Mid Wales (Powys) Conjoined Public Inquiry (CPI) into. 5 wind farm Applications and a 132 kv Overhead. Culture and Heritage.

Transcription

1 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

2 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 A. Cumulative effects on Landscape

3 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

4 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.

5 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.

6 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

7 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.

8 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. To have overhead lines on pylons along this route would mean that no longer could it be considered a tourist route. Tourism in Powys is the single most important employer and anything that will adversely affect tourism will have a major and adverse cumulative effect on the local economy. A.2.9 At the eastern end of the Vyrnwy Valley near the border with England lies the Offa s Dyke National Trail as it passes through Carreghwfa (Llanymynech). As a National Trail known worldwide it is very popular with visitors. It is part of the local economy as walkers need overnight accommodation and local sustenance. The overhead line proposed could not have been routed any worse as far as walkers on the trail are concerned seeking to walk along an unspoilt historic border land. In this section between Llandysilio going north to Llanymynech the trail follows the Montgomery Canal which goes in a horse- shoe arc going west from Llandysilio before turning east at the Vyrnwy aqueduct to Llanymynech. Being raised on the valley sides the view from the canal is uninterrupted across the valley in the centre of which is proposed the route of the overhead lines. The lines will almost be at eye level and where the proposed lines cross directly over the canal at the aqueduct (Grade 11* listed) the visitor/walker will have pylons stacked either side in a row going west and east. A.2.10 While National Grid mentions that their proposal involves crossing Offa s Dyke Trail at this point (7) there is no acknowledgement of the loss of landscape value and visual amenity. This contrasts with the discussion that proximity of the Glyndwr Way at Meifod, was a reason for undergrounding the lines west of Meifod (8). While that is a good reason for undergrounding overhead lines, the fact that Glyndwr s Way is a minor less well known long distance trail in comparison to Offa s Dyke Trail means that it is even more important to underground the lines at Carreghwfa. Not to do so will add to the

9 cumulative devastation of landscape value and adversely affect the visual and sensory amenity caused by these overhead lines. A.2.11 Much investment has been made to date into renovating the Montgomery Canal and connect it to the national canal system. Final plans are being prepared to complete the relatively short missing section because the investment is seen as being a major boost to the local economy as and when the Montgomery Canal becomes part of the nation canal system. The canal route in total is considered to have one of the highest visual amenities of all canals and with the aqueduct at Carreghwfa crossing the River Vyrnwy, at that location it is considered a visual high point. The consequence of the proposed overhead line would damage the overall visual and sensory amenity of the canal as a tourist destination, a direct cumulative effect of the proposed overhead lines. A.3 River and floodplain landscape. A.3.1 The River Vyrnwy at Llansanffraid ym Mechain and Carreghwfa (Llanymynech) is on an important flood plain and has many meanders. Approximately 29% of the route corridor lies within areas of high flood risk 1:1000 years and 25% extreme risk areas 1:100 years (9). A.3.2 National Grid claim floodplain areas and river meanders of the River Vyrnwy are unavoidable across the preferred route corridor (10) and hence due to access restrictions, the river and the difficulties associated with constructing an underground connection through this section the preferred means of connection is by overhead line (11). From Waen Fach to Llanymynech the proposed overhead line would cross the River Vyrnwy 10 times and it is clear that National Grid wishes to dismiss and ignore the high Landscape Value of this section of the Vyrnwy Valley and its High Sensitivity to over head pylons because it has a problem with underground construction, flood risk and water resources in this area.

10 A.3.3 However National Grid could consider an alternative route which has no river crossings and a lower flood risk which would overcome the problem of flooding and the crossing of many river meanders between Waen Fach and Llanymynech. The alternative route would also be in line with modern thinking on flood prevention, a major consideration of this age, where meanders are to be encouraged and flood plains managed by avoiding any construction and use of concrete which encourages run off and flooding downstream. The alternative route would enable National Grid to take into account the value of landscape at Llansanffraid ym Mechain and Carreghwfa (Llanymynech). A.3.4 The National Grid Draft Route Report (Sept 2013) therefore expects visual receptors, i.e. the residents of Llansanffraid ym Mechain and Carreghwfa and all the visiting visual receptors of the Caravan Parks, should be denied their visual and sensory amenity because National Grid has chosen the wrong route for financial gain. Clearly National Grid has not considered the wider context of flood management long term and landscape sensitivity adequately and this is a direct cumulative effect of the proposed construction of wind farms in Mid Wales. A.3.5 A far more significant direct cumulative effect of wind farm development on areas like Llansanffraid ym Mechain and Carreghwfa (Llanymynech) will be the increased risk of extreme flooding. To cover upland Mid Wales with extensive areas of concrete for turbine bases and extensive stone road networks will increase the speed of rain runoff. Weather patterns are already more extreme and so such construction work on the uplands is totally contra- indicated. In fact hydrologist now recommends methods of retaining water in the uplands, which avoids concrete and stone construction, to even out the extremes of weather and protect communities downstream. A direct cumulative consequence of the proposed wind turbines up stream is for more extreme and prolonged flooding risk for the communities such as Llansanffraid ym Mechain and Carreghwfa (Llanymynech).

11 A.4 Summary and conclusion - Landscape A.4.1 In summary, the principal management recommendation given by Landmap on the visual and sensory amenity of the whole of the Vyrnwy Valley including Llansanffraid ym Mechain and Carreghwfa(Llanymynech) is to Maintain as existing. The cumulative consequence of the proposed overhead line would be to totally ignore this advice and devalue the established landscape value. A.4.2 The disturbing cumulative effect of the proposed wind farms for residents is the way National Grid believes it is entitled to disregarded local opinion, apparently make decisions contrary to guidelines and be inconsistent and illogical in reaching a conclusion. National Grid has placed greater concern on its own costs and profitability at the expense of the local residents who through no fault of their own face losses in several forms, with no right of recompense. This is clearly a direct and cumulative effect of the wind farm proposals.

12 B Cumulative effects on Culture and Heritage. B.1 Holford rule 2 states that proposers of overhead lines should choose routes which minimise the effects on the setting of areas of architectural, historic and archaeological interest including conservation areas, listed buildings and ancient monuments. Clearly the cumulative effects of overhead lines on not only the conservation areas, listed buildings and ancient monuments themselves but also their setting and environs are just as important. B.2 This is acknowledged by National Grid (12) and yet irrationally it proposes to ignore this by admitting that its proposal for an overhead line at Plas yn Dinas a scheduled medieval motte and bailey at Llansanffraid ym Mechain would have a severe adverse effect upon its immediate setting. There is sufficient stand- off from the monument for an underground connection to have negligible direct adverse effect (13). B.3 In another publication (14) National Grid state Numerous listed buildings throughout study area little difference between corridors. This is factually incorrect. It is a seriously misleading statement. To investigate this flawed statement, all the listed buildings and scheduled ancient monuments within the highlighted routes prepared by National Grid of Red North (Mathrafal to Waen Fach Section B), Red North (Waen Fach to Llanymynech Section C) and Red Central (Trefnannau to Llanymynech) were identified from public records using map references. The public records used were those prepared by CADW, kept at the Planning Offices of Powys County Council and they were cross referenced against the Clwyd and Powys Archaeological Trust data base.

13 The results are as follows: Table 1 Red North B Red North C Red Central Grade 11* Grade SAM B. 4 The section of the Vyrnwy Valley, so called Red North from Waen Fach to Llanymynech Section C including Llansanffraid ym Mechain and Carreghwfa (Llanymynech) has the highest number of listed buildings and scheduled ancient monuments in comparison to any other local section of proposed routes. Yet National Grid proposes to underground Red North B and place overhead lines at Red North C. The lack of consistency is quite remarkable and defies reasoning. B.5 The study by National Grid contains further errors and omissions. A single higher grade listed building (11*) is located on the north west slopes of the valley, whilst a second is located within Llansanffraid ym Mechain Conservation Area (15) The first grade 11* building mentioned is actually outside the proposed route and the grade 11* building claimed to be in the conservation area of Llansanffraid ym Mechain does not exist. However there are 3 grade 11* buildings not mentioned by National Grid which will be directly and adversely affected as the overhead lines will pass over two structures and very close to the third in Red North C. These grade 11* buildings have been totally overlooked by National Grid.

14 B. 6 Summary and Conclusion Culture and Heritage It is clear that the cumulative effect on the culture and heritage of overhead lines in the Llansanffraid ym Mechain and Carreghwfa section if the proposal by National Grid were to proceed would have the greatest adverse effect on these communities in comparison to other possible routes. National Grid has made a misjudgement and its inconsistency has resulted in worsening the cumulative effects in terms of Culture and heritage for the residents of Llansanffraid ym Mechain and Carreghwfa (Llanymynech). References 1. National Grid Draft Route Report. Sept p.115, National Grid Route Corridor and Substation Siting Study. March 2011 p National Grid Stage One Consultation Feedback Report. July 2012 p.107, National Grid Draft Route Report. Sept p.132, National Grid Stage One Consultation Feedback Report. July 2012 p.84, National Grid Draft Route Report. Sept p.115, National Grid Draft Route Report. Sept 2013 p.133, National Grid Draft Route Report. Sept p. 115, National Grid Draft Route Report. Sept p.77, National Grid Draft Route Report. Sept p.139, National Grid Draft Route Report. Sept.2013 p. 141, National Grid Stage One Consultation Feedback Report. July 2012 p. 305, / National Grid Draft Route Report. Sept p. 137, National Grid Route Corridor and Substation Siting Study. March 2011 p National Grid Draft Route Report. Sept.2013 p.133,