OBJ/003/LAND/POE/S4 Mid Wales (Powys) Conjoined Public Inquiry (CPI) into 5 wind farm Applications and a 132 kV Overhead Power Line Connection. Session 4 – Cumulative Effects Proofs of Evidence re: Landscape. Culture and Heritage. Presented by: Llansanffraid Action Group (LAG) against Wind Farms and Pylons in Mid Wales On behalf of: Cyngor Cymuned Llansanffraid a Deuddwr Community Council : Cyngor Cymuned Carreghwfa Community Council Author - Rh. ap Rh. Owen, BVSc Hons, DVR, DipACVS, FRCVS Preface This proof of evidence is presented on behalf of the above bodies because it is abundantly clear to them that a direct consequence of the proposed wind farm developments presently being considered by the Public Inquiry has to include the National Grid 400kV line, otherwise the wind farms would not be functional. Therefore the National Grid 400kV line is a relevant and significant part of this whole infrastructure project and needs to be considered by the inquiry. Hence the reason for this submission which is to discuss the cumulative consequences of these Wind Farm projects on our communities. February 2014. A. Cumulative effects on Landscape A.1 Landscape ‘sensitivity’,’ value’ and ‘visual and sensory amenity’. A.1.1 Landscape characteristics and attributes, hence ‘Value’, has been quantified to a degree in the ‘Landmap’ (Crown Copyright). Landmap however has only quantified landscape as ‘visual and sensory amenity’ which it has limited to three categories High, Moderate and Low. Even so Landmap is the basis on which objective assessments are then made in greater detail. A.1.2 To understand and define how various landscape values may be sensitive to the development of overhead power lines and associated pylons they need to be categorised into 5 more detailed tiers of ‘Sensitivity’, namely High, Medium/high, Medium, Low/medium and Low. High and Medium /high landscape sensitivity offers very limited opportunity for accommodating change due to overhead lines. Hence High and Medium/high landscape values are vulnerable to change and loss as a result of overhead lines. A.1.3 “The landscape of Meifod valley is highly sensitive to overhead line development” (1). “The Meifod valley considered of High sensitivity and tributary valleys, including Banwy, Cain and Tanat” (2). By including the Cain and Tanat valleys National Grid is clearly referring to Llansanffraid ym Mechain and Carreghwfa (Llanymynech). It is clear therefore that the whole Vyrnwy Valley including Llansanffraid ym Mechain and Carreghwfa (Llanymynech), being categorised as ‘High’ landscape sensitivity, would be subject to a loss of landscape value as a result of overhead lines. A.1.4 The Countryside Commission for Wales, now part of Natural Resources Wales, quoted by National Grid (3) described the whole Vyrnwy Valley as “substantially rural, unspoilt and domestic in character”. “The landscape and visual effects of routeing such a large scale power line into an unspoilt valley would be significant and adverse”. The full text of the Countryside Commission for Wales feedback report to National Grid (comments 49 – 52) makes very clear that due to the high landscape sensitivity “we (CCW) would wish to see the line placed underground from Mathrafal to at least 2Km to the north east of Meifod village” and “given that the character of the valley landscape does not alter significantly along its length to Llansanffraid ym Mechain, continuing with the undergrounding as far as the turning point east of Llansanffraid ym Mechain”. Even east of this turning point in the Vyrnwy Valley the CCW report states “there would still be significant adverse landscape and visual effects”. A.1.5 On the basis of landscape ‘sensitivity’ and ‘value’ the CCW advised that any power line should be undergrounded in the Vyrnwy Valley from Mathrafal to the east of Llansanffraid ym Mechain to avoid the cumulative effect on landscape value and the visual amenity. However National Grid has only proposed to accept the advice in part and underground from Mathrafal to Waen Fach. The remaining section of the Vyrnwy Valley from Waen Fach to the turning point east of Llansanffraid ym Mechain would be overhead lines. Clearly where the overhead lines are not undergrounded there would be a cumulative loss to the landscape in terms of value and visual amenity. A.1.6 This decision by National grid is inconsistent and cannot be justified on the basis of ‘landscape’ factors. Their lack of objectivity and consideration of the facts is best revealed by the illustration based on ‘Landmap’, albeit that the Landmap uses ‘visual and sensory amenity’, the inconsistency is obvious. Fig. 1 shows a description and the category of ‘visual and sensory amenity’ landscape in the Vyrnwy Valley around Meifod, Llansanffraid ym Mechain and Carreghwfa(Llanymynech); purple being high with yellow and blue moderate. The broken line is proposed underground and the solid line over head lines. The figure clearly shows that the visual and sensory amenity of the landscape in the Vyrnwy Valley to the east at Llansanffraid ym Mechain and Carreghwfa (Llanymynech) is at least equivalent if not greater than the west section at Meifod. A.1.7 The conclusion has to be on the basis of landscape value and visual and sensory amenity that the landscape sensitivity throughout the Vyrnwy Valley is similar and therefore the decision by National Grid to ignore the evidence regarding the need to underground cables fully will result in a major deleterious cumulative effect on the Vyrnwy Valley around Llansanffraid ym Mechain and Carreghwfa (Llanymynech) if the pylon route is required. A. 2 Visual Receptors A.2.1 Visual receptors are defined as factors which are affected by landscape value. By definition the introduction of overhead lines into a landscape would change its value in a detrimental way and therefore the visual receptors will be directly affected significantly and adversely. A.2.2 Visual receptors include residents, temporary residents of caravan parks and visitors visiting or passing through the area. A.2.3 Llansanffraid ym Mechain is the largest village in the Vyrnwy Valley and it is situated in an elevated position on the north side of the valley near the confluence of the Vyrnwy and Cain rivers. The proposed overhead line route will pass along a raised ridge of land between the Cain and Vyrnwy Rivers directly south of the village which means a full, uninterrupted and skylined view of the overhead line from the village. Furthermore the route east of Llansanffraid ym Mechain crosses the Trederwen ridge and will be visible to residents on the eastern aspect of the village as a rising row of pylons stacked in a line as they cross the Trederwen ridge. This is acknowledged by National Grid “an overhead line along the valley floor would be overlooked by the properties on the valley sides of the large villages of Llansanffraid ym Mechain and Llanymynech”(4). The route could not take a more prominent course for the residents of Llansanffraid ym Mechain on both counts and as a consequence all the residents of the village, as visual receptors, will be adversely affected. A.2.4 This in direct conflict with Holford Rule 5 which states “minimise the exposure of the numbers of towers on prominent ridges and skylines”. National Grid admits that “some sky lining of pylons unavoidable” (4). That is an inaccurate claim. There are avoidable alternatives. A.2.5 Holford Rule 2 states areas of amenity value should be avoided such as routeing “close to residential areas”. It is ironic that National Grid state (5) that one of the highest causes of concern expressed by respondents was proximity to areas of population and property and yet by routing overhead lines next to Llansanffraid ym Mechain they have detrimentally and adversely affected the greatest number of residents in the Vyrnwy Valley. The cumulative effect is that the greatest population of residents, as visual receptors will be adversely affected by this proposal in terms of reduction in landscape value and visual and sensory amenity value. A.2.6 The Holford Rules supplementary notes state that overhead lines should avoid areas of “district and local value”. South of Llansanffraid ym Mechain near the Cain River there is a network of public footpaths and two pedestrian bridges over the Cain River which is a very popular circular walk for residents from the village. The routing of the overhead lines as proposed by National Grid would change this local amenity of unspoilt rural tranquillity away from traffic on the edge of the village to an industrialised landscape. This loss of visual and sensory amenity would be a direct cumulative effect of the overhead lines. A.2.7 Between Llansanffraid ym Mechain to the west and Carreghwfa (Llanymynech) to the east there are 5 large caravan parks, the largest tourist facility anywhere along the proposed National Grid route. This means that during the spring, summer and autumn the population and hence the visual receptors more than double. These caravan owners are the single most important contributors to the local economy of these two areas of population in the Vyrnwy Valley and yet as visual receptors they have not been consulted by National Grid. The caravan park owners have not wished to consult their clients because obviously to do anything to highlight the possibility of adversely changing the substantially rural and unspoilt landscape around each site would be likely to drive clients away. This in turn will affect the local economy, a direct cumulative effect of having overhead lines. A.2.8 Likewise the A 495 which runs through Llansanffraid ym Mechain and along the Vyrnwy Valley to the west is a tourist route to the Welsh coast. While National Grid acknowledges the “significant (adverse) effects on the A495 tourist route” (6) at Meifod, the same effect is ignored for Llansanffraid ym Mechain.