxtaposed between these two sites, also suffers from a significant effect of large/very large scale.

h) The fort at Hen Domen was replaced by a stone built castle at Montgomery in the 13th century commanding sweeping views across the Camlad plain. Although the effect of the overhead line upon this heritage asset (SAM MG 022) is not so severe as for some others the Alliance will present visuals at the Inquiry that show, considering how important those views are, that there is still a significant effect.

i) This military complex spans Neolithic, Iron Age, Roman, Norman and Medieval times, is highly significant in Welsh and English history and inextricably linked to the River Severn, and should not be so significantly affected regarding settings and views in and out by an aesthetically challenging overhead transmission line. The UES acknowledges that for Forden Gaer, Hen Domen, and Ffridd Faldwyn the level of significance will be large/very large and for Montgomery Castle we would argue that it is significant. This whole area is obviously one of the most important parts of the Registered Historic Landscape and must not be treated with disdain.

12. Caerhowel to Kerry Hill Domestic focus

a) This area comprises the Cefn Coed and Upper Mule Landmap Historic Aspect areas which are both rated as OUTSTANDING. The Landmap descriptions above show that they are important for the continuum of settlement from prehistoric to recent times. The proposed overhead line will have a considerable effect upon the aspect of these areas as both are virtually free of structures of this scale. Presently the heritage assets sit comfortably in their lovely hills and valleys. Significantly affected assets journeying along the proposed line (see map 28) from Caerhowel to Kerry Hill would be:

27 SP Manweb UES 2013 Volume 1 Chapter 8 page 32 para 8.5.98 28 SP Manweb UES 2013 Volume 6 Figure 8.2 pages 29 & 30 8 Alliance Session 3 Proof of Evidence - Cultural Heritage

Listed Level of SAM UES ref Heritage Asset Visual Effect Building Significance 7989 & 8.5.85 Caerhowel 7991 Farmhouse & Moderate Moderate / Large Barns 7999 8.5.87 Caerhowel Smithy Large / Very Major Large 7993 8.5.86 Court Calmore Major Moderate / Large MG 220 8.5.57 Henfron Moated Large / Very Major Site Large 7716, 8522 8.5.84 Llwynmadoc & 18523 Farmhouse & Moderate Moderate / Large Barns 1822 29 8.5.108 Cuckoo Hall Large / Very Major Hillfort Large 17304 8.5.91 Upper Maenllwyd Large / Very Major Large MG 169 8.5.53 Great Cloddiau Large / Very Major Camp Large MG 172 8.5.54 Glanmule hengiform Moderate Moderate / Large monument 17296 8.5.90 Smithy at Moderate / Moderate / Large Glanmule Major 17314 to 8.5.93 Springfield 17319 Sawmill Moderate Moderate / Large Conservation Area 17306/7/8 8.5.92 Cilthriew & Large / Very Major Outbuildings Large

Note: SP Manweb have only used a representative sample of Grade II listed properties and therefore there may be others that would be affected.

29 Possible SAM 9 Alliance Session 3 Proof of Evidence - Cultural Heritage

b) A very important property that the Alliance believes may not be being fully considered in the analysis is Cefn Bryntalch Hall (grade II*) 30 and its Registered Historic Park and Garden.31 The entry in paragraph 8.5.99 considers the visual effect as minor but the Viewpoint shown as 036 in volume 4 of the UES shows that there could be an effect greater than this. The Hall and grounds should be protected visually being very significant as one of the earliest Queen Anne revival houses (architects Bodley and Webb). It was formerly the home of the composer known as Peter Warlock and where he wrote his famous song cycle ‘The Curlew’. The listing states Cefn Bryntalch is exceptionally important ‘… regarded as one of the seminal smaller houses of the late nineteenth century contributing to the Queen Anne revival of 1870s and 1880s’.

c) It is clear that the proposed line will have a seriously deleterious effect and prejudice the interpretation of heritage assets that are fully representative of the reasons why the two Landmap Historic Aspect areas are cited as OUTSTANDING. The Alliance again judges this is of sufficient magnitude to warrant refusal.

13. Kerry Hills Prehistoric Landscape

a) As the description given of the Kerry Hills Historic Aspect area illustrates, the area from ‘Kerry Hill’ almost to Bryn Dadlau is recognised as a ‘prehistoric landscape’. Many SAMs are present and expert opinion considers intervisibility between some of the barrows, stone circles and other funerary relics was important for ritual reasons. The bare landforms in this area assist in appreciation of interlinking but equally ensure that the proposed line would have a major effect on settings and views to and from these nationally important SAMs.

b) According to the UES there are nine SAMs that are significantly affected. Four of these (MG062, MG063, MG257, MG280) have a significance of large/very large and five (MG048, MG109, RD250, MG121, MG122) a significance of moderate/large.

30 LB 7714. SP Manweb UES 2013 Voumel 1 Chapter 8 page29 para 8.5.69 31 PGW(Po)29. SP Manweb UES 2013 Volume 1 Chapter 8 page 32 para 8.5.99 10 Alliance Session 3 Proof of Evidence - Cultural Heritage

c) The proposed repowered Llandinam windfarm itself also has a profound effect upon the prehistoric landscape as its site encompasses five SAMs each one being of prehistoric date 32and the site hosts a total of 22 known prehistoric data points.33

d) In the ES 34 it also says that ‘This entire uplands landscape may be characterised as being prehistoric in nature.’

e) Although the Alliance judges that the line itself has too significant an effect upon the prehistoric landscape by itself it is obvious that the line and windfarm together produce a profound effect upon the larger prehistoric landscape.

f) The Kerry Ridgeway is reputed to be the oldest road in Wales and likely to be, according to the official board at the Cider House car park, of Iron Age era. It would have its setting seriously affected by the proposed overhead line. Although SP Manweb are at pains to point out that the visibility of the line at the Two Tumps (MG048) and adjacent Kerry Ridgeway would be minor it is important to realise that when approaching along the Kerry Ridgeway path from either west or east, the overhead line would be very prominent in the bare landscape.

g) Yet again we have another OUTSTANDING historic landscape that will be seriously affected by the line. In the Alliance’s judgement this is further grounds for refusal. Conclusion

14. The proposed line is positioned almost entirely in landscapes officially recognised as having historic aspects of OUTSTANDING quality.

15. The line has significant, in many cases a very high level, of effect upon heritage assets spanning many eras.

32 Llandinam Windfarm Repowering and Extension ES 2008 Volume 1 Chapter 10 page 6 para 10.4.4.1 Item 2 33 Llandinam Windfarm Repowering and Extension ES 2008 Volume 1 Chapter 10 page 6 para 10.4.4.1 Item1 34 Llandinam Windfarm Repowering and Extension ES May 2008 Volume 1 Chapter 10 page 11 para 10.5.1 item 4 11 Alliance Session 3 Proof of Evidence - Cultural Heritage

16. As illustrated through analysing just four of the groupings it is difficult to conceive how an overhead line which is a direct result of the Llandinam windfarm could be located more disastrously for cutting a swathe through such an OUTSTANDING historic canvas.

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CV of Brett Kibble

Brett Kibble CEng MIMechE BSc(Hons) is a Chartered Engineer and Member of the Institute of Mechanical Engineers and worked for many years as a Technical Director in the rail industry. He sat on the Board of a large rail franchise and managed the entire maintenance organisation for a fleet of 400 railway vehicles.

After retirement, his home for 12 years has been in Mid Wales and he walks and cycles extensively throughout the area.

As a volunteer he is an active member of Sustrans. Nationally, he sits on the organisation’s Advisory Board. Locally he co-ordinates volunteers and has been instrumental in establishing a cycleway along the Montgomery Canal that is a much used facility for the communities and visitors alike.

Amongst local interests he is a member of the Kerry Local History Society and the Newtown 2020 Sustainability Group.

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