Clair Jenkins Ein cyf/Our ref: SH/2015/118868/01-L01 Pembrokeshire County Council Eich cyf/Your ref: 15/0419/PA Development Control County Hall Freemens Way Dyddiad/Date: 27 August 2015 Haverfordwest Dyfed SA61 1TP Annwyl / Dear Ms Jenkins Proposal: INSTALLATION OF A SINGLE 85KW WIND TURBINE AND ASSOCIATED INFRASTRUCTURE. (36.6M TO HUB, 48.4M TO BLADE TIP.) Site Address: BUSH FARM, RHOSFACH, CLYNDERWEN, SA66 7JR. Thank you for consulting Cyfoeth Naturiol Cymru/Natural Resources Wales on the above application, which we received on 30 July 2015. We object to the proposal due to adverse effects on the character and quality of the Pembrokeshire Coast National Park at the southern slopes of the Preseli Hills and on its setting within the upper reaches of the Eastern Cleddau. The proposal is not compatible with the conservation and enhancement of the natural beauty of the park due to its adverse effect on landscape character and visual intrusion into sensitive views both from and to the park. It would also have an adverse impact on the historic character and integrity of the Preseli Registered Landscape, in which it lies. The Register of Landscapes of Special Historic Interest in Wales promotes the conservation of the key characteristics of historic landscapes as those landscapes evolve. Pembrokeshire County Council Local Plan Policy GN38 requires that development should protect and enhance the character and integrity of the historic environment, including historic landscapes. The Cultural Heritage Impact Assessment does not include an assessment of the impacts on the Registered Landscape. The LVIA underestimates the sensitivity of the landscape in our opinion and the photographs do not represent the level of detail seen in the field, thereby illustrating a lower magnitudePembrokeshire of impact. Very few viewpoints County are included Council from public footpaths/bridleways and areas of open access land, of which there are many in the locality. Natural Resources Wales / Cyfoeth Naturiol Cymru Maes Newydd, Llandarcy, Neath Port Talbot, SA10 6JQ. Llinell gwasanaethau cwsmeriaid / Customer services line: 0300 065 3000 www.cyfoethnaturiolcymru.gov.uk / www.naturalresourceswales.gov.uk Croesewir gohebiaeth yn y Gymraeg a'r Saesneg Correspondence welcomed in Welsh and English Explanation The proposal lies approx.1.5km from the Pembrokeshire Coast National Park boundary to the north-west and north-east. It lies within the Preseli Registered Landscape of Outstanding Historic Interest. The proposal would be sited on pasture land at 207m AOD to the north-west of Llangolman and south-east of Rhosfach. The ZTV shows that the turbine would be potentially visible from Carn Afr, Mynydd Bach/Foel Feddau, Foel Cwmcerwyn, Craig Talfynydd, the road to Mynachlog-ddu, A478 as well as local footpaths and lanes within the locality within 5km of the turbine. The Cultural Heritage Impact Assessment mentions the Preseli (HLW (D) 7) historic landscape character area, which is of outstanding historic interest but provides no assessment of the impacts on the Registered Landscape. The effects on the setting of various scheduled monuments, listed buildings and other heritage assets within the area has been assessed. The effect on the setting of the standing stone north-west of Spring Gardens (NA27) and Castell Pen-Gawai (NA28) is considered moderate adverse; on the setting of Gors Fawr stone circle (NA31) and Foel Cwmcerwyn round cairns (NA59) moderate-low and on Foel Feddau round cairn (NA61) low. These monuments lie within the Registered Landscape and within 5km of the proposal. Cumulative effects are considered in relation to Foel Cwmcerwyn and Foel Feddau cairns, where a number of other turbines would be visible (Llandilo Uchaf, Maenllwyd, Trebengych, Cornel & Ciliau Fawr). There is also an approved turbine at Ciliau Fawr. The positive contribution of the undeveloped upland setting is recognised. It is considered that the setting of Foel Cwncerwyn cairn has already been compromised by approved turbines but there would not be excessive cumulative effects and no substantial harm. It is stated that the presence of existing turbines reduce the visual effect on Foel Feddau cairn. We consider that this additional turbine would add to the adverse cumulative effect. The presence of existing turbines do not reduce the visual effects of this proposal, which is larger than all the other approved turbines within 5km. There would be additional cumulative effects from this turbine and combined cumulative effects from this group of turbines around the head waters of the Eastern Cleddau to the south of the Preseli hills. There would be adverse individual and cumulative effects on a number of scheduled monumentsPembrokeshire that lie within the Registered Landscape County and on theCouncil historic character and integrity of the Registered Landscape itself. Whilst the turbine is identified as a small/medium scale turbine, it is a large, moving modern infrastructure development in the context of the historic landscape. The LVIA identifies the turbine as small/medium scale, in accordance with the Pembrokeshire and Carmarthenshire: Cumulative Impact of Wind Turbines in the 2 Landscape (April 2013) Guidelines. Appendix 5 appears to combine landscape character sensitivity and visual sensitivity in an assessment of the view, rather than assessing landscape character and visual impact separately. A full account of the 5 layers of Landmap has not been considered in the assessment. Of the 12 viewpoints, only viewpoint 12 is considered of high sensitivity and 10 of 12 viewpoints are from roads with only two from footpaths. Given the high sensitivity of the landscape recognised by Landmap and its location within a National Park and Registered Landscape this is a considerable undervaluation of this landscape. There are numerous footpaths and bridleways, including on high ground, some of which are likely to have clear views of the turbines, as well as open access land on the Preseli Hills. With regard to Landmap aspect areas, the site lies within historic landscape aspect area Rhosfach (PMBRKHL42249), overall evaluation high. It is a multi-period historic landscape in the foothills of the Preseli’s that relates directly to the uplands. It lies within the cultural aspect area Preseli Hills and Carns (PMBNPCL331), evaluated as outstanding and visual & sensory aspect area New Inn (PMBRKVS044), evaluated as high. The area is of high scenic quality with views to the Preseli Hills important. Geological and habitats aspect areas are evaluated as moderate. We consider that the sensitivity of the landscape has been underestimated and in many cases the sensitivity of the viewer (receptor). The local lanes are likely to include walkers, cyclists and horse riders as well as motorists, given the proximity to the National Park. There are many footpaths and bridleways as well as access land where views have not been assessed. Viewpoints 9, 10 and 11 are within the National Park. We consider the receptors at these viewpoints to be of high susceptibility and the value of the landscape to be high, resulting in high sensitivity. Visibility from viewpoints 9 and 11 is limited, whereas there are clear views from viewpoint 10. At 2.98km distant the turbine is likely to be conspicuous on the skyline and result in a major-moderate significant effect. From viewpoints 4, 5 and 12 there are scenic views to the Preseli’s and there are likely to be major-moderate significant effects from viewpoints 4 & 5, within 2.3km where the turbine is likely to be prominent and moderate significant effects from viewpoint 12 4.25km away. From viewpoints 1 & 2, within 1km, the turbine is likely to be dominant, have a major impact on medium sensitivity receptors with a major—moderate significant effect. We base ourPembrokeshire opinions with regard to dominant, County prominent, conspicuous Council on a variety of guidance including Cumbria County Council (2007) Cumbria Wind Energy Supplementary Planning Document and University of Newcastle (2002) Visual Assessment of Wind Farms Best Practice, and supported by recent Inspectors decisions at Public Inquiries. All the photographs appear to be panoramas with no horizontal field of view 3 indicated. They do not show the level of detail seen in the field and illustrate a lower magnitude of impact than the reality. This requires single frame images with a 40 degree horizontal angle of view, reproduced at A3. In terms of cumulative effects, the proposal would add to the cumulative effects of turbines around the head waters of the Eastern Cledddau to the south of the Preseil Hills in close proximity to the National Park and within the Registered Landscape. The turbine is larger than all the approved 8 turbines within 5km and considerably larger than all but one (Ciliau Fawr 42m). The existing turbines are scattered, with reasonable distances between them and a degree of screening from vegetation and landform. The additional turbine would add to the cumulative effect. The LVIA only considers the additional cumulative effect of this turbine and considers the effects to be limited. The cumulative visual effects on this part of the National Park are not likely to be significant, in our opinion, with the main effect is from the individual turbine. There would be an adverse cumulative effect on the historic character of the Registered Landscape and setting of the National Park due to major-moderate effects within 2.3km and moderate adverse effects on two scheduled monuments. Outside Strategic Search Areas. Planning Policy Wales TAN8, Annex D, paragraph 8.4 states that ‘In the rest of Wales outside the SSAs, the implicit objective is to maintain the landscape character i.e. no significant change in landscape character from wind turbine development.’ We are concerned that the character of this area, within the setting of the National Park and within a Registered Landscape is changing from an area with occasional wind turbines to one with wind turbines as a key characteristic.