Cumulative Landscape and Visual Matters. Proof of Evidence for the Applicant

Transcription

1 Mid Wales (Powys) Conjoined Wind Farms Public Inquiry SESSION 4: SSA C Proposed Repowering and Extension to Llandinam Wind Farm, Powys, Wales CeltPower Limited Cumulative Landscape and Visual Matters Proof of Evidence for the Applicant James D G Welch FLI DECC Reference: BERR/2008/0003

2 2 Section Contents Page 1.0 Introduction Approach to cumulative assessment Agreement between Parties Areas of disagreement Summary of findings from Session Relevant cumulative baseline considerations Assessment of potentially significant cumulative effects Conclusions 31 Key supporting documents: APPENDIX A APPENDIX B APPENDIX C James Welch CMLI Experience & Instructions OPEN s standard methodology for Cumulative LVIA Supplementary ZTV and wirelines

3 3 1.0 INTRODUCTION 1.1 My name is James Welch. I am a Director of Optimised Environments Limited, OPEN, a firm of Landscape Architects and Environmental Planners, based in Edinburgh. I am a Fellow of the Landscape Institute (FLI), with 26 years experience in the landscape and visual evaluation of development. My practice is also a registered Practice with the Landscape Institute. I formed OPEN in 2009 having been a Managing Principal of EDAW plc for the five years previous to that. Prior to that I was a Partner/ Director in the business of Derek Lovejoy Scotland Limited, with whom I was employed for 19 years. 1.2 My experience and instructions are set out in Appendix A to this Proof. I have been involved in a large number of windfarm developments across the UK, including several repowering proposals, many of which have involved complex cumulative landscape and visual assessments. I have also given evidence on cumulative effects at a number of Public Inquiries, including for example Dorenell S36 windfarm in Moray; Harburnhead windfarm in West Lothian and Flood s Ferry in Fenland. My experience also includes several transmission line routeing studies including assessing options for a 400kV line from Dungeness to South London; a 132kV wooden pole line connection for Black Law Windfarm and a high level assessment for a 400kV grid connection to Spalding CCGT Power Station. I am therefore familiar with the terminology and nature of the various infrastructure types which are being considered under this Session of the Mid Wales Inquiry. 1.3 CeltPower Limited ("CeltPower") applied on 9 May 2008 under section 36 of the Electricity Act 1989 for consent to build a 42-turbine wind farm (the Development ), with a proposed installed capacity of up to 126 MW, at a site including the area of the operational Penryddlan & Llidiartywaun (P&L) wind farm in Powys, Mid Wales. The Development has subsequently been amended to address consultation responses and to mitigate its effects and the scheme before this Inquiry comprises 34 turbines (of up to metres in overall height) with a proposed installed capacity of up to 102 MW. The existing P&L windfarm comprises 102 turbines of 45.5m height with an installed capacity of 31 MW ("the existing Llandinam Windfarm") and which would be replaced by the proposed Development. 1.4 I was approached to prepare landscape and visual evidence in support of CeltPower s case at the Mid Wales Inquiry in December 2012 and I acted as its witness on landscape

4 4 and visual matters at Session 1 of the Inquiry. Details of my relevant experience and instructions in relation to this Inquiry are set out in Appendix A to my Proof. The evidence set out in this Proof, for Session 4 of the Inquiry, should be read in conjunction with my Proof for Session 1, which I adopt and rely on for those effects not under consideration at Session 4. This Proof is concerned with cumulative landscape and visual effects of the Development and develops the findings of the Cumulative Landscape and Visual Assessment (CLVIA) undertaken to date by the Applicant. It sets out my opinion on the likely cumulative effects, drawing on the CLVIA by SLR and my own analysis and evaluation. It is my understanding from the Inspector s note of the Opening Session of the Inquiry that Session 4 is specifically concerned with the cumulative landscape and visual effects that may arise between windfarms in SSAs B and C and also between the various windfarms and the potential grid infrastructure that is proposed to connect them to the electricity network. Session 4 is thus not concerned with the cumulative effects that arise from the schemes within SSA C, as that was considered within the evidence for Session My Proof explains my professional opinion which is supportive of CeltPower s Development. It is clear to me from the evidence that was led at Session 1 of the Inquiry that there is considerable agreement with both Powys County Council (PCC) and Natural Resources Wales (NRW) that Llandinam Repowering Windfarm is an acceptable development in landscape and visual terms, both singly and cumulatively with other operational and consented windfarms. This agreement is founded on the fact that the Development re-powers an existing windfarm which has an existing influence on the landscape character and visual amenity of the area. It is also my view that the Waun Ddubarthog ridgeline, on which the Development would be sited, has physical characteristics which are inherently compatible with commercial scale windfarm development. The Alliance of Objectors does not agree that the Development is acceptable in landscape and visual terms either singly or cumulatively and I refer to both opposing positions further later in my Proof. 1.6 This Proof has been prepared to inform CeltPower s case in respect of cumulative landscape and visual effects, at Session 4 of the Mid Wales Conjoined Inquiry, concerning the TAN 8 Strategic Search Area C (SSA C). It should be read in conjunction with the following key documents which are referred to throughout my proof: The Applicant s ES of May 2008 (AD/CPL/ );

5 5 The Applicant s SEI dated December 2011 (AD/CPL/ ); The Applicant s SEI dated May 2013 (AD/CPL/ ); The LUC Supplementary Cumulative Graphics; My Proof, Appendices and supporting Documents from Session 1 of the Inquiry. 1.7 I am the second chartered landscape architect to review the Llandinam Development for CeltPower Ltd from a cumulative landscape and visual perspective. The LVIA was prepared by chartered landscape architects at SLR Consulting, with whom I have cooperated in the preparation of the 2013 SEI report and illustrations. I think that it is particularly relevant to this Inquiry that both landscape architects who were independently engaged by CeltPower consider that the amended Development would not lead to any unacceptable effects in landscape, visual or cumulative terms. The project (when it comprised 39 wind turbines) was also subject to scrutiny by Capita Symonds Ltd who was appointed by Powys County Council (PCC) to independently review the 2008 LVIA that supported the application and the SEI prepared in Capita Symonds identified a number of matters in its 2012 report, the majority of which I consider have been addressed by the amended scheme, as I discuss in my Proof for Session In preparing my evidence for Session 4 I have collaborated with landscape architects acting for the other windfarm developers that are involved in the Inquiry. The purpose of this collaboration has been to produce a single set of cumulative figures on which all parties to the Inquiry can rely. The document prepared on behalf of the Applicants by Land Use Consultants (LUC-December 2013) provides an agreed set of visualisations and ZTVs which will help to give the Inspector a consistent and comprehensive impression of the potential cumulative effects of the various applications in context with other windfarms and of other related infrastructure which is being determined through separate processes. I therefore adopt the LUC graphics as part of my evidence for Session It is relevant to note that the LUC figures have been submitted to the Inquiry as Supplementary Environmental Information (SEI). These figures do not alter Celtpower s and my view that such matters do not reveal any additional significant environmental effects for Llandinam Repowering over and above those already identified. CeltPower is content to rely on the LUC document as supplementary cumulative graphics. I refer to them in my Proof as the LUC graphics.

6 The evaluation undertaken within my Proof follows best practice and only assesses the cumulative effects that the Llandinam windfarm could give rise to it does not (re)assess the effects of the other schemes which are before the Inquiry as it is for the landscape architects which represent them to assess their own applications. Where potential grid connections are referred to but have not yet been formally assessed through EIA, I have set out my assumptions made on a realistic, worst-case basis - about the likely magnitude and significance of effect they may have; that is based on my experience and through reference to other similar assessments, for example SP Manweb's EIA of the Llandinam Repowering grid connection which is before the Inquiry. My approach refers to best practice guidance as set out by Scottish Natural Heritage (SNH) in its report Assessing the cumulative impact of onshore wind energy developments - SNH Paragraph 55 of the Guidance states: The purpose of a Cumulative Landscape and Visual Impact Assessment (CLVIA) is to describe, visually represent and assess the ways in which a proposed windfarm would have additional impacts when considered in addition to other existing, consented or proposed windfarms. It should identify the significant cumulative effects arising from the proposed windfarm I refer in my Proof to the two documents which were submitted as SEI to the Inquiry in December The first of these is a Grid Connection Options Review prepared by Mott Macdonald on behalf of the developers behind the four other wind farms before the Inquiry (AD-RWE-031). This considers a number of options in relation to how those four projects may be connected to the National Grid, in addition to other potential electricity generation projects in Mid Wales. The second document is a high level environmental review of the options which are identified within the Mott Macdonald study, prepared by LUC also on behalf of the four other windfarm developers (AD-RWE-032 to AD-RWE- 032b) My role at the Inquiry is primarily to ensure that the Inspector and, through him, the Secretary of State - has all the relevant information on landscape and visual matters to hand insofar as the Llandinam Repowering Development is concerned. I also refer to the current position as expressed by NRW, as set out in its Submission to the Opening Session of the Inquiry which indicates that it has no outstanding concerns, in landscape and visual terms, relating to the effects of the Development on its own. NRW does however as I understand it - maintain an objection to the Development in relation to the contribution of the three schemes in SSA C to cumulative impact in landscape terms (NRW Statement of Case for Session 1 at paragraph 9). Having reviewed NRW s

7 7 Statement of Case for Session 4 I am no clearer whether NRW objects to Llandinam repowering in terms of its cumulative interaction with the proposed and potential grid connections, although I am clear that it considers that the consenting of the dedicated 132kV grid connection for Llandinam Repowering would be premature, pending detailed design of other grid infrastructure which is not the subject of this Inquiry (NRW SoC para 3.7) My Proof also addresses my understanding of the relevant and various concerns - expressed by the Alliance of Objectors together with other individuals who have expressed concern - insofar as cumulative landscape and visual matters have been raised. My instructions are to review all of the relevant background information relating to the application and to address the outstanding concerns expressed in consultations and representations that have been made in connection with the windfarm application, insofar as landscape and visual matters are concerned. Wherever italics are used in my Proof this signifies a quotation that I have extracted from another source I understand my duty to the Inquiry and have complied, and will continue to comply, with that duty. I confirm that this evidence identifies all facts which I regard as being relevant to the opinion that I have expressed and that the Inquiry's attention has been drawn to any matter which would affect the validity of that opinion. I believe that the facts stated within this proof are true and that the opinions expressed are correct My evidence focuses on those issues and locations which are potentially significant in cumulative terms. For the avoidance of doubt, I have nothing further that I would wish to add to the LVIA chapter of the ES (including the subsequent SEI reports) which deals with those wider effects which are not significant. This is not to disregard effects which are not significant, in the terms of the EIA Regulations, but rather to focus on those aspects of the effects that are likely to be determining matters in respect of the application. Ultimately, there will inevitably be some impacts from any development of this scale which must be weighed in the planning balance before a decision can be taken upon a project. That planning balance will be dealt with for the Applicant by Mr Peter Frampton in his Planning Proof.

8 8 2.0 APPROACH TO CUMULATIVE ASSESSMENT Introduction 2.1 Cumulative landscape and visual assessment is by its very nature a complex topic, which relies on the application of methodology which can be difficult for the unfamiliar reader to readily comprehend. It is potentially made all the more impenetrable when different forms of development are assessed together, such as the various grid connections and wind farms under consideration at this session of the Inquiry. As noted in the introduction to my Proof, key to the approach lies an understanding of what it is that is actually being assessed. As with landscape and visual assessment, the assessment of cumulative effects is reliant to a degree on the application of trained and reasoned professional judgement. 2.2 In my company s approach, which reflects best practice guidance (SNH Cumulative impacts of onshore wind energy developments (CPL-LAN-007), the assessment identifies whether any additional magnitude of change which is caused by Llandinam Repowering, when added to the impact of a number of baseline developments, is significant or not. Importantly, the proposed Development, in my case Llandinam Repowering, remains the focus of my assessment and I do not assess the effects of the other schemes or development. That is for other applicant s to undertake. Furthermore, I do not attempt to assess the overall, combined effect of a number of developments taken together as that is beyond the remit of the assessment, as acknowledged in the Landscape Institute s Guidelines for Landscape and Visual Impact Assessment 3 (CP-LAN-005) at paragraph 7.18: the assessor will not have assessed the other schemes and cannot therefore make a fully informed judgement. A more comprehensive overview of the cumulative effects must rest with the competent authority. In this case that overall judgement rests with the Inspector and the Secretary of State, who will have the benefit of hearing cumulative evidence from each of the Applicants. 2.3 Support for my approach to cumulative assessment is found within both the Landscape Institute s Guidelines noted above and within SNH s Guidance Assessing the cumulative impact of onshore wind energy developments 2012 ( the SNH Guidance ) which is specifically concerned with windfarm effects. The CLVIA undertaken by SLR within the 2008 and 2011 ES chapters refers to the previous guidance prepared by SNH (2005). Whilst not materially different in approach, the 2012 guidance places greater emphasis on an approach which focuses its attention on those cumulative effects that have the potential to be significant. For example paragraph 33 emphasises in bold that: The key

9 9 principle for all cumulative impact assessments is to focus on the likely significant effects and in particular those which are likely to influence the outcome of the consenting process. And at paragraph 66: At every stage in the process the focus should be on the key cumulative effects which are likely to influence decision making, rather than an assessment of every potential cumulative effect. Cumulative effects guidance 2.4 As with landscape and visual assessment, the assessment of cumulative effects considers effects separately on landscape and visual receptors. The SNH Guidance explains the different considerations very clearly and I have extracted some relevant paragraphs below for ease of reference: Cumulative landscape effects can impact on either the physical fabric or character of the landscape, or any special values attached to it (designated landscapes). For example: - Cumulative effects on the physical fabric of the landscape arise when two or more developments affect landscape components such as woodland, dykes, rural roads or hedgerows. Although this may not significantly affect the landscape character, the cumulative effect on these components may be significant for example, where the last remnants of former shelterbelts are completely removed by two or more developments. - Cumulative effects on landscape character arise when two or more developments introduce new features into the landscape. In this way, they can change the landscape character to such an extent that they create a different landscape character type, in a similar way to large scale afforestation. That change need not be adverse; some derelict or degraded landscapes may be enhanced as a result of such a change in landscape character. 2.5 Cumulative effects on visual amenity can be caused by combined visibility and/or sequential effects : -Combined visibility occurs where the observer is able to see two or more developments from one viewpoint. Assessments should consider the combined effect of all windfarms which are (or would be) visible from relevant viewpoints. Combined visibility may either be in combination (where several windfarms are within the observer s arc of vision at the same time) or in succession (where the observer has to turn to see the various

10 10 windfarms). - Sequential effects occur when the observer has to move to another viewpoint to see different developments. Sequential effects should be assessed for travel along regularlyused routes like major roads, railway lines, ferry routes, popular paths, etc. Sequential effects may range from frequently sequential (the features appear regularly and with short time lapses between) to occasionally sequential (long time lapses between appearances) depending on speed of travel and distance between the viewpoints. Although prepared before this guidance was published, the CLVIA for Llandinam Repowering does follow this approach. 2.6 Furthermore, the SNH Guidance advises at paragraph 45 that The cumulative impact of windfarm development on landscape and visual amenity is a product of: the distance between individual windfarms (or turbines), the distance over which they are visible, the overall character of the landscape and its sensitivity to windfarms, the siting and design of the windfarms themselves, and the way in which the landscape is experienced. 2.7 And at paragraph 70: The magnitude of cumulative change may be different from the magnitude of change brought about by the development when considered on its own. The aim of the cumulative assessment is to identify the magnitude of additional cumulative change which would be brought about by the proposed development when considered in conjunction with other windfarms. A range of parameters should be considered, including: the number of other windfarm projects which would be visible in the landscape in each of the different scenarios (existing, consented or application stage); direction to each of the projects; distance to each of the projects; the number and height of turbines at each of the projects which may also be expressed as the horizontal and vertical angle occupied by turbines and any access tracks and grid connections; and

11 duration of the change (i.e. age of constructed windfarms and the planning status of the projects). 11 A further factor which is specific to Llandinam Repowering is that the Development replaces an existing operational windfarm. The assessment of cumulative magnitude of change from the Development must take account of this, as the degree of change is not as great as it would be if there was no existing windfarm on the site. 2.8 The GLVIA 3, published by the Landscape Institute, acknowledges the approach developed by SNH (paragraph 7.3) and develops this in respect of other forms of development. Paragraph 7.28 in GLVIA 3 advises in relation to cumulative landscape effects that: The most significant cumulative landscape effects are likely to be those that would give rise to changes in the landscape character of the study area to such an extent as to have major effects on its key characteristics and even, in some cases, to transform it into a different landscape type. This may be the case where the project being considered itself tips the balance through its additional effects. The emphasis must always remain on the main project being assessed and how or whether it adds to or combines with the others being considered to create a significant cumulative effect. 2.9 In relation to visual effects, the GLVIA 3 advises at paragraph 7.38: Higher levels of significance may arise from cumulative visual effects related to: Developments that are in close proximity to the main project and are clearly visible together in views from the selected viewpoints; Developments that are highly inter-visible, with overlapping ZTVs- even though the individual developments may be at some distance from the main project and from individual viewpoints, and when viewed individually not particularly significant, the overall combined cumulative effects on a viewer at a particular viewpoint may be more significant.

12 AGREEMENT BETWEEN PARTIES Introduction 3.1 With the exception of the Alliance of Objectors, there is a large measure of agreement between the Applicant and main parties that the Llandinam repowering project is acceptable in landscape and visual terms. Both Powys County Council (PCC) and Natural Resources Wales (NRW) have withdrawn their previous objections to the project, and NRW has decided not to attend Session 4 of the Inquiry, instead relying on specific aspects of the Council s case, as set out in its correspondence of 17 th February 2014 to the Inspector. At Session 1 of the Mid Wales Inquiry, PCC and CeltPower Ltd for Llandinam Repowering produced an Agreed Statement of Common Ground (dated 3 October 2013) in which it is recorded that: (vi) taken in combination with existing and consented windfarms in Mid Wales, the proposed Llandinam windfarm would not introduce any unacceptable cumulative landscape and visual effects. 3.2 The Council s landscape expert, Mr Philip Russell-Vick, confirmed at paragraph 5.13 of his Proof of Evidence for Session 1 that The Llandinam Repowering scheme is acceptable in landscape and visual terms. and For these reasons I believe that it is right, in landscape and visual terms, that this scheme proceed. I am aware from their respective evidence to Session 3 of the Inquiry that both PCC and NRW maintain some concern over aspects of the routeing of the dedicated 132kV wooden pole connection between Llandinam Repowering and Welshpool substation. These concerns are not in relation to the principle of the grid connection but are concerned with detailed aspects of its routeing, which they suggest could be overcome by undergrounding sections of the line. It is clear to me that the proposed Llandinam Repowering windfarm does not become unacceptable in landscape and visual terms because of concerns over aspects of the separate application for a grid connection. While I accept that these concerns exist, the Llandinam Repowering windfarm is inherently acceptable in my professional opinion, for the reasons set out in my Proof at Session 1. That judgement forms the basis of my approach in this Proof. 3.3 I understand from the evidence led in Session 2 that the Council s landscape witness also finds the schemes in SSA B which are before the Inquiry (Llanbrynmair and Carnedd

13 13 Wen) to be acceptable too in landscape and visual terms, with the exception of their respective access arrangements. I draw from this that the Council must consider the cumulative landscape and visual effects between these turbines in SSA B and SSA C to be acceptable, insofar as these two schemes and Llandinam Repowering are concerned. This is an important and relevant conclusion to draw in respect of the evidence to be heard at Session 4 and my own evidence concurs with this finding. 3.4 In its Statement of Case for Session 4, PCC has confirmed in paragraph that Llandinam wind farm can be accommodated within the environmental capacity of the area subjecting to demonstrating that it will not have unacceptable impacts through the proposed strategic transport route, and subject to resolving outstanding NRW objections. In relation to the proposed 132kV grid connection to Welshpool, PCC s position is clarified in paragraph 3.5 as follows whilst the chosen route results from a flawed routeing process and causes unnecessary landscape harm it could be accommodated within the environmental capacity of the area provided it is subject to undergrounding in the most sensitive area around the Glog. 3.5 The Council s Statement of Case provides more helpful clarification in section where it confirms that PCC supports the combination of Llandinam Repowering, Llaithddu (northern array) and the Llandinam 132kV OHL scheme. Furthermore, at paragraph it states that PCC does not consider that unacceptable cumulative landscape and visual effects would occur between the wind farm schemes before the Inquiry in SSA B and C, whilst recognising that from a few sensitive locations, in particular weather conditions, there is the potential for significant visual effects. PCC s Statement of Case provides a helpful indication of the Council s position in respect of Session 4 evidence and confirms the Council s considered support for Llandinam Repowering project, albeit caveated with the expectation that NRW s prior objection is also satisfactorily addressed. 3.6 The Applicant has also sought to prepare a Statement of Common Ground with the Council in respect of the cumulative effects of Llandinam Repowering and is hopeful that a joint Statement will be agreed during the course of Session 4 of the Inquiry.

14 AREAS OF DISAGREEMENT 4.1 The Alliance of Objectors is a main party to the Inquiry and does not share either the Council s or NRW s view of the (substantial) acceptability of Llandinam Repowering, in landscape, visual or cumulative terms. The Alliance objects to Llandinam Repowering and its associated 132kV grid connection before this Inquiry and has submitted evidence prepared by Dominic Watkins of Chris Blandford Associates on landscape matters to Sessions 1 and 3. Its Statement of Case for Session 4 reaffirms its position that the harm resulting and associated with each proposal together with potential grid connection effects is, whether on its own or taken together with the other proposal, too great a price to pay for the benefits claimed. 4.2 Whilst I understand the position taken by the Alliance and other local residents in respect of the change that could occur to their local landscape and visual amenity, I do not accept the arguments put forward in respect of Llandinam Repowering, that it is unacceptable in landscape and visual terms. I consider Llandinam Repowering to be acceptable both singly and cumulatively with schemes in SSA B and SSA C and the grid infrastructure that could be required to provide their connections, for the reasons set out in this Proof and my Session 1 evidence. 5.0 FINDINGS FROM SESSION In Table 2 on page 40 of my Session 1 Proof I set out my findings of significant landscape and visual effects from the Development, including in respect of significant cumulative effects within SSA C. I conclude that for landscape character effects, significant effects may arise within approximately 7-8km of the site, where the turbines may have a defining influence on the key characteristics of the character. I consider that there will be significant landscape effects on the landscape character of parts of the character types and areas that surround the site, but that these effects will diminish within a distance of around 7-8km from the turbines to a not significant level. I found that significant visual effects could occur at a greater range than landscape effects and the principal visual effects will be confined to areas and locations that have clear and open views of the Llandinam Repowering wind turbines within an approximate range of 10km. Outside of approximately 10km radius from the Llandinam Repowering turbine envelope I do not consider that there is any potential for significant landscape and or visual effects to arise.

15 In relation to the cumulative effects of Llandinam Repowering in combination with existing and consented windfarms within SSA C, I found significant cumulative effects would arise at the following viewpoints, all of which are within 10km from the windfarm: VP 2 Newtown Significant 8.7km VP 4 A483 Dolfor Significant 5.1km VP 5 Kerry Ridgeway Significant 6.05km VP 7 Fron Top Significant 7.64km VP 9 Minor road north of David s Well Significant 3.8km VP 10 Bwlch-y-sarnau Significant 6.05km VP 13 Grach Significant 1.4km VP 14 Pant-y-dwr Significant 6.6km VP 16 Glyndwr s Way near Moelfre Significant 0.54km VP 17 Llidiartywaun Community Hall Significant 1.8km (Note: I do not consider that the effects at VP 11 and 15 are significant, despite being recorded as significant in the ES, as noted in my Session 1 Proof at paragraph I also regard the assessment for VP 2 Newtown to be borderline significant). 5.3 In relation to the cumulative effects of Llandinam Repowering in combination with existing, consented and application stage windfarms (within SSA C) the additional contribution of Llandinam Repowering is generally reduced, because of the greater baseline influence from the application sites and this would give rise to significant cumulative visual effects at the following viewpoints: VP 2 Newtown Significant 8.7km VP 4 A483 Dolfor Significant 5.1km VP 9 Minor road north of David s Well Significant 3.8km VP 14 Pant-y-dwr Significant 6.6km VP 16 Glyndwr s Way near Moelfre Significant 0.54km VP 17 Llidiartywaun Community Hall Significant 1.8km VP 25 A470/ Railway in Afon Carne Valley Significant 5.7km Again, all of these effects are within 10km from the turbine envelope.

16 These findings have a direct bearing on the potential range within which significant cumulative effects may arise, as the impact from the Llandinam Repowering turbines becomes an increasingly less influential component in the landscape beyond approximately 10km. It is technically possible that a significant cumulative effect could arise at a greater distance than for the windfarm when considered on its own, for example, if it extended windfarm visibility into a part of a view which was previously unaffected and was sufficient to tip the balance in terms of the combined influence of turbines. I have not found any such instances when undertaking my assessment, primarily because of the fact that the existing windfarm is almost always seen as part of the baseline influence, thereby reducing the additional impact of the Llandinam Repowering turbines. It is also the case that the lesser number of turbines proposed, when compared with the existing P&L windfarm, may actually improve the appearance of the Development over the existing windfarm from some viewpoints. This was acknowledged by the Council s witness in his Session 1 Proof and his position is supported by the supplementary wireline analysis that I have undertaken with Appendix C to this Proof. 5.5 It is relevant to reiterate here that neither PCC nor NRW consider the Llandinam Repowering project to be unacceptable in landscape and visual terms, in the full knowledge of the significant effects that I have extracted from the LVIA in the ES, above, and verified in the field. Indeed, Mr Russell-Vick for the Council considers in his Proof for Session 1 at paragraph 5.8 that a considerable number of the assessments within SLR s LVIA do not properly take account of the presence of the existing P&L turbines and therefore reach conclusions which in his opinion are too conservative, or indeed flawed. I have some sympathy with Mr Russell-Vicks findings, which in places accord with my own conclusions, as set out in section of my Session 1 Proof. I consider that some of the Applicant s assessments of effect are over cautious and have corrected this where I feel appropriate. I also support Mr Russell-Vick s assessment at paragraph 5.4 of his Session 1 Proof, that the change in appearance from the busyness of the P&L Wind Farm to the larger but more open and graceful appearance of the Llandinam Repowering scheme would be a visual enhancement on the current scene in my judgement. This has supportive implications for the cumulative assessment as well as the scheme when considered on its own. 5.6 In the following section of my Proof I set out the relevant cumulative baseline for Session 4 of the Inquiry and go on to assess whether there is the potential for Llandinam

17 17 Repowering to give rise to significant cumulative effects with those baseline scenarios. 6.0 RELEVANT CUMULATIVE BASELINE CONSIDERATIONS Introduction 6.1 Notwithstanding the acknowledged level of support that exists amongst some of the main parties for Llandinam Repowering on its own, as established through the evidence at Session 1 and Statements of Case for Session 4, it is relevant that the Inspector has a clear understanding of the likely cumulative effects of the scheme when added to other relevant development proposals which generally lie outside of SSA C. These wider cumulative effects form a relevant part of the decision making process and it is important that the Inspector has the necessary information before him to determine the overall cumulative effects of the Development. 6.2 The Applicant s 2008 ES; 2011 Addendum and 2013 SEI all contain cumulative assessments of Llandinam Repowering, based on the information concerning other windfarms that was available at the respective time. The 2013 SEI also contains a high level assessment of the likely cumulative effects from the proposed grid connection to SSA C and the dedicated 132kV Llandinam Repowering connection to Welshpool (section ). The most up to date assessment by the Applicant is therefore contained within the April 2013 SEI (Chapter 6.0), (qualified where relevant by my own assessment as set out in section 10 of my Session 1 Proof). The cumulative baseline to which Llandinam Repowering was added and assessed is set out at section of Volume 1 of the 2013 SEI and is illustrated on Figure A As noted earlier in my Proof, the consultants acting for all five windfarms at the Mid Wales Inquiry have collaborated to produce a single set of combined, supporting visualisations for Session 4 of the Inquiry. This includes ZTVs for the respective SSA B and SSA C windfarms and their respective possible grid connections as well as a set of cumulative wirelines and photomontages from eight representative viewpoints around the study area. The viewpoint locations were agreed with PCC s landscape expert and many are common to each of the Applicant s ESs. For example, Viewpoints CCVP 1; 2; 3; 5; 6 and 7 are all locations which are assessed with the Llandinam Repowering LVIA. I adopt the figures within this document for the purposes of my evidence. 6.4 The cumulative graphics prepared by LUC in December 2013 provide an up-to-date

18 18 picture of the cumulative baseline. Figure 2 in the LUC graphics provides a comprehensive and up-to-date overview of the relevant cumulative baseline, including Feed in Tariff (FiT) turbines which NRW has requested are considered. Other than these small turbine developments, Figure 2 differs from the baseline assessed in CeltPower s 2013 SEI in that the Llandinam Repowering CLVIA did not assess a baseline including: Pen Coed in SSA B; Mynnydd Mynyllod in Denbighshire; Bryn Titli Extension; Reeves Hill in Herefordshire; Nant y Moch in SSA D; Bodelith Isaf in Gwynedd; Mynydd Gorddu in Ceredigion; Llangwyryfon in Ceredigion; Braich Ddu in Gwynedd. Scoping out effects 6.5 I have reviewed the location and scale of each of these additional wind turbine developments in conjunction with Llandinam Repowering and conclude that the inclusion of some or all of these additional turbines within the baseline would not alter the findings of significance identified within the 2013 SEI cumulative assessment. This is either because the additional turbines are associated closely with other windfarms; are sufficiently distant from Llandinam Repowering so as not to have the potential to give rise to a significant effect or because of the specific relationship between the Development and turbine(s) in question. Importantly, all of the windfarms which are before this Inquiry have been properly assessed within the 2013 SEI as application sites. 6.6 In relation to the schemes within SSA B, I agree with the findings set out in the 2013 SEI that Llanbrynmair and Carnedd Wen windfarms make a minimal contribution to the cumulative baseline. Where they are seen in combination with Llandinam Repowering (for example from CCVP 6 near Caersws which is in an area of notable ZTV coverage) the respective, actual, visibility of the schemes (which is low), separation distances, orientation and presence of intervening screening combines to preclude significant effects arising from Llandinam Repowering. This is also the case for more elevated viewpoints, such as Garreg Hir, where the additional effect from introducing Llandinam Repowering, to a baseline containing application sites within SSA B, is of a low

19 19 magnitude, having regard to the existing influence of the P&L turbines. I do not therefore consider that the potential exists for Llandinam Repowering to generate significant cumulative effect in combination with the sites within SSA B and consequently scope this out from further consideration in my Proof. I note that Philip Russell-Vick for PCC also takes the view that no unacceptable cumulative landscape and visual effects would occur between the wind farm schemes before the Inquiry in SSA B and C, whilst acknowledging that there may be the potential for some significant visual effects from some viewpoints in particular weather conditions. 6.7 In relation to the single and pairs of FiT turbines identified within Figure 2 in the LUC graphics, a number of these are located within and close to SSA C. There is therefore the potential for a cumulative effect to arise when combined with Llandinam Repowering. I have inspected a number of the single turbines during my fieldwork, for example there are several close to the village of Dolfor, which are seen sequentially from the A483 as the route is travelled in a southerly direction from Newtown. The existing P&L wind turbines can also be seen from within the vicinity of Dolfor so a useful impression of the potential for cumulative effects between the different scales of development can be effectively appreciated on the ground. Some of the single turbines are relatively tall structures in their own right and they can give rise to significant environmental effects on their own. When a number of single turbines are seen in quick succession from a route or hilltop viewpoint they can combine to generate a significant cumulative effect upon an area. However, as they are normally of a smaller scale than the turbines used in commercial windfarms, the contribution that single turbines make to a baseline impact is invariably less than that caused by a commercial windfarm. 6.8 In my opinion, the impact from one or more single turbines in the landscape is generally of a different order of magnitude from that found with larger windfarms. Given the repowering nature of the Llandinam windfarm, I have not found any instances where the additional magnitude of the proposed Development, over the existing windfarm, is sufficient to lead to a significant cumulative landscape and/ or visual effect with a FiT turbine. While I can appreciate that single turbines can give rise to a gradual accumulation across a landscape, such as is the case in parts of rural Aberdeenshire for example, I do not believe that situation has yet arisen within SSA C. I do not therefore consider that the potential exists for Llandinam Repowering to generate significant cumulative effects in combination with individual FiT turbines within SSA B or C and consequently I also scope this out from further consideration in my Proof.

20 20 Potential grid connections 6.9 Turning to the matter of grid connections, it is relevant that I refer here to the Mott Macdonald study published in December This study identifies a range of potential grid connections in order to export power from windfarms in SSA B and SSA C that are before this Inquiry. The study considers how and whether connection to the national grid could be achieved using wooden pole 132kV overhead distribution connections, thereby avoiding the need for larger steel pylon towers with resultant greater landscape and visual impacts. A number of potential grid scenarios are identified, depending on the number and locations of windfarms that are assumed to be consented, together with their relative electricity generation capabilities It is evident from the Mott MacDonald study that considerable new grid infrastructure will be required if the generation targets for the strategic search areas are to be met. As presently proposed, SP Manweb intends to connect four of the proposed windfarms (excluding Llandinam Repowering) using 132kV circuits to a new National Grid substation to the west of Cefn Coch, which would connect to the national grid via a new 400kV steel transmission line. SP Manweb proposes that Llandinam Repowering would connect to an existing substation at Welshpool, via 132vK connection, which is before the Inquiry. This dedicated route from Llandinam Repowering would effectively use up all of the available capacity at Welshpool substation (90MW), although with further grid reinforcement in that area this capacity could be increased to 160MW. The Mott MacDonald study confirms at paragraph 3.3 that It is clear, therefore, that for more than 160MW of generation to be connected, additional transmission capacity if required in mid Wales The Mott MacDonald study summarises in Table 3.3 nine possible connection options for SSA B and C (1-8b), which are hypothetical given that only the Llandinam Repowering 132kV grid connection is before the Inquiry as a firm application. The Llandinam 132kV connection features as an integral part in eight of the nine options, indicating its relative importance in the overall grid connection possibilities. In order to visualise the options it is necessary to also review the LUC Study of December 2013, which undertakes a high level assessment of the likely routeing options in the Mott MacDonald study and also illustrates the options on a series of supporting figures Figure 8b in the LUC Study provides an illustration of the option that could have the

21 21 greatest landscape and visual effect of all of the options, therefore representing a worstcase scenario in my opinion. In addition to assuming a need for the Llandinam Repowering dedicated 132kV connection, this option assumes a new 400kV grid connection (up to 47m high with part over ground/ part underground routeing) from Lower Frankton to the new substation near Cefn Coch, with 132kV connections (wooden pole up to 14m high) from there to the proposed schemes in SSA B (Route BNC) and SSA C (Route CC1-4) (other than Llandinam Repowering) I have reviewed the potential routeing of the National Grid proposed 400kV infrastructure to the proposed new substation at Cefn Coch. With a separation distance of some 17km between Llandinam Repowering and the proposed substation, and an incrementally greater separation distance between the Development and the 400kV transmission line routeing as its heads north to Lower Frankton, I consider that there is no realistic potential for a significant cumulative landscape and/ or visual effect to arise from the addition of Llandinam Repowering to a baseline which contains the National Grid 400kV proposals. In my experience from assessing the effects of 400kV transmission lines, it is unusual for significant visual effects of the towers and transmission lines to arise at distances much beyond 1-2km from the lines, exceptionally to 2-3km. While I appreciate that cumulative effects can occur sequentially, along a route for example, the separation distance between the transmission line route and main road and rail routes in the area convinces me that Llandinam Repowering is unlikely to give rise to any significant landscape and visual effects with the 400kV infrastructure. On this basis, I exclude the National Grid proposals from further consideration in my Proof For the same reasons noted above, I also consider that the potential 132kV wooden pole BNC connection(s) between Cefn Coch and the SSA B (north) windfarms before this Inquiry (and indeed the BSC wood pole connection that is proposed to Carno III windfarm in SSA B (south)) are sufficiently distant and of sufficiently small scale that no significant cumulative interaction with Llandinam Repowering is likely in landscape and/or visual terms. These routes are shown clearly in Figure 3 in the separate LUC Graphics. However, given their closer proximity to the Development, I do consider that the Llandinam Repowering windfarm has potential to give rise to some significant cumulative effects with the proposed grid connections closer to and within SSA C, including the dedicated Llandinam Repowering 132kV connection and the potential SSA B to SSA C wooden pole connection across the Severn valley (CC 1-4) and serving Llaithddu, Llanbadarn Fynydd and potentially Neuadd Goch Bank windfarms. I assess the potential

22 significance of the cumulative effects of Llandinam Repowering when added to these proposed and potential grid connections in section 7.0 of my Proof. 22 Summary 6.15 I have reviewed the potential for significant cumulative effects to arise when Llandinam Repowering is added to other windfarms within SSA B and the proposed/ potential grid infrastructure that is before the Inquiry. In doing this I have had regard to the Mott MacDonald Study, the LUC high level environmental review of routeing options (the LUC Study) and the separate LUC graphics that have been produced for Session 4. I have also reviewed the 2008 ES; 2011 SEI and April SEI prepared for Llandinam Repowering. From this work and in applying my experience and professional judgement, I consider that there is scope to remove a considerable proportion of the proposed and potential infrastructure from further consideration in my evidence, on the basis that I do not consider that Llandinam Repowering has the potential to give rise to a significant cumulative effect when added to it. For the avoidance of doubt, I have found that Llandinam Repowering would not give rise to any significant effects when assessed in addition to any of the following potential developments: The proposed windfarms in SSA B which are before the Inquiry; The current National Grid proposals for a new substation near Cefn Coch and a 400kV transmission line connecting it to Lower Frankton; SP Manweb s potential 132kV wood pole connections to the SSA B windfarms before this Inquiry (BNC); SP Manweb s potential 132kV wood pole connection to Carno (BSC) The main reasons why I have been able to draw these conclusions include the following factors: The influence in landscape and visual terms from the existing Llandinam windfarm, which means that the additional contribution from the proposed Development in cumulative terms is not as marked as would be the case with a completely new windfarm; The separation distance between the Development and the other proposals, which reduces the potential for significant cumulative interactions to occur; The scale and visual influence of the grid connections which is more localised than found with windfarms, generally containing significant effects to within a maximum of 2-3km from the route.

23 I have identified that there is the potential for significant cumulative effects to arise with proposed and potential grid infrastructure closer to and within SSA C, from within a 10km range of Llandinam Repowering - where the Development has a more notable presence, and I assess this in the following section of my Proof. 7.0 ASSESSMENT OF POTENTIALLY SIGNIFICANT CUMULATIVE EFFECTS Introduction 7.1 Figure 1 in Appendix C to my Proof illustrates the potential grid connections within a 10km radius from Llandinam Repowering. As noted in section 6 of my Proof, I do not consider that the potential exists for Llandinam Repowering to give rise to significant cumulative effects with any of the potential grid infrastructure beyond this approximate range. I have overlaid SP Manweb s potential route (100m wide) corridor options for the 132kV connection between SSA B and SSA C (Mid Wales Connection CC 1-4) onto the plan and have also indicated the routeing of the proposed 132kV Llandinam grid connection. The plan shows the cumulative Zone of Theoretical Visibility (ZTV) of Llandinam Repowering in combination with the potential and proposed grid infrastructure, with the ZTV for the latter being confined to 1km either side of the line/ route, being indicative of the maximum possible extent of significant landscape and visual effects for a grid connection of the scale proposed. 7.2 The findings of Gillespies landscape and visual assessment within the EIA of October 2013, for SP Manweb s Llandinam proposed 132kV grid connection are helpful to the Inquiry, in that the landscape and visual assessment gives a good indication of the potential magnitude and significance of effect from a 132kV heavy duty wooden pole line in the mid Wales context. I have reviewed the findings of Gillespies assessment and have compared them with my own experience of a heavy-duty wooden pole line, in order to help calibrate my judgement of the potential for significant effects to arise from other possible grid connections of the same size and structure. It is relevant to record that the greatest distance at which a significant visual effect is recorded in Gillespies assessment is 630 metres from the proposed grid connection, in respect of VP 71 on the Kerry Ridgeway, attributed largely due to its elevated position relative to the line. In most of the viewpoints where significant visual effects were found, the separation distance is appreciably less, being within 400 metres. In my opinion, limiting the ZTV to 1km either side of the grid connection gives an appropriate and cautious indication of the potential maximum extent of