The North Wales Wind Farms Connection Project Appendix to SP Manweb's Response to the Examining Authority's Second Written Question NWWFC SWQ12.7 (The "Berain Paper") Application Reference: EN020014 Deadline 6 Submission 25th November 2015 Document reference: SPM NWWFC SWQ12.7A North Wales Wind Farms Connection Project Paper To The Examining Authority Addressing Issues Raised During The Issue Specific Hearings Of The Proposed Development On The Property Known As Berain November 2015 PINS Reference: EN020014 SPM Document Reference: NWWFC SWQ12.7A North Wales Wind Farms Connection Project Berain Table of Contents 1 INTRODUCTION and summary ....................................................................................... 2 1.1 Purpose of the Paper ........................................................................................................ 2 1.2 Summary of Conclusions .................................................................................................. 2 2 CONTEXT ......................................................................................................................... 3 2.1 Routeing of the Proposed Development ............................................................................ 3 2.2 Berain as a working farm................................................................................................... 3 2.3 Berain in the landscape ..................................................................................................... 4 2.4 Berain and the historic environment .................................................................................. 4 3 THE PROPOSED DEVELOPMENT AT BERAIN ............................................................. 5 3.1 Description of the route at Berain ...................................................................................... 5 3.2 Description of the 132kV Overhead Line at Berain ............................................................ 5 4 LAND MANAGEMENT IMPACTS .................................................................................... 6 4.1 Pole locations and their impact on farming practices at Berain .......................................... 6 4.2 Operational effects of working beneath the 132kV overhead line ...................................... 9 4.3 Conclusion ........................................................................................................................ 9 5 LANDSCAPE AND VISUAL IMPACTS .......................................................................... 10 5.1 Description of baseline landscape and visual .................................................................. 10 5.9 Assessment of landscape effect ...................................................................................... 11 5.11 Assessment of visual effects ........................................................................................... 13 6 HISTORIC ENVIRONMENT IMPACTS ........................................................................... 15 6.1 Assessment of effect ....................................................................................................... 15 7 LEGISLATION AND POLICY TESTS ............................................................................. 23 7.1 Introduction ..................................................................................................................... 23 7.2 Consideration of Serious Concerns ................................................................................. 24 7.3 Consideration of landscape and visual effects against policy .......................................... 26 7.4 Consideration of historic environment effects against policy ............................................ 27 7.5 Consideration of cumulative effects ................................................................................. 30 8 CONCLUSION ................................................................................................................ 31 North Wales Wind Farms Connection Project Berain North Wales Wind Farms Connection Project Berain 1 INTRODUCTION AND SUMMARY 1.1 Purpose of the Paper 1.1.1 This Paper provides information on the effects of the 132 kV Overhead Line at Berain. 1.1.2 During the course of the Examination a number of points have been raised concerning the property at Berain and a number of responses have been submitted at previous deadlines. This Paper draws together the information presented in those responses and reiterates SP Manweb’s view that the 132 kV Overhead Line in the vicinity of Berain does not warrant an underground connection. 1.2 Summary of Conclusions 1.2.1 The Paper explains why there is no need to underground any part of the 132kV Overhead Line in the vicinity of the property at Berain. 1.2.2 The Paper makes clear that likely environmental effects, as assessed at Berain Farm, with respect to agricultural operations are similar to those experienced elsewhere. 1.2.3 It outlines the minor inconvenience caused during arable and silage operations, concluding that Berain Farm would not be financially or competitively disadvantaged as a result of the 132 kV Overhead Line. Furthermore, an overhead 132KV line development has recently been installed (Rhyl Flats) across agricultural farmland with minimum disruption to the operation of those farms. 1.2.4 It explains why the LVIA assessment is robust and how a conclusion of moderate effects (at the lower end of the scale) is in no way sufficient to raise ‘serious concerns', as outlined in paragraph 2.8.8 of National Policy Statement EN-5. 1.2.5 The Paper analyses the assessed effects on the historic environment at Berain. It makes clear that there is no substantial harm to or loss of those assets and only a lower moderate effect would arise. The harm is not sufficient to require undergrounding as mitigation. 1.2.6 Intra-project effects are assessed and it is concluded that all effects, either in isolation or considered in-combination, do not warrant a consideration of undergrounding, or need to underground, the 132 kV Overhead Line at this location. 1.2.7 LVIA and historic environment impacts are assessed against the policy tests that are explained in Section 7 of this Paper. The concept of "serious concerns", which can only apply to LVIA impacts, is not engaged in relation to the Proposed Development in the vicinity of Berain. Nor is there any "substantial harm" on the historic assets of Berain. 1.2.8 The Secretary of State has accepted that EN-5 "sets a high threshold for refusing overhead lines in favour of undergrounding". Paragraph 267 of the Inspector's report on the Legacy Substation states, “Furthermore, EN-5, which provides important guidance, sets a high threshold for refusing overhead lines in favour of North Wales Wind Farms Connection Project Berain undergrounding.” The Secretary of State adopted this position in his decision letter stating that he accepts the Inspectors ‟conclusions and recommendations as set out in paragraphs 210 to 273 of the report.” 1.2.9 The Paper makes clear that SP Manweb considers that the 132 kV Overhead Line is acceptable in planning terms at Berain and does not meet the high bar set out in national policy for undergrounding. 2 CONTEXT 2.1 Routeing of the Proposed Development 2.1.1 SP Manweb has set out its approach to routeing in the Appendix 6 to the ‘Applicant's Oral Summary to the Issue Specific Hearing held on 29 September 2015 – Deadline Four Documentation Submission’ (Examination Library Reference REP4-009). 2.1.2 As previously discussed at the Issue Specific Hearing Day 1 and in the submission noted above, the approach builds on SP Manweb’s experience in routeing overhead electricity transmission and distribution lines, and uses established routeing methodologies (including the Holford Rules). It is a staged approach which refines the level of detail at each stage. The primary objective, in accordance with SP Manweb's statutory duty, is to identify a technically feasible and economically viable overhead line route between specified points, which causes the least disturbance to the environment, and to the people who live, work, visit and enjoy the area. 2.1.3 The design has evolved iteratively through a number of revisions in response to consultee comments and the outcome of studies being undertaken, initially for the routeing process and then as part of the environmental impact assessment. In addition to environmental considerations, technical and economic considerations were also taken into account in developing the proposed route. 2.1.4 The approach to routeing was based on the Holford Rules, the broad principles formulated by the late Lord Holford for the routeing of overhead transmission lines. The process has led to a proposed route that as far as possible accords with the Holford Rules and minimises effects. 2.1.5 SP Manweb considers that, through the routeing methodology and studies undertaken, an acceptable design for the 132 kV Overhead Line has been identified. However, in response to submissions by Interested Parties throughout the Examination, further consideration has been given to the section of the 132 kV Overhead Line in the vicinity of Berain. 2.2 Berain as a working farm 2.2.1 The farming business of Berain Farm is an intensive ‘in hand’ (i.e. run by the landowner) mixed farm approximately 2.5km to the south east of Llannefydd. 2.2.2 The business farms approximately 360 Acres (146 Hectares), which is identified on the published ALC Map as Grade 3 agricultural land1, as