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Llaith Ddu WindfarmReview of Landscape and Visual Impact Assessment & Supplementary Environmental Information

June 2012

Client: Powys County CouncilIssue Date: June 2012

Llaith Ddu WindfarmReview of Landscape and Visual Impact Assessment& Supplementary Environmental Information

Project No: CG/6132 Doc Ref: CG/6132 Rev: A

Name Signature Date

Author Greg Vaughan June 2012

Checker Richard Bryan June 2012

Approver Greg Vaughan June 2012

Issue Record

Rev Date Description/Comments Author/Prepared by: Approved for Issue by:

A June 2012 Review of SEI Greg Vaughan Richard Bryan

“The report shall be for the private and confidential use of the clients for whom the report is undertaken and should not be reproduced in whole or in part or relied upon by third parties for any use whatsoever without the express written authority of the Consultant’

Contents

Llaithddu Wind Farm 30 May 2012

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Contents 1. Introduction 1

1.1 Purpose of study 1 1.2 Description of the study area 1 1.3 Methodology 1 1.4 Planning Policy Background 2 1.5 Description of the development 6

2. Appraisal Criteria 8 2.1 Source Information 8 2.2 Scoping 8 2.3 Clarity of report structure / approach / methodology 9 2.4 Description of the proposed development 9 2.5 Extent of study area / Zone of Theoretical Visual Interest (ZVI) 9 2.6 Baseline study, including landscape classification 10 2.7 Selection of viewpoints 10 2.8 Assessment of Landscape and Visual Impacts 11 2.9 Presentation / Accuracy of material 11 2.10 Completeness 12 2.11 Mitigation of effects 12 2.12 Cumulative effects 13

3. Appraisal of Landscape and Visual Impact Assessment 15 3.1 Grading 15 3.2 Scoping 15 3.3 Clarity of report structure/approach/methodology 16 3.4 Description of the proposed development 16 3.5 Extent of the study area/Zone of Theoretical Visual Interest (ZTVI) 17 3.6 Baseline study, including Landscape Classification (LANDMAP) 18 3.7 Selection of Viewpoints 19 3.8 Assessment of Landscape and Visual Impacts 21 3.9 Presentation and Accuracy of Material 25 3.10 Completeness 26 3.11 Mitigation of effects 26 3.12 Cumulative effects 27

4. Summary of Findings 29 4.1 Summary of findings 29

5. Conclusion 30

1. Introduction

1. Introduction 1.1 PURPOSE OF STUDY

Capita Symonds was commissioned by Powys County Council to undertake an appraisal of the Landscape and Visual Impact Assessment contained within the Environmental Statement submitted on behalf of the developer for the Llaithddu Wind Farm. This was submitted as part of a detailed planning application by Fferm Wynt Llaithddu Cyf in April 2008.

The objectives of this report are to:

• Review the current assessment in respect of its technical competence, assessment techniques, completeness and compliance with best practice.

• Review the magnitude and significance of the potential landscape and visual effects as assessed within the Environmental Assessment.

• Consider the appropriateness of the development. • Make recommendations for further study or information required from the

developer to form part of the planning application.

This report does not take into account any assessment relating to the off-site access routes to the proposed development site. These are the subject of a separate report.

1.2 DESCRIPTION OF THE STUDY AREA

The study area is centered on upland areas around 8km to the southwest of Newtown, Powys, including Brondre-fawr Hill and Garn Fach. The study area extends to a radius of 35km. The area comprises a dissected plateau landscape, with various watercourses ‘cutting’ into the landscape. In the north, these generally run eastwards towards the River Ithon, whose valley is followed by the A483 road from Llandridnod wells to Newtown, where the River Ithon then joins the Severn. In the south, the drainage leads west via the River Marteg towards the Wye. The topography elsewhere within the study area is diverse, ranging from the lower-lying broad river valleys of the Severn and Wye, to the smooth rolling upland summits and foothills of the Cambrian Mountains. To the western edge of the study area lies the distinctive craggy peak of Plynlimon, rising to 752m AOD. The Snowdonia National Park boundary lies along the northern western edge of the study area, approximately 32km away. The Shropshire Hills AONB lies around 12km to the east. An existing windfarm, referred to as the P & L development, exists to the immediate northwest of the site area.

1.3 METHODOLOGY

The following tasks were carried out as part of this report:

• A review of current guidance. This was undertaken to establish an accepted and consistent approach to the assessment of onshore windfarm


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developments. The documents reviewed and key criteria extracted are summarised in section 2.

• A desk based appraisal of the LVIA. This was considered against key criteria established from the current published guidance and best practice as well as relevant planning policy documents. A grading system (based on IEMA guidance) has been incorporated and is outlined within section 3.

• A site based visual assessment. This was carried out by a Chartered Landscape Architect. A selection of the agreed viewpoints used within the submitted Landscape and Visual Assessment were visited and independently considered. This was undertaken in January 2009. Weather conditions were mixed but not untypical for the time of year.

• Photographs, wire frames and photomontages were tested for accuracy. Comparative photographic material, sections and other methods were used.

1.4 PLANNING POLICY BACKGROUND

The following planning national policy documents are relevant to this study:

• Planning Policy Wales (March 2002) The study area adopted by the Llaithddu Assessment extends over an area of

3846km2 and this includes the southern edge of the Snowdonia National Park. This is the highest status of landscape designation in England and Wales. Planning Policy Wales states that the statutory purposes of National Parks are ‘to conserve and enhance their natural beauty, wildlife and cultural heritage and to promote opportunities for public understanding and enjoyment of their special qualities.’ The document also states that they ‘must be afforded the highest status of protection from inappropriate developments…..whether those activities lie within or outside the designated areas.’

The boundary for the Snowdonia National Park lies around 32km from the proposed development.

• Ministerial Interim Planning Policy Statement (MIPPS) – Planning for

Renewable Energy The MIPPS replaces Sections 12.8 to 12.10 of Planning Policy Wales and sets out the context for sustainable energy and the commitment within Wales to achieve its specific targets for renewable energy production. It states that ‘Renewable energy projects should generally be supported by local planning authorities provided environmental impacts are avoided or minimised, and nationally and internationally designated areas are not compromised.’

Focusing in particular on wind development, the MIPPS states that ‘in the short term, wind power offers the greatest potential for an increase in the generation of electricity from renewable energy.’ The statement continues, ‘The Assembly Government accepts that the introduction of new, often very large, structures into the open countryside needs careful consideration to minimise the impact on the environment and landscape. However, the need for wind turbines is established through a global environmental imperative and international treaty, and is a key part of meeting the Assembly Government’s target for renewable energy production.’


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The statement endorses the approach of TAN 8, and the identification of Strategic Search Areas (SSA’s) as described below.

• Technical Advice Note 8

TAN 8 was published in July 2005 by the Welsh Assembly Government and is the key document driving the delivery of renewable energy policy in Wales. The note states that large scale (over 25mW) onshore wind developments should be concentrated into particular areas defined as Strategic Search Areas (SSA’s). Allowance has been made for local planning authorities to undertake refinements to guide and optimise development within SSA’s.

The note states that ‘SSA’s should display the following characteristics. They are:

Extensive areas with a good wind resource. Upland areas (typically over 300m AOD) which contain a dominant

landform that is flat (plateau) rather than a series of ridges. Generally sparsely populated. Dominated by conifer plantation and/or improved/impoverished moorland. Has a general absence of nature conservation or historic landscape

designations. Of sufficient area to accommodate developments over 25MW, to achieve

at least 70MW installed capacity and to meet the target capacity. Largely unaffected by broadcast transmission, radar, MOD Mid Wales

Tactical Training Area (TTA) and other constraints.

Documents and policies at a County level that are relevant to this study include:

• Interim Development Control Guidance (IDCG) on Onshore Development (draft)

This document supplements the Powys Structure Plan and the emerging Unitary Development Plan (UDP) on the development of windfarms. The IDCG refines the SSA’s contained within Powys’ administrative boundaries, and provides further guidance and advice on how the Local Planning Authority will deal with applications for planning permission.

• Powys County Structure Plan (Replacement) Adopted February 1996

The following policies are of relevance to this study • POLICY E20 – Renewable Energy Sources. This policy allows for

renewable energy sources providing that: a) There are no unacceptable planning, access, service,

environmental or amenity problems; b) The proposals would not have any unacceptable adverse effects

on….sites of conservation interest; c) The proposals would not have any unacceptable adverse effects

on ….the Special Landscape Areas. • POLICY EC5A: Landscape Features. This policy states that ‘development

proposals which ….adversely affect, directly or indirectly, landscape features which are of major importance…will only be permitted provided it can be shown that the reasons for the development clearly outweigh the


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need to retain the features and that mitigating measures that are within the control of the developer will be provided which would reinstate the integrity or continuity of the features.’

• POLICY EC15: Ancient Monuments. This policy states that ‘development will not…be permitted on sites of scheduled ancient monuments….in exceptional circumstances, permission may be granted…providing that:

a) There are no overriding local archaeological reasons for the preservation of the sites intact

b) Adequate provision has been made in the proposals for the excavation, recording and/or protection of archaeological features…..

c) Any amenity value of the site is preserved and ….enhanced.’ • POLICY EC16: Sites and Landscapes of Archaeological or Historic

Interest. This policy states that ’development proposals that would have unacceptable adverse effects for sites, features and landscapes of archaeological and/or historic interest and their settings …will not normally be permitted, especially on sites of national importance.’ The description further states that assessments and mitigation proposals would be necessary to allow such development.

• Radnorshire Local Plan (1999) The following policies are of relevance to this study:

• POLICY REC 17: Wind Energy. This policy states that wind power proposals will be permitted provided that they do not ‘…have any unacceptable adverse effects upon Radnorshire’s Landscape and:

a) The special landscape areas (SLA’s) in accordance with policy REC6

b) Historic Landscapes, Parks and Gardens in accordance with policy REC7’

The policy also states that ‘the scale and cumulative impact of the proposed development, when considered in the context of other existing or proposed windfarm developments, shall not have unacceptable adverse effects on the landscape….or on the surrounding area and occupants of nearby properties in terms of noise, privacy, reflected light, visual dominance, shadow flicker…’ Furthermore, the policy states that existing rights of way should be protected in accordance with policy RT8 and that all associated cables should be laid underground subject to conservation and archaeological interests.

• POLICY REC 15: Ancient Monuments of National Importance. This policy states that ‘development proposals on or adjacent to scheduled ancient monuments or nationally important archaeological remains…..will not be permitted where they will have an unacceptable adverse effect on the remains or its setting. In exceptional circumstances, where there are no overriding local archaeological reasons for the preservation of the site insitu and the benefits of the development outweigh those of preservation, planning permission will be granted.’


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• The Powys Unitary Development Plan: Deposit Draft October 2004 The following policies are of relevance to this study:

• POLICY GP1: Development Control. This states that ‘development proposals will only be permitted if they take into account….the design, layout, size, scale, mass and materials of the development’. These ‘shall complement and where possible enhance the character of the surrounding area.’ In addition ‘the amenities enjoyed by the occupants of nearby or proposed properties shall not be unacceptably affected by levels of noise, light, dust, odour, hours of operation or any other planning matter.’

• POLICY SP 3: Natural, Historic and Built Heritage. This is an “overarching” policy, which underlines the Council’s commitment to maintaining the environmental quality of Powys for the enjoyment of present and future generations, and seeks to attain the above by safeguarding, protecting and conserving the natural and built environment. The policy states that ‘in order to safeguard the natural heritage of Powys, development proposals will be expected to take account of the need to protect, conserve and ….enhance sites and features of importance for their aesthetic, amenity …value.’

• POLICY ENV 2: Safeguarding the Landscape. This policy is concerned with maintaining the distinctiveness of Powys’ landscape safeguarding the quality of its environment and ensuring the economic well being of the area. The policy states that ‘Proposals…should take account of the high quality of the landscape in Powys and be appropriate and sensitive to the character of the surrounding landscape. Proposals…should contain appropriate measures to ensure satisfactory integration into the landscape.’

• POLICY SP12: This overarching policy states that ‘appropriate proposals for energy generation from renewable sources will be approved providing that they meet the landscape….and other requirements set out in the other policies of this plan.’

• POLICY E3: Wind Power. The policy is aimed at striking a careful balance between the pressing need to combat climate change through renewable energy measures and the need to protect a valued and attractive landscape. The policy states that the council will approve applications….’where:

1 They do not unacceptably adversely affect the environmental and

landscape quality of Powys, either on an individual basis or in combination with other proposed or similar developments. Where the cumulative impact of proposals in combination with other approved or existing windfarms would be significantly detrimental to overall environmental quality they will be refused.

2 They do not unacceptably impact upon….features of conservation… interest.

3 They do not unacceptably adversely affect the enjoyment and safe use of …public rights of way network, especially bridleways…

4 They would be capable of being served by an acceptable means of highway access and any new or improved roads and accesses required would not have unacceptable environmental impacts.


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5 Applicants are able to demonstrate….that there would be adequate mitigation or compensation for any adverse impact on environmental quality…

6 Any ancillary structures or buildings are so sited and designed so as to adequately blend into their setting.’

• Footpaths/Access

The study area is rural and relatively sparsely populated throughout. However, there are extensive areas of access land (i.e. land which is normally available for access under the Countryside and Rights of Way Act 2000), footpaths, bridleways and roads. Of particular significance strategically are: • Glyndwr’s Way. This long distance footpath extends east to west with its

nearest point reached around 4-5km to the west and 7-8km to the east of the site area.

• Jack Mytton Way; • Mortimer Trail; • Offas Dyke; • Severn Way; • Shropshire Way; • Wye Valley Walk; • Kerry Ridgeway Walk; • The Herefordshire Trail; • Teifi Pools Walk; • National Cycle Route’s 8 and 81 extending east to west through the study

area. Of note locally are: • Bridleways extending through and around the proposed development site.

Of particular note is bridleway AC410 and LD756 extending along the route of the southern alignment of turbines. To the north LD106 runs along the alignment of the northern turbines. These will require realignment. Other bridleways also be significantly affected as outlined in section 6.246.

• Footpaths extending through and around the proposed development site. In particular, LM107 will be significantly affected as it rises to turbine 3.

1.5 DESCRIPTION OF THE DEVELOPMENT

The proposed windfarm development will contain:

• 15 turbines at 80m hub height and 14 turbines at 64m hub height. This gives a maximum height to vertical blade tip of 115.5m and 99.5m respectively.

• In-site access tracks providing access from the highway and running between the turbines. These will have a finished width of 5m and 7m on bends, and will be constructed with a compacted stone surface around 500mm depth.

• Concrete crane hardstanding areas, with dimensions around 30x40x1.2m. • 2 permanent anemometer masts 64 and 81m in height, with concrete bases

and guy wires. • Underground cable trenches, generally following the route of internal access

tracks around 1x0.9m dimensions.


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• Single storey substation and control room around 15x5x5.4m. Wall finishes are described as stone masonry. Roof materials have not been specified.

• Temporary construction compound and turning area approximately 50x50m in dimension. This would contain temporary buildings, materials storage and parking for site based and incoming vehicles. Temporary fencing will enclose the area.

The construction period is anticipated to extend to around 24 months, depending on weather and ground conditions encountered.

2. Appraisal Criteria

2. Appraisal Criteria 2.1 SOURCE INFORMATION

The following guidance has been reviewed:

• Guidelines for Landscape and Visual Impact Assessment, Second Edition (2002). The landscape Institute/Institute of Environmental Management and Assessment.

• Use of Photography and Photomontage in Landscape and Visual Assessment. (August 2008). Landscape Institute Advice Note 01/04.

• Visual Assessment of Windfarms – Best Practice (2002). Scottish Natural Heritage Commissioned Report F01AA303A.

• Cumulative Effect of Windfarms, (Version 2 – May 2005). Scottish Natural Heritage Commissioned Report.

• Visual Representation of Windfarms – Good Practice Guidance. (March 2006). Scottish Natural Heritage Commissioned Report.

• The Visual Issue – An investigation into the techniques and methodology used in windfarm computer visualisations. April 2007. Architech Animation Studios (UK).

• Best Practice Guidelines for Wind Energy Development. (1994). British Wind Energy Association.

• Guidelines for the Environmental Impacts of Wind Farms and small Scale Hydroelectric Schemes. (Scottish Natural Heritage, Feb 2001).

• Environmental Statement Review Criteria. Institute of Environmental Management and Assessment.

It is clear from reviewing these and other documents that there is a wide and diverse range of opinions on issues relating to the landscape and visual impact assessment of windfarms. Furthermore, many of the guidelines appear to be based on smaller first generation turbines and need to be updated for the second and third generation models currently being advocated, such as for the proposed Llaithddu development. This study recognises that it is the primary responsibility of the landscape professionals carrying out assessments to ensure that the approach and methodology adopted is appropriate for the particular development to be assessed. However, it is also recognised that the perception of the visual effects of windfarms can often be subjectively presented depending on particular interests relating to the development. As a basis to review the Llaithddu Landscape and Visual Assessment and to pass comment on its consistency, credibility and effectiveness, we have compiled criteria that we believe meet with our interpretation of best practice and available guidance. These are listed and explained below:

2.2 SCOPING

A comprehensive scoping exercise should be carried out with statutory and non-statutory bodies prior to the assessment to ensure that the extent of the study area is agreed, any sensitive issues addressed and a consensus obtained on terms of


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reference, methodology and assessment techniques. National designations, such as the Snowdonia National Park, indicate potential for significant effects. Sites within or adjacent to such landscapes require detailed and rigorous assessments that are appropriate to the status of the landscape. The scoping process should also include community consultation, in order to gather specific information about the site and to canvass the views of the public on the proposed development. It can be a valuable tool in seeking understanding and agreement about key issues and can highlight local interests and values, which may otherwise be overlooked. The Environmental Statement should provide a clear summary of the responses gained through the scoping exercise. It should clearly identify those aspects of the environment that are likely to be significantly affected by the development and provide an evaluation of impacts where possible. Where issues raised by the consultees are not to be addressed in detail by the Environmental Statement, a reasoned justification for their exclusion should be given.

2.3 CLARITY OF REPORT STRUCTURE / APPROACH / METHODOLOGY

The report should be structured and organized to ensure that the key issues of relevance are addressed. It should use clearly defined and agreed terminology throughout, and particularly when defining the sensitivity of landscape and visual resources, magnitude of predicted effects and their significance. The methodology should be appropriate for the nature, location and scale of the project and potential sensitivity of the site, as established through scoping. This should be clearly outlined within the introduction to the section and should acknowledge any deficiencies or limitations of data, techniques or resources that may have constrained the assessment.

2.4 DESCRIPTION OF THE PROPOSED DEVELOPMENT

The assessment should include a clear, concise description of the development through the lifecycle of the project as well as consideration of alternatives. Any mitigation measures should also be outlined. The description should be accompanied by simple, easy to read proposal maps/plans at A3/A4 size, together with cross sections and other drawings.

2.5 EXTENT OF STUDY AREA / ZONE OF THEORETICAL VISUAL INTEREST (ZVI)

The area of study should theoretically extend to include the entire visual envelope. However in practice this may be reduced in agreement with the regulatory authority, providing that sensitive issues are adequately addressed and any reduction is dependent on the distance from the proposed development within which the view is expected to be of interest or concern. A ZVI should be used, superimposed on a 1:50000/1:10000 map. This should assess the degree of visibility based on the numbers of turbines visible at least to the maximum height and if possible based on nacelle/hub height and on total height. The ZVI should be tested and verified by desk and field study and the results should be described. The data used to calculate the ZVI should be adequately described and the distance selected for the outer limits should be justified. The existence of


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error should also be acknowledged and if possible the errors should be assessed and discussed. Table 1 outlines the recommended distances for ZVI’s based on the height of turbines. This indicates that a ZVI of at least 30km is required for turbine heights of 100m.

Table 1: Recommended ZVI distances based on height of turbines. (source: Visual Assessment of Windfarms – Best Practice (2002). Scottish Natural Heritage Commissioned Report F01AA303A. Height of turbines (total including rotors) (m)

Recommended ZVI distance (km)

50 15 70 20 85 25 100 30

2.6 BASELINE STUDY, INCLUDING LANDSCAPE CLASSIFICATION

This forms the basis from which the occurrence, estimation of magnitude and significance of the landscape and visual effects of the development may be identified and assessed. The assessment must describe the current condition of the landscape and provide a visual appraisal of the study area. It should include an identification of those landscape elements and characteristics that are valued and the people by whom they are valued. Nationally designated landscapes require special attention, including a description of the distinctive attributes and characteristics that justified the original designation. The landscape should be classified into units or groups of distinct and recognizable type and character. LANDMAP has been used extensively in Wales in recent times and should form the basis of this element of the assessment. This is reinforced by Planning Policy Wales (2002), which advocates the use of Landmap as the basis of a consistent all Wales approach to landscape assessment. The baseline assessment should identify the physical attributes of the surrounding landscape, including topography, vegetation and drainage. Specific sensitive receptors should be identified. Appropriate plans should be included to show landscape character areas within the ZVI, photographs showing the typical appearance of the landscape and as well as a plan showing key issues.

2.7 SELECTION OF VIEWPOINTS

Key points relating to selection of viewpoints are as follows:

• Viewpoints should be selected to give a true representation of visual impacts upon residents, visitors, travelers through the area and other interest groups; viewpoint selection should follow a consultation exercise with interested parties and the statutory authorities included in 2.1 above.


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• Publically accessible areas, such as footpaths, bridleways and common land should be used wherever possible. The choice of viewpoints should be justified and the location and precise direction of view shown on an accompanying map.

• The selection should aim to achieve an effective assessment of two distinct considerations: (1) Significant sensitive viewpoints and (2) Representative viewpoints. This will enable a balanced overall view to be gained.

• Viewpoints used to verify the accuracy of any ZVI should be distinguishable from those used to assess potential sensitivity and significance. Viewpoints used as part of any landscape assessment should be clearly distinguished from those used as part of the visual assessment.

• All viewpoints should include information relating to precise locations (including OS grid reference points), orientation to the proposed development, date, time of day and weather conditions.

• The selected viewpoints must not underestimate the visual effect by the judicious positioning of screening objects or landforms.

• Information on lens type, focal length and use of panoramic images must be provided.

2.8 ASSESSMENT OF LANDSCAPE AND VISUAL IMPACTS

The two principal criteria determining significance are magnitude and sensitivity. However, there is no standard methodology or guidance for the quantification of scale or magnitude of relative effects. This will be based on the experience and professional judgement of the assessor and the use of well defined criteria on which to base any judgement. A balanced and well-reasoned evaluation of magnitude and sensitivity of the receptor is therefore essential. It is also imperative that the assessment report should include a detailed rationale for the basis upon which all sensitivity, capacity, magnitude and significance evaluations have been made. Distance should not be used mechanistically to predict magnitude at a particular viewpoint because of the potential effects of other modifying factors. Other factors such as mobility should be taken into account. Significance is not absolute and can only be defined in relation to each development and its location. It is for each assessment to determine the assessment criteria and the significance thresholds and criteria, using informed and well reasoned judgments supported by thorough justification for their selection. An explanation of how the conclusions have been derived on the significance of each effect should be provided.

2.9 PRESENTATION / ACCURACY OF MATERIAL

The report should be concise and logical in its layout. It should include a:

• Clear description of the basic elements of the development; • Good understanding and description of landscape constraints and

opportunities; • Systematic identification and evaluation of potential effects, including

reasoned criteria and judgments for evaluations; • Measures to address effects.


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It is important that the overall approach uses a transparent, structured and replicable procedure so that others can test and confirm the accuracy of what has been presented. It should be a balanced document, providing an unbiased and impartial account of the effects with reasoned and justifiable arguments. Illustrations including plans, photographs, photomontages and wireframes should be included as appropriate. Photomontages / wireframes require the following to be stated:

• Precise locations and dimensions of the development; • Other features forming reference points in the view; • Precise location, viewing distance and height from which the photo was taken; • Lens focal length and camera format; • Inclusion of other windfarm developments (as outlined in item 11.Cumulative

effects below)

Guidance from the Landscape Institute on photographic material to be used in assessments is for the use of ‘a single lens reflex camera utilising a 50mm lens in a 35mm format camera (or its digital equivalent)’. It is considered that a single frame photo (based on an SLR/50mm focal length lens (or digital equivalent)) is highly unlikely to convey the amount of contextual information required. Panoramas should be produced by splicing standard photographs rather than specialist cameras to minimize distortion, although care needs to be taken to ensure that the field of view is not unrealistically wide. Generally it is considered that an image height of approximately 20cm is required to give a realistic impression of reality and it is important that photos are not reduced in scale to fit on an A3 sheet or conversely enlarged. This is likely to portray an unrealistic impression of the development, with the perception of the effects of the development as either lower or greater in magnitude. Wireframes should also be used as appropriate. These are generally considered preferable to montages because they reduce the risk of implying a false realism. The limitations of photomontage should be recognised and acknowledged especially a tendency for montages to underestimate the actual appearance of a windfarm in the landscape.

2.10 COMPLETENESS

Recommendations for additional material/information will follow in subsequent sections of this report.

2.11 MITIGATION OF EFFECTS

It is accepted that mitigation of the effects of windfarm developments will be difficult due to the sheer size of the turbines and the often open and expansive nature of the surrounding landscape. The assessment should, however, display evidence of the consideration of different approaches in terms of scheme design, or size/scale/orientation of the proposed development. Alternative site layouts, access and servicing arrangements should be an important approach to ensure sensitive siting in the landscape. An important issue will be how turbines relate to the visual horizon. Where possible, turbines


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should be located back from plateau edges and skylines and the proposed materials and design of the built structures may aim to camouflage/disguise their impact through appropriate coloured finishes (usually an off white/grey). It is also considered that large developments are more suited to open larger scale landscapes and mitigation may require a reduction in the number, spacing or size of the turbines. Cumulative impacts should also be considered (as below), and consideration should be given to the design and finish of any neighbouring windfarm development. A viewer’s eye tends to be drawn to the skyline. Where an existing windfarm is already prominent on a skyline, the introduction of additional structures along the horizon may result in a development that is proportionally dominant. The proportion of developed to non-developed skyline is an important consideration and mitigation may be required to address such issues.

2.12 CUMULATIVE EFFECTS

Cumulative effects result from changes to the landscape or visual amenity caused by the proposed development in conjunction with other developments (associated with or separate to it) or actions that occurred in the past, present or are likely to occur in the foreseeable future. The focus of the cumulative assessment should be the proposed windfarm. It should consider the effects of the proposal in combination with:

• Existing development, either built or under construction; • Approved development awaiting implementation; • Proposals awaiting determination within the planning process.

The nature of the effects will consist of:

• Combined visibility, where the viewer is able to view two or more developments from one viewpoint. The assessment should consider the combined effect of all windfarms visible. This may be in combination (several windfarms are within the observers arc of vision at the same time) or in succession (where the observer has to turn to see the various windfarms).

• Sequential effects. These occur when the viewer has to move to another viewpoint to see different development and should be considered for travel along regularly used routes like major roads or popular paths. Sequential effects may range from frequently sequential (the features appear regularly and with short time lapses between, depending on speed of travel and distance between the viewpoints) to occasionally sequential (long time lapses between appearances, because the viewer is moving very slowly and/or there are large distances between the viewpoints).

• Perceived effects. These may arise when 2 or more developments are present but one or more is never seen by the observer, either because they are screened, or the observer is unable or unwilling to gain a viewpoint from where they would be seen. The observer is aware that other developments are present because, for example, they may have learnt about them or seen signs to them. This effect may be significant, but can also be mistaken, where the observer’s information or interpretation of it is wrong.

The significance of impacts will vary depending on the:


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• number and sensitivity of visual receptors; • duration, frequency and nature of combined and sequential views (glimpsed,

prolonged views, oblique, filtered, direct, time separation between views); • relative visual impact of each individual windfarm.

The assessment of cumulative landscape and visual impacts requires:

• A base plan, showing all existing, consented or publicly proposed windfarms within range of the proposed windfarm. As zvi analysis is normally undertaken out to 30km from the development, it is recommended that this base plan includes all proposals out to 60km from the proposed windfarm, so that any potential cumulative effects towards the edge of a 30km zone of influence can be identified.

• ZVI analysis, identifying separately the areas where 2, 3 or more windfarms would be visible.

• Selecting appropriate viewpoints at which to assess the nature and significance of combined visibility effects, and appropriate routes or journeys through the area for which to assess sequential visibility effects.

• Appropriate photomontages and or wireframes to illustrate the nature and degree of effects. For installed or consented windfarms and as yet undetermined planning applications, the turbines from the previously submitted layout drawings should be shown on the photomontage and/or wireframe views (in addition to those turbines proposed). The drawings should be clearly annotated to interpret the different proposals. The dimensions of the ‘existing’ turbines should also be clearly stated.

• A description and assessment of the effects.

3. Appraisal of Landscape and Visual Impact Assessment


3.1 GRADING

The Landscape and Visual Assessment has been reviewed against the criteria listed within section 2 and a grading system applied. This is outlined below:

A Excellent, no tasks left incomplete. B Good, only minor omissions and inadequacies. C Satisfactory, despite omissions and inadequacies. D Parts well attempted, but must as a whole be considered unsatisfactory

because of omissions and/or inadequacies. E Poor, significant omissions or inadequacies. F Very poor, most tasks left incomplete.

3.2 SCOPING

Information within the Assessment relating to the scoping is limited and outlines that sensitive receptors and representative viewpoints were determined following pre-application consultations with the DTI, Planning Authority and other relevant parties. Further information is provided within Section 4 and provides a scoping report, which was submitted in June 2006. The scoping report sets out the development proposal, EIA methodology and technical assessments to be undertaken. It also includes a list of Consultees within the appendix 5 of this section and this includes (amongst others):

• CADW • Powys County Council • Countryside Council for Wales

Responses to this scoping report are included within Appendix 4.2. Responses from PCC and CCW have either not been received or are not included. It is noted that a response from CADW requests that the setting of the Scheduled Ancient Monuments affected (RD 039 Fowlers Armchair and Round Cairns) are given due consideration. It states that these are publicly accessible and can be viewed from adjacent rights of way. Furthermore, it requests that at least one viewpoint showing the scheduled site in relation to the proposed turbines is provided. This is included within Section 8 Historic Environment, and is further discussed in section 3.7 below. However, we do not feel that this particular issue has been explored adequately and would suggest that further consideration is given, including additional viewpoints. Other limitations noted with regard to this section include the following:

• The list of consultees does not include Natural England or Snowdonia National

Park. These bodies possess responsibilities relating to the Shropshire Hills AONB and the Snowdonia National Park. In particular, with regard to the


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AONB, key viewpoints should be agreed with Natural England given the relatively short distance of this sensitive area to the development.

• It is unclear as to the level of involvement that PCC have had in the development of the ES and whether the scope has been formally agreed. Paragraph 2.53, describes meetings held with PCC and subsequent changes to the design to take account of feedback from these meetings. Further clarification is, therefore, required on this issue.

• It is unclear as to the level of involvement that statutory or other consultees have had in the selection of viewpoints. Paragraph 6.84 of the assessment states that these have been chosen in consultation with the Local Authority. No other bodies or interests are mentioned.

• A summary of the responses gained through the scoping exercise has been provided but is limited in relation to landscape and visual issues.

• Paragraph 4.119 of the Scoping Report outlines a commitment to public consultation, via public exhibitions, circulars and a web site. However, there is limited information on the nature and content of the material exhibited and we are unaware of any subsequent consultations. We are unable to assess the accuracy and value of this exercise to the assessment process. Similarly there is limited mention of any local interests and values of relevance within the ES that may have been obtained through the consultation.

This section has been assessed as poor, with significant omissions or inadequacies evident and is graded as D.

3.3 CLARITY OF REPORT STRUCTURE/APPROACH/METHODOLOGY

The report is generally well structured and organized. It uses clearly defined and agreed terminology throughout and provides good definitions of the relevant criteria and resulting assessments. The methodology is clearly set out and logical and appears appropriate to the scale and nature of the project. The approach adopted appears to be good, with only minor omissions and inadequacies evident and is graded as B.

3.4 DESCRIPTION OF THE PROPOSED DEVELOPMENT

The assessment includes a good description of the proposed development through its lifecycle, including decommissing. Alternative options have been considered at three levels, comprising strategic site selection, design development and changes to the scheme design following consultations and exhibitions. Sections 2.43 to 2.56 describe the process followed from an initial design submitted as part of the scoping report, through the production of a draft final design. The latter took account of environmental information produced by the consultants preparing the EIA. In particular, it is stated within paragraph 2.51 that the turbines within the southern section of the site, at Brondre-fawr Hill, were reduced in height to mitigate visual effects to properties to the south. Other changes mentioned include altering the position of turbines in relation to existing bridleways, thereby minimising the proliferation of tracks through coinciding access routes with existing public rights of way.


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The assessment also states that the siting of turbines has been agreed with Clwyd Powys Archaeological Trust (CPAT). This is of relevance to issues relating to Fowlers Armchair. The reduction in height of the turbines 15 and 17-29 along the main ridgeline of Brondre-fawr Hill to enable a reduction in consequent visibility upon the various receptors to the south appears to be a sensible response to the visual constraints. Concern regarding visual impacts from this area is shared by the ‘Revised Tan 8: Annex D’ study, ranks Brondre Fawr Hill as fourteenth out of fifteen on overall visual effects. Elsewhere, Turbines 1-14 to the north of the scheme are sited below and to the east of the main ridgeline of Waun Ddubarthog. This area is visually less sensitive. The initial design layout is included within section 4 and formed part of the scoping report submitted in June 2006. A preliminary ZVI for this arrangement is also included and has been compared to the ZTVI for the current layout. It is noted, however, that visibility for the current arrangement is greater to the north-west than the initial layout and broadly similar elsewhere. We are unable to note any significant reductions in visibility across the ZVI up to the 30km limit provided for the preliminary layout. Whilst it is clear that the design has attempted to take account of visual issues during the evolution of the layout, we are unable to confirm that the assessment demonstrates any significant benefit from the decision to reduce the height of the turbines to the south. The development is illustrated by figures 2.1-2.6 and 3.2-3.9, including plans, sections and elevations of the main elements. These have been produced to an acceptable standard. An indicative programme for the construction works is provided as Figure 3.1, together a methodology for construction. These have been prepared to a good standard. The approach adopted appears to be good, with only minor omissions and inadequacies evident and is graded as B.

3.5 EXTENT OF THE STUDY AREA/ZONE OF THEORETICAL VISUAL INTEREST (ZTVI)

The assessment includes ZTV’s at both blade tip height and hub height extending to a range of 35km, as shown on figures 6.8 and 6.9. This includes large areas of the Shropshire Hills AONB, the Cambrian Hills to the west and the south-eastern edge of the Snowdonia National Park. A 1:155,000 scale plan has been adopted at A3 size. The degree of visibility is based on the numbers of turbines visible. A comparison of the viewpoints to the ZTV confirms that this is generally accurate. The methodology adopted for the production of the ZTV is included in Appendix 6.1. The assessment includes cumulative ZTV’s for existing, planned and committed windfarm developments. It is noted, however, that the adjoining development, comprising the replacement of the P & L Windfarm at Llandinam, has not been taken into account. This is a significant omission and is discussed in more detail in section 3.12. Overall it is considered that the study area and ZTV adopted for this assessment is acceptable.


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The approach adopted appears to be good, with only minor omissions and inadequacies evident and is graded as B.

3.6 BASELINE STUDY, INCLUDING LANDSCAPE CLASSIFICATION (LANDMAP)

The baseline description provided includes:

• Baseline 1: Planning Policy Framework. This provides an account of landscape related planning policy at a national, regional and local level. Key designated areas and policy zones are illustrated on figure 6.4. The planning base line provides a discussion relating to the ‘Revised Tan 8: Annex D’ study, justifying the location of the application site as being predominantly within the modified SSA C boundaries. The findings of this study are further used within section 6.160 to justify the application site, highlighting the low sensitivity and high capacity of sub-areas C10-12 (ranked within the top four). The report acknowledges that Bronde-fawr Hill (sub-area C8) is ranked further down the list (tenth out of fifteen). However, it is noted from the Annex D report that, based on overall visual effects, Brondre Fawr Hill is ranked as fourteenth out of fifteen. This aspect is not mentioned within the assessment. As a summary, this section broadly acknowledges key criteria of landscapes to be considered for inclusion in the refined SSA’s, as well as other planning guidance issues relevant to the consideration of landscape and visual effects.

• Baseline 2: Description of Site and Surrounding Area. This section provides a description of the site and its context, in terms of its physical qualities. Sections are included on Landscape Context, Landform and Vegetation, Settlement and Recreation and Heritage. It is noted that the assessment fails to consider both the Caersws and Clywedog Historic Landscapes, although they are included within the Historic Environment Section of the EIA. Although advisory and non-statutory, landscape and visual impacts on these areas should be a significant consideration and will need to be explored by the assessment. This is reinforced by Tan 8 Annex D report within section 4.4.1, which states that ‘the Caersws Basin has been of exceptional strategic and historical importance in Wales.’ Whilst it is accepted that a large proportion of this area is outside the ZTV, the sensitivity of this area needs to be acknowledged and considered.

• Baseline 3: Landscape Character. This section characterises the landscape into aspect areas based on LANDMAP data, where available, within Wales and using recent landscape character assessments within Shropshire and Herefordshire. Valued Landscapes, including the Snowdonia National Park, the Shropshire Hills AONB and the various Special Landscape Areas are described in detail, along with a brief description relating to Landscape, recreation and heritage resources. This text is supported by figures 6.4, 6.5 and 6.6a & b.

• Baseline 4: Visual Environment. This section describes the visual environment based on field surveys and a desktop study of maps and aerial photos. Supporting information is provided by a set of character views, included in Appendix 6.12 and plan 6.5a. A description of prevailing weather conditions, atmospheric conditions and visibility is provided in relation to the distance that objects are visible in the landscape and is supported by data provide from the Met office. This concludes that visibility is limited to less than 15 to 20km for 50% of the time. The report includes a description of the visual


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environment at a local, detailed and distant level, restricted to the areas lying within the ZTV of the proposals. Key receptors which have the potential to be affected visually by the proposed windfarm are summarised and grouped as follows: 1. Residential property 2. Recreational trails and public rights of way 3. Publicly accessible land 4. Cultural heritage features with public access 5. Public highways

The report also provides an appraisal of visually sensitive and valued landscapes, including the Snowdonia National Park, Shropshire Hills AONB, Special Landscape areas and Historic Parks and Gardens. Overall the base line study provides a good basis from which the occurrence, estimation of magnitude and significance of the landscape and visual effects of the development may be identified and assessed. In summary, however, the following omissions and limitations are noted:

1) The Historic Landscapes at Caersws and Clywedog require acknowledgement and should be assessed if appropriate (i.e. from designated areas within the ZTV).

The approach adopted appears to be good, with only minor omissions and inadequacies evident and is graded as B.

3.7 SELECTION OF VIEWPOINTS

The assessment has included 32 viewpoints and a comparison has been made between the existing view and that with the development in place, using appropriate wireframe and photomontage images. These viewpoints are located on figure number 6.6A and illustrated on 6.10 and provide a range of views from close to distant across the study area. Detailed information is provided on the lens type and focal length and other factors. Fourteen viewpoints test the full visibility of 29 turbines, whilst the remainder are mixed in terms of the number of turbines that would be visible. It is noted within Paragraph 24 of Appendix 6.6 ‘that photomontage viewpoints are representative of sensitive landscape and visual receptors, in particular settlements, informal recreation resources/routes and important roads located in the study area.’ It also states that ‘Viewpoint selection was informed by the statutory consultee responses to EIA scoping and by consultations with the local authority....’ Furthermore, paragraph 6.87 again states that ‘viewpoint locations were selected, taking account of consultations with Powys County Council, as being representative of sensitive residential and recreational receptors/views in the study area.’ However, it is evident from available material within the assessment that responses from consultees relating to viewpoints have been limited. These are included in Appendix 4.2. Cadw, in particular, have requested consideration of ‘Fowlers Armchair’ through at least one viewpoint, showing the scheduled site in relation to the proposed turbines.


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It is also noted that the list of consultees does not include Natural England or Snowdonia National Park. These bodies possess responsibilities relating to the Shropshire Hills AONB and the Snowdonia National Park. In particular, with regard to the AONB, key viewpoints should be agreed with Natural England given the relative distance of this sensitive area to the development. We are, in addition, unable to verify the extent of involvement of Powys CC with regard to the selection of viewpoints.

We have reviewed the viewpoints used within the assessment in detail and note that:

• Twenty of the viewpoints are located on roads and have been classified as being of low sensitivity. Nine of these are on minor roads, five on B classified roads and six on A classified roads.

• Four viewpoints are located on long distance recreational routes and have been classified as high sensitivity.

• Two viewpoints have been located on minor footpaths and have been classified as high sensitivity.

• Four viewpoints may be representative of designated landscapes, comprising the Snowdonia National Park, The Shropshire Hills AONB and Special Landscape Areas to the west. These have been classified as being of high sensitivity.

• One viewpoint has been located on access land at Beacon Hill and is classed as being of high sensitivity.

It is acknowledged that individual residential receptors and key Public Rights of Way within 5km have been subject to an individual assessment which is tabulated and included within Appendix 6.8. However, it is clear that the selected viewpoints and tabulated summaries within Appendix 6.9 fail to:

• Provide a balance between those used to test the accuracy of the ZTVI and those used to assess potential sensitivity and significance. The majority of viewpoints are located on roads and have been classed as being of low sensitivity. Their value, therefore, is assumed to relate to the testing of the accuracy of the ZTVI, although this contradicts the assertion provided that the viewpoints are ‘representative of sensitive landscape and visual receptors.’

• Adequately explore impacts on the range of public access and recreation/cultural heritage resources as highlighted on figure 6.6a and key designated areas within the study area. The majority of viewpoints are located on minor roads classed as above and these often fail to acknowledge or reflect adjacent more sensitive receptors, such as housing and footpaths. These are not representative of the general area and the assessment fails to effectively gauge impacts on significant sensitive receptors. Key sensitive areas have not, therefore, been explored in enough detail.

• Adequately explore visual impacts on residential and other receptors between 5 and 10km. Key areas requiring further attention include the west facing slopes of the Ithon Valley, where land rises and allows views to extend directly west across to the proposed development. It is likely that all turbines will be seen extending across the view from north to south. Also of note are the areas to the west of the development around St Harmon. Viewpoints 5, 7, 8 and 10 are located in this area, although it is noted from figure 6.8b that all four have been positioned where visibility is reduced. Viewpoints 7 and 8, in particular,


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are located where no turbines are visible. Areas of significant visibility (i.e. 21-29 turbines visible) are located 1-2km to the west of these viewpoints and receptors in these areas will need to be assessed.

• Consider the visual effects on the setting of Fowlers Armchair. This has been explored by only one photomontage. This is considered to be inadequate given the sensitivity of the site and potential magnitude of effects. In addition, the historic landscapes at Caersws Basin and Clywedog Valley should be reviewed within the Landscape and Visual Assessment Section, with viewpoints included as appropriate.

• Consider visibility from the existing bridleways and footpaths extending through and around the immediate site area.

This aspect of the assessment is poor, with significant omissions or inadequacies and is graded as E.

3.8 ASSESSMENT OF LANDSCAPE AND VISUAL IMPACTS

Landscape and Visual Impacts are independent but related issues. Landscape issues relate to changes in the fabric, character and quality of the physical baseline landscape. Visual impacts relate to the changes in appearance and the perception of these changes on people who might see them. The assessment criteria are outlined in Appendix 6.1 paragraphs 6-14. This includes only three levels of sensitivity from low to high. We believe that this does not allow a distinction to be made for landscapes of the highest quality and sensitivity, such as would be found within the National Park to the north, or elsewhere. It is also noted that the high sensitivity description included in the table does not recognise landscapes that may be classified as of outstanding evaluation within Landmap. The visual table similarly fails to differentiate between public rights of way and nationally designated countryside/landscape features with public access, such as Glyndwrs Way and other long distance footpaths. We would recommend four categories for sensitivity rather than the three provided, and that the resultant assessment acknowledges this within the significance ratings. Impact magnitude again uses only three levels of category. Guidelines suggest that a minimum of four are used. The assessment does not take into account capacity. This is based on a consideration of sensitivity and landscape quality and takes into account the type and form of the development proposed. It is a useful factor in considering the true significance that the effects of a development may have on a landscape. View range thresholds have been included within Appendix 6.1 (paragraph 23-24). These generally suggest that close range views are below 3km. Distant or long range views are classed as above 10km, at which point any views of the proposals would be read as part of the landscape and receptors would experience negligible or less magnitude of effect. Current guidelines suggest that turbines are perceptible at distances of up to 20km, with full turbine detail visible at distances up to 10-12km. We believe that the criteria included within the assessment underestimate the potential impacts on landscape and visual resources, and furthermore, that distance is used mechanistically predict magnitude. The potential effects of other modifying


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factors should be taken into account to ensure that the assessment is sensitive to the often subtle nature of impacts that can result from windfarm developments. Evaluation of assessment of impacts on Landscape and Landscape Character Direct landscape effects on the site landscape and features are described in sections 6.166-6.181. The assessment states that there are ‘no features of recognised landscape importance situated on the site, such as native species hedgerows or mature trees protected with TPO’s.’ We believe this to be inaccurate. The ecological report outlines that there are areas of heath, mire and acid flush habitat which are BAP priorities. The archaeological report establishes that there are a number of valued sites of national significance, including a SAM, within the site area. In addition, this large scale, open and simple upland landscape will be sensitive to impacts upon the landform itself, such as earthworks or other operations on or around prominent slopes. It is clear from the assessment that the excavations and construction work involved in the development will have an impact on the various grassland habitats within the footprint of the development, amounting to an area of around 638ha. There will, however, also be an extensive amount of excavated material, which the assessment suggests will be deposited within the site, possibly within the borrow pits. Conversely, section 3.18 states that ‘topsoil and subsoil will be stripped and stored separately for future reinstatement.’ The developer does not anticipate that spoil will be removed from site. The impact from the spreading of this excavated material within the site does not appear to have been adequately considered by the assessment. We calculate that around 55,000m3 (including 15% bulking) of material may need to be contained within the site. This will directly impact on vegetation within the footprint of any storage area as well as the landform itself, potentially adding to indirect effects outside the site. It is suggested that the developer give further consideration to this issue and provide appropriate plans and details relating to how excavated materials will be stored or disposed of. Ecological, archaeological and landscape issues will need to be adequately addressed. In summary we believe that the assessment relating to effects on site landscape and features has been underestimated. Effects on Landscape character are described within paragraphs 6.182. The following limitations are noted:

• Distance is used throughout the assessment to gauge impacts on landscape character. The assessment suggests that impacts beyond 5km would not be significant. It also asserts that a windfarm landscape or landscape sub-type would only occur potentially within 750-1000m and 1500-2000m respectively from the development. Impacts on landscape character are often subtle and given the potential extent of visibility and the sensitivity of some the rural areas within the study area, we believe that this is inaccurate. As an example, the land rising to the east of the River Ithon, between 5 and 10km from the proposed turbines will experience significant visibility, with the turbines clearly seen as a row along the skyline. The elevated open access areas centred on Gors Lydan, Cilfaesty Hill and further to the east, Beacon Hill, are popular, with footpaths and long distance routes, such as Glyndwrs Way. The Landmap evaluation classifies this area as high. Although the existing P & L Windfarm is visible, the structures are smaller and the new turbines will be


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considerably more visible in this upland rural scene and the impact will on the landscape character will be significant.

• The description of effects on Waun Ddubarthog Wind Farm (MNTGMVS443) provides an interpretation of the Landmap description that appears to be overly positive relating to the presence of windfarms. The Landmap description generally accepts that the existing P & L turbines are a positive feature within the landscape but also specifically states that further windfarm development should be restricted in this area.

• The description of Upland moor, north and west of Abbeycwmhir (RDNRVS115) states that the eastern character unit is significantly influenced by the existing P & L wind farm. The Landmap description of this area does not mention the windfarm and it is noted the vast majority of the eastern section slopes away to the south east away from Waun Ddubarthog, with the more elevated section of land intervening and screening any visibility. We do not believe that this area should be classed as a ‘Wind farm sub-type’ and suggest that the impact on this area has been understated.


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Evaluation of assessment of Visual Impacts 32 viewpoints have been included within the assessment, as well as schedules relating to visual effects on properties within 5km and public rights of way within 3km. Viewpoints 1-32 have been photographed and wireframe images produced to help give an idea of the appearance of the built wind farm in the landscape.

The following receptor groups were evaluated by the visual assessment:

• Residential property and settlement; • Recreational trails and PRoW; • Land with public access; • Cultural heritage assets (publicly accessible only); • Public highways – local roads and major routes.

Again, it is noted that distance is used to form the basis for significance of visual effects. 15km is stated as being the limit of significant visual impact. Furthermore, it is stated that, in practice, it is unlikely that significant visual effects would occur beyond 5km of the site. We consider this to be inaccurate and would suggest that significance is re-assessed taking into consideration the true sensitivity and importance of the receptor and the nature and magnitude of the effect. Above 5.4km (viewpoint 6), the visual assessment effectively classifies the significance of the majority of effects, as recorded at the individual viewpoints 1-32 and within the schedules in the Appendices, as being of minor or negligible significance. This is considered to be inaccurate, given the scale and elevated position of the development, the sensitivity and range of receptors within the study area and the extent of the ZTVI. Particular concern relates to the assessment of impacts upon the Afon Marteg valley. This area contains scattered dwellings, together with the hamlet of Pant-y-Dwr, together a section of Glyndwr’s Way and minor roads. The landform is aligned to the north-east, with views contained by the ridgeline of Brondre-fawr Hill. No windfarm developments will be visible from this area. The southern section of the development will intrude into the valley and will be a prominent feature along the ridgeline as shown by photomontage 5. Visual impacts throughout have been assessed as being of low magnitude with minor significance. We consider that these have been considerably underestimated. We also consider that visibility has not been adequately explored by the assessment in the following areas and further information would be useful to explore the significance of any impacts:

• The ZTVI suggests that land rising to the east of the River Ithon, between 5 and 10km from the proposed turbines will experience significant visibility. These elevated open access areas, centred on Gors Lydan, Cilfaesty Hill and further to the east, Beacon Hill, are popular, with footpaths and long distance routes, such as Glyndwrs Way. The area also contains scattered dwellings and farmsteads. Although the existing P & L Windfarm is likely to be visible, the proposed turbines will be considerably more visible in this upland rural scene due to their increased size and will impact significantly on the open panoramic views available.

• The ZTVI suggests that significant visibility will be experienced on elevated areas to the north of Rhayader and to the west of St Harmon. Viewpoints 7


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and 8 within this area are located where landform intervenes and the resulting impacts are assessed as negligible. However, views from the more elevated open access areas to the immediate west of these viewpoints are likely to experience a higher magnitude of effect with all 29 turbines seen on the skyline. These impacts would be expected to be significant and should be explored in more detail by the assessment.

• To the west of the development, within the 10-15km range, it is noted from the ZTV that viewpoints 13, 15 and 16 are located where it would be expected that around 11-15 turbines would be visible. Areas of maximum visibility are located to the north and south of Llangurig and views from this location would be expected to take in the development along its entire length. Possible sensitive viewpoints could include the Wye Valley Walk around 3km to the south of Llangurig.

We, therefore, consider that the visual assessment has underestimated the significance of the development. Viewpoint selection as discussed above in section 3.7, has highlighted that many of the viewpoints have been classified as being of low significance and, in some cases do not reflect the true sensitivity of the location.

We also have the following concerns regarding the layout and design of the development.

• We believe that turbines 17 and 18 intrude into the setting of Fowler’s Armchair, although further information, including additional photomontages, would be useful to allow proper consideration to be given to this. We suggest these should be repositioned or removed from the layout.

• Turbine 16 is seen to the front of turbines 15 , 17 and 18 within views from the east and north-east and visually interacts with these. In order to reduce ‘stacking’ it is suggested that this turbine is removed or relocated.

• Within views northeast from the southern slopes of the Afon Marteg Valley, around Bwlch-y-Sarnau, (refer to photomontage 2 and 4) Turbines 25-29 are seen interacting with each other along the ridgeline within close range views. Receptors within this area include Glyndwrs Way and residential properties and it is suggested that a more sensitive layout should be considered that reduces the effects of stacking. It may be necessary to reduce the number of turbines within this area.

In summary, we believe that the visual assessment:

• Underestimates the magnitude, sensitivity and significance of effects; • Does not adequately explore areas of significant visibility to the east and to the

west within the range of 5 to 10 km; • Has highlighted some limitations and insensitivities relating to the layout which

will need to be addressed.

This aspect of the assessment is poor, with significant omissions or inadequacies and is graded as E

3.9 PRESENTATION AND ACCURACY OF MATERIAL


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The report provided is concise, well structured and uses an approach that is transparent. We have examined this is detail to review accuracy and consider the procedures and methods described to be relatively easily replicated. The report includes plans, photographs, photomontages and wireframes including the appropriate supporting data. It is stated that photographs have been taken using a 35mm camera with a 50mm lens. The images presented are around 13cm in height and show panoramic views, with consistent fields of view, (stated as 75 degrees for each viewpoint). We have carried out a desk and field based review of these viewpoints and this has included comparisons of the photographic material with images that we have taken with a digital equivalent camera. Guidance material suggests that an image height of around 20cm is required to give a realistic impression of reality. It may be argued, therefore, that the photographs, photomontages and wireframes give an unrealistic impression of the development, with the perception of the effects of the development as lower in magnitude than would be experienced. As outlined in section 10 above, it is also noted that the wireframe and photomontage images do not include the proposed adjacent replacement P & L development. Whilst it is accepted that this may be due to the timing of the adjacent applications, we consider this to be a significant omission as stated in section 10 below. This section is considered to be satisfactory, despite some omissions and inadequacies and is graded as C.

3.10 COMPLETENESS

The assessment includes sections relating to most areas of relevance. This review has highlighted some omissions as outlined above and below, although, overall the assessment is adequate in terms of its completeness. The approach adopted appears to be good, with only minor omissions and inadequacies evident and is graded as B.

3.11 MITIGATION OF EFFECTS

The assessment does include a section relating to mitigation of effects. However, it is accepted that mitigation of the effects of windfarm developments will be difficult due to the sheer size of the turbines and the often open and expansive nature of the surrounding landscape. Alternative options have been considered and the design and layout of the development has responded to a number of landscape and visual constraints. In particular, turbines within the southern section of the site, at Brondre Fawr Hill, were reduced in height to mitigate visual effects to properties to the south. Other changes mentioned include altering the position of turbines in relation to existing bridleways, minimising the proliferation of tracks through coinciding access routes with existing public rights of way.


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Bridleways AC410, LD756 and LD106 will require realignment. A number of other paths are significantly affected along with some footpaths. We would expect mitigation to include proposals for their realignment. Further details are also required relating to the finish of the control building in terms of outer wall materials (local stone should be used) and roofing materials. This section is considered to be satisfactory, despite some omissions and inadequacies and is graded as C.

3.12 CUMULATIVE EFFECTS

The assessment includes a description of cumulative effects within Appendix 6.10, together with figures 6.11 and 6.12a-q. The base plan (figure 6.11) indicates the positions of existing, consented and publicly proposed windfarms within 70km. However, it is noted that the adjacent P & L replacement windfarm development has not been considered. It is understood that the application was submitted following the Llaithddu application. It will be vital that this is considered within this assessment and is a significant omission. Based on the information available and from an assessment submitted separately relating to the adjacent development at Llandinam, it is clear that the heights of the turbines within the two developments will be different, with the turbines at Llaithddu around 6m lower than Llandinam. It is also evident that the spacing of the 2 developments will differ considerably, although more detailed layout plans will be required to adequately gauge this aspect. It is suggested , therefore, that further consideration is given to the integration of these two separate developments. A ZTV analysis is provided indicating the interaction and extent of visibility for Llaithddu and each of the identified cumulative windfarms. A number of windfarms identified on figure 6.11 towards the edge of the 70km buffer zone have not been assessed, although we do not consider this to be significant. Figure 6.13 indicates combined cumulative visibility. This suggests that the Llaithddu development will, for a large proportion of its individual ZTV, be seen in the context of at least one other scheme. Areas where it will be seen in isolation are limited in extent and are principally located within the Afon Marteg valley and around Welshpool and Montgomery. Viewpoints 1-32 include cumulative windfarms where these fall within the horizontal field of view (75 degrees). Effects shown on these have, therefore, been considered in combination (i.e. several windfarms are within the observers arc of vision at the same time) rather than succession (i.e. where the observer has to turn to see the various windfarms). Sequential effects have been considered for the Llaithddu development in isolation along significant routes and are indicated on figures 6.7a and b. However, they have not been illustrated for cumulative effects, although a description is provided in sections 86-95. Perceived effects have not been described or considered by the assessment photomontages and wireframes have been included and illustrate the nature and degree of effects.


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In summary, the following limitations are noted with regard to the Cumulative Assessment:

• the adjacent P & L replacement windfarm development has not been

considered. Photomontage and wireframes will be required, particularly viewpoints3a, 3b, 6, 9, 11 & 17. These are all based to the east of the proposed development. Information is required to demonstrate integration of the two separate developments in terms of heights and spacing of turbines, colours and other design issues.

• sequential cumulative effects have not been considered adequately. Although a description is provided in section 86-95, illustrations would be useful to allow this issue to be fully considered.

This aspect of the assessment is poor, with significant omissions or inadequacies and is graded as E.

4. Summary of Findings

4. Summary of Findings 4.1 SUMMARY OF FINDINGS

Our review of the submitted Landscape and Visual impact assessment has revealed extensive omissions and inadequacies which the LPA may require to be addressed before proceeding with the application. The key areas on which we are satisfied that the LVIA broadly complies with guidance are as follows:

• The report has generally been presented in a well structured format and with a clear methodolgy used for presenting the information.

• The proposed development has been adequately described, backed up with good quality illustrations.

• The extent of study area/ZTVI complies fully with good practice and relevant guidance with a 35km limit included.

• The baseline study provides a good basis from which to assess the magnitude and significance of landscape and visual effects.

• With the exception of the items listed below, the assessment includes sections relating to all areas of relevance and is consistent and accurate.

The key areas on which in our view the LVIA is inconsistent, fails to meet the required standard or where further information should be provided are summarised as follows:

• Although the LVIA provides an account of the scoping exercise, there is

insufficient evidence contained within the report to confirm that this has been sufficient in relation to landscape and visual matters. It is not clear to what extent the selected viewpoints have been agreed with PCC and other statutory bodies. In particular, it is also noted that Natural England have not been included on the list of consultees, and this may suggest that their interests relating to the Shropshire Hills AONB have not been addressed by the assessment.

• The description of the development suggests that alternative layouts have been considered. However, the suggestion that the current proposed layout avoids areas of highest visual sensitivities is not accepted and further investigation of this may be necessary.

• The viewpoints selected fail to provide a representation of sensitive landscape and visual receptors within the study area. The majority are located on minor roads classed as low sensitivity. Key areas appear unassessed, including the west facing slopes of the Ithon Valley. Areas nearer the site, including Fowler’s Armchair also require further illustrations to gauge effects.

• The Landscape and visual assessment is inconsistent and inaccurate throughout. As above key areas require further assessment as outlined in section 3.8. It is also suggested that the layout and design is further considered to reduce interaction, stacking and impacts on Fowler’s Armchair.

• The cumulative assessment does not provide adequate information regarding sequential effects and, more significantly, fails to include an assessment of the proposed replacement P & L development.


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5. Conclusion

We have reviewed the Landscape and Visual Impact Assessment contained within the Environmental Statement submitted by Fferm Wynt Llaithddu Cyf for the Llaithddu Wind Farm. This has established deficiencies in terms of its technical competence, assessment techniques and compliance with best practice. The assessed sensitivity of receptors and the magnitude and significance of effects are considered to be inconsistent and the assessment fails to adequately consider key areas and features. We are required to consider the extent to which the application is in accordance with Planning Policy and this is outlined below.

National Planning Policy The following policies are affected by this development:

• Planning Policy Wales (March 2002) states that National Parks and AONB’s ‘must be afforded the highest status of protection from inappropriate developments…..whether those activities lie within or outside the designated areas.’ The boundary for the Snowdonia National Park lies around 32km from the proposed development and it is not considered that the development will have any significant impacts on this designated area. However, the Shropshire Hills AONB lies less than 12km from the edge of the development and impacts can be considered to be more significant. The assessment currently includes one viewpoint within this area at a distance of 23.5km. Areas of visibility nearer to the development have not been adequately explored by the assessment. We are, therefore, unable to assess the impact on this policy from the information provided.

• The context for sustainable energy and the commitment within Wales to achieve its specific targets for renewable energy production is set out in Ministerial Interim Planning Policy Statement (MIPPS) – Planning for Renewable Energy and Technical Advice Note 8, which recommends Strategic Search Areas (SSA). The development is located within the refined SSA C. However, whilst it is accepted that the development is sited within areas deemed acceptable for windfarms, we do not believe that the landscape and visual impacts associated with this development have been minimised. The deficiencies in the assessment suggest that impacts have not been properly identified, addressed and mitigated. The development is contrary to this policy.

Regional and Local Planning Policy The following policies extracted from the Powys County Structure Plan (Replacement) Adopted February 1996 are affected by this development:

• POLICY E20 – Renewable Energy Sources and POLICY EC5A: Landscape Features. This report has highlighted various inconsistencies and limitations with regard to the assessment. Particular concern relates to the impact of the development on the AONB, Fowler’s Armchair and the west facing slopes of the Ithon Valley. Concerns have also been raised relating to the layout and appearance of the development within specific sensitive views, such as from Glyndwrs Way, near Bwlch-y-Sarnau. We, therefore, believe that there are


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unacceptable planning and environmental problems relating to the proposals and that this development is contrary to the aims of this policy.

• POLICY EC15: Ancient Monuments and POLICY EC16: Sites and Landscapes of Archaeological or Historic Interest. It is felt that the siting of turbines within the proximity of Fowlers Armchair and other archaeological remains is contrary to this policy. The former is nationally designated and publicly accessed. The amenity value of this site will be compromised. It is suggested that further assessment is carried out and further consideration given to the layout of the development.

The following policies extracted from the Radnorshire Local Plan (1999) are affected by this development:

• POLICY REC 17: Wind Energy. The development is located within the refined

SSA C. However, whilst it is accepted that the development is sited within an area deemed acceptable for windfarms, we do not believe that the landscape and visual impacts associated with this development have been minimised. The deficiencies in the assessment suggest that impacts have not been properly identified, addressed and mitigated and the development is contrary to this policy. In addition consideration will need to be given to the various bridleways and footpaths in and around the site.

• POLICY REC 15: Ancient Monuments of National Importance. It is felt that the siting of turbines within the proximity of Fowlers Armchair and other archaeological remains is contrary to this policy. The former is nationally designated and publicly accessed. The amenity value of this site will be compromised. It is suggested that further assessment is carried out and further consideration given to the layout of the development.

The following policies extracted from the Powys Unitary Development Plan: Deposit Draft October 2004 (as modified November 2007) are affected by this development:

• POLICIES GP1: Development Control, SP 3: Natural, Historic and Built

Heritage, ENV 2: Safeguarding the Landscape. It is clear from the submitted LVIA that the design and layout of the proposed scheme is insensitive to the surrounding landscape and that landscape and visual impacts have not been adequately identified, addressed and mitigated (as generally outlined in section 6.1). The proposed development is contrary to these policies.

• POLICY SP12: This overarching policy states that ‘appropriate proposals for energy generation from renewable sources will be approved providing that they meet the landscape….and other requirements set out in the other policies of this plan.’ It is not considered that the landscape requirements set out in the UDP have been met, and the proposals at present are contrary to this policy.

• POLICY E3: Wind Power. The policy is aimed at striking a careful balance between the pressing need to combat climate change through renewable energy measures and the need to protect a valued and attractive landscape. It is clear from the submitted LVIA that the current design and layout of the proposed scheme is insensitive to the surrounding landscape and that landscape and visual impacts have not been adequately identified, addressed and mitigated. The assessment fails to properly consider cumulative impacts. In addition, it fails to properly consider impacts upon the various footpaths and bridleways extending through and adjacent to the development or provide adequate mitigation relating to these routes.


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5. Conclusion

Overall, we recommend that the application be refused. It is clear that sufficient information has not been provided to adequately gauge the landscape and visual impacts and that the assessment is inaccurate. Furthermore, it is considered that the current proposals are insensitive to the landscape as far as can be established at present. However, it is entirely possible that, should the assessment be revised to take account of our recommendations and the layout amended to reduce issues of ‘stacking’ and impacts on the more sensitive areas, such as Fowlers Armchair, the development may be acceptable.


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5. Conclusion

Addendum to main report

The preceding sections of this report were issued to the developer by Powys CC in August 2010. This resulted in a number of meetings between the developer and Powys CC, supported by Capita Symonds Landscape Architect(s) and the submission of supplementary planning information.

This information and the meetings were intended to address the key areas listed in Section 4.1 of this report on which in our view the LVIA is inconsistent, fails to meet the required standard or where further information should be provided. The degree to which our concerns have been addressed are outlined below:

• Although the LVIA provides an account of the scoping exercise, there is insufficient

evidence contained within the report to confirm that this has been sufficient in relation to landscape and visual matters. It is not clear to what extent the selected viewpoints have been agreed with PCC and other statutory bodies. In particular, it is also noted that Natural England have not been included on the list of consultees, and this may suggest that their interests relating to the Shropshire Hills AONB have not been addressed by the assessment.

A meeting was held on the 5th March 2010 between representatives of Powys CC, Capita Symonds Ltd, FWL and RPS during which the consultation process was discussed and clarified. Viewpoints were agreed with both PCC and CCW, including the addition of two additional ones at the request of the latter. Responses were not forthcoming from the Shropshire hills AONB Partnership or Natural England. However, it was agreed at the meeting that any additional viewpoint from the AONB would be unlikely to significantly alter Powys CC’s understanding of the likely landscape impacts of the proposed scheme. This appears to address our main concerns in respect of this scoping and consultation.

• The description of the development suggests that alternative layouts have been considered. However, the suggestion that the current proposed layout avoids areas of highest visual sensitivities is not accepted and further investigation of this may be necessary.

This issue was discussed at length during the meeting of the 5th March 2010 and it was agreed that the layout would be reconsidered in relation to views north from Bwlch-y-Sarnau and that an additional viewpoint would be provided from Glyndwrs Way above Llanbadarn Fynydd. This material has been provided. The revised arrangement along the skyline, in our opinion, is a considerable improvement and demonstrates reduced stacking, balanced and equal spacing and a good relationship of turbines to the horizon. Cumulative issues in relation to existing and proposed windfarms at Llandinam were discussed and it became clear that the onus to address this issue would fall to the more recently submitted developer responsible for the Llandinam Repowering Scheme.

• The viewpoints selected fail to provide a representation of sensitive landscape and visual receptors within the study area. The majority are located on minor roads classed as low sensitivity. Key areas appear unassessed, including the west facing slopes of the Ithon Valley. Areas nearer the site, including Fowler’s Armchair also require further illustrations to gauge effects.

This issue was again discussed at length during the meeting of the 5th March 2010 and it was agreed that an additional viewpoint would be provided from Glyndwrs Way above Llanbadarn Fynydd. This material has been provided and demonstrates that the proposed Llaith Ddu scheme would be seen to the rear of the Llanbadarn Fynydd scheme and to the outer edge of the SSA C scheme. Cumulative effects in this


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context are not considered to significant. Areas of particular concern in relation to sensitivity were also discussed and it was agreed by all that addressing the view north from Bwlch-y-Sarnau was a priority, due to proxity of the village and the ‘static’ open views available from the residential properties. The revised arrangement along the skyline, in our opinion, is a considerable improvement and demonstrates reduced stacking, balanced and equal spacing and a good relationship of turbines to the horizon. Cumulative issues in relation to existing and proposed wind farms at Llandinam were discussed and it became clear that the onus to address this issue would fall to the more recently submitted developer responsible for the Llandinam Repowering Scheme. Mitigation measures have been agreed with CADW and as far as we are aware, no residual concerns exist from this organisation in relation to the revised layout.

• The Landscape and visual assessment is inconsistent and inaccurate throughout. As above key areas require further assessment as outlined in section 3.8. It is also suggested that the layout and design is further considered to reduce interaction, stacking and impacts on Fowler’s Armchair.

As outline above this issue is now considered to be resolved. • The cumulative assessment does not provide adequate information regarding

sequential effects and, more significantly, fails to include an assessment of the proposed replacement P & L development.

Cumulative issues in relation to existing and proposed wind farms at Llandinam were discussed and it became clear that the onus to address this issue would fall to the more recently submitted developer responsible for the Llandinam Repowering Scheme. This will also apply to subsequent developments at Hirddywel and elsewhere in SSA C and potentially B.

Overall, in our opinion, the developer has addressed or clarified many of our concerns and the efforts made to refine the design of the scheme have resulted in a considerable improvement in the appearance of the southern arm of the scheme where it will be seen largely in isolation on the skyline. It is now recommended that the scheme be approved in terms of landscape and visual matters.

Capita Symonds, Tŷ Gwent, Lake View, Llantarnam Park, Cwmbran NP44 3HR 01633 463333

www.capitasymonds.co.uk