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CM/P20-1336 2 October 2020 Planning Inspectorate Wales Crown Buildings Cathays Park Cardiff CF10 3NQ

BY E-MAIL ONLY

Dear Sir Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017: Regulation 6 (1) Request for a Screening Opinion in Relation to the Proposed Solar Energy Scheme on land near Llanedi, Carmarthenshire, Wales, SA18 3PL. On behalf of Brynrhyd Solar Farm Limited, (‘the applicant’), Pegasus Group duly requests Planning Inspectorate Wales Environmental Impact Assessment (EIA) Screening Direction for the provision of ground mounted solar farm with an export capacity of circa 36 Megawatts peak occupying c. 65ha of land on land near Llanedi, Carmarthenshire, Wales, SA18 3PL. By virtue of its potential generating capacity, which stands at circa 36MWp (Megawatts peak), this project constitutes a Development of National Significance ["DNS"]. Therefore, this screening direction request is presented to the Planning Inspectorate Wales as it relates to a development of national significance for the purposes of section 62D of the Town and Country Planning 1990 Act;

1. BACKGROUND

This Screening Direction request is made under Regulation 31 of the Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017 (as amended). The information contained within this letter is in accordance with Regulation 31 (2) which states that a request for a screening direction shall be accompanied by:

(a)a plan sufficient to identify the land; (b)a description of the development, including in particular— (i)a description of the physical characteristics of the whole development and, where relevant, of demolition works; (ii)a description of the location of the development, with particular regard to the environmental sensitivity of geographical areas likely to be affected;

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(c)a description of the aspects of the environment likely to be significantly affected by the development; (d)a description of any likely significant effects, to the extent of the information available on those effects, of the proposed development on the environment resulting from— (i)the expected residues and emissions and the production of waste, where relevant; and (ii)the use of natural resources, in particular soil, land, water and biodiversity; (e)a statement that the request is made in relation to a development of national significance for the purposes of section 62D of the 1990 Act; and (f)such other information or representations as the person making the request may wish to provide or make including any features of the proposed development or any measures envisaged to avoid or prevent what might otherwise have been significant adverse effects on the environment

The remainder of this letter is split into the following sections:

• Section 2: The Development Site • Section 3: The Development Proposal • Section 4: EIA Assessment • Section 5: Conclusions

This screening opinion request is also supported by the following:

• Site Location Plan • Preliminary Ecological Appraisal (PEA) & Ecological Constraints and

Opportunities Plan, prepared by Clarkson & Woods

2. THE DEVELOPMENT SITE

The site covers approximately 65 hectares and is located on land near Llanedi, Carmarthenshire, Wales, SA18 3PL. The site is located within the administrative area of Carmarthenshire County Council. The proposed solar PV development is situated within open countryside c. 0.7km to the north-east of Llanedi. The site is positioned between the A483, which runs parallel to the site c. 0.9km to the north-west, and the River Loughhor, which runs to the south-east c. 0.9km from the site boundary. Approximately 0.3km to the north of the site is situated Clawdd Ddu Solar Farm, which was approved planning permission on the 7th October 2013. Clawdd Ddu Solar Farm runs at a maximum capacity of 12MW and has a land take of 28 ha. Given that this application was determined before the Planning (Wales) Act 2015, this application was determined by the Local Planning Authority, Carmarthenshire County Council, under the provisions of the Town and Country Planning Act 1990. Clawdd Ddu Solar Farm was not deemed EIA by the LPA. To the immediate north of Clawdd Ddu Solar farm there are two individual land parcels which form part of a separate DNS proposal for a ground mounted solar farm. That application is currently being determined by the Planning Inspectorate Wales on behalf of the Welsh Minister. That scheme comprises three separate land parcels and the third land parcel is located further west near the A48. Turning back to our development proposal, the Brynrhyd Solar Farm would occupy agricultural land that is predominantly used for grazing. The fields are variously bounded

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by fences, hedgerows, woodland edges and ditches or streams. The surrounding landscape is dominated by similar networks of pasture farmland, hedgerow networks, woodland and streams. The site occupies undulating land between 40m and 120m above sea level with various wooded stream valleys encircling the north and east of the Site. The floodplain of the River Loughor is located within 50m of the eastern extent of the Site within which it flows southwards to Swansea. The M5/A48 interchange is roughly 1Km to the west. A public footpath passes through the northern section of the site past Bryn Awel Farm, before progressing in a northbound and southbound direction towards Plas-newydd and Pen-y-fed-fach, respectively. The southern section of this footpath re-enters the site and runs along the south-western edge for c. 350m. Flood Risk & Hydrology The Nature Resource Wales Development Advice Map1 locates the site within Zone A, an area least at risk of flooding. The area surrounding the River Loughor is marked as within Zone C2.

Figure: Extract from the Natural Resource Wales Development Advice Map Environmental Designations and Ecological Sensitivities.

1 https://maps.cyfoethnaturiolcymru.gov.uk/Html5Viewer/Index.html?configBase=https://maps.cyfoethnaturiolcymru.gov.uk/Geocortex/Essentials/REST/sites/Flood_Risk/viewers/Flood_Risk/virtualdirectory/Resources/Config/Default&layerTheme=2

https://maps.cyfoethnaturiolcymru.gov.uk/Html5Viewer/Index.html?configBase=https://maps.cyfoethnaturiolcymru.gov.uk/Geocortex/Essentials/REST/sites/Flood_Risk/viewers/Flood_Risk/virtualdirectory/Resources/Config/Default&layerTheme=2https://maps.cyfoethnaturiolcymru.gov.uk/Html5Viewer/Index.html?configBase=https://maps.cyfoethnaturiolcymru.gov.uk/Geocortex/Essentials/REST/sites/Flood_Risk/viewers/Flood_Risk/virtualdirectory/Resources/Config/Default&layerTheme=2

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There are no environmental designations within the site’s boundaries. Caeau Afron Gwili SSSI is located adjacent to the site to the north-west. Caeau Afon Gwili is an SSSI designated for traditional meadows and grasslands which support notable floral diversity as well as notable species of reptiles, birds and invertebrates. This site borders the Site immediately to the west of the northern fields of Brynrhyd. No part of the SSSI actually occurs within the site. It was noted during the walkover survey as being of significant floral diversity owing to the absence of grazing and lack of intensive management. It was considered that many of the grassland fields within the site have the potential of being restored to this ecologically valuable status given the correct conservation management in conjunction with an operational solar array. The Graig Fawr SSSI is located c. 1.5km to the south-east of the site. There are no other notable environmental designations on site or within the surrounds. Clarkson & Woods Ecological Consultants have provided a Preliminary Ecological Appraisal (PEA) of the site, based upon information collected during an ecological walkover survey carried out by Clarkson and Woods on 21st and 22nd July 2020. The survey sought to characterise the habitats present and the potential for legally protected habitats and species and those of conservation concern which may pose constraints to future development. The PEA carried out by Clarkson & Woods identifies that 51 parcels of Ancient Woodland within 2km of the site boundary. Of these, two are within 100m of the Site, the closest being adjacent to the Site, lining the valley of Cwm Bychan close to the landholding of Gelli Organ farm in the north east of the site. Part of the northern fields within Brynrhyd lie within the edge of a Natural Resources Wales Priority Area for heathland and grassland. The PEA identified that the hedgerow network is extensive and generally species-rich across the site, and is the single most valuable habitat feature within the site and should be protected adequately during construction. It is not proposed to remove any sections of hedgerow. As the PEA notes, there is an opportunity to infill ‘gappy’ areas with species-rich hedgerows to match existing, which will be maintained to an appropriate height. This will be done as part of the landscape and ecological mitigation strategy, which will be established at full planning stage following extensive landscape and visual assessment. The PEA provides findings on protected species. A large badger sett was found in one field. As a precaution, and to ensure that construction and operational maintenance works comply with best practice standards on the avoidance of unlawful disturbance to badgers, a 30m buffer zone will be established from the perimeter of the sett. Within this buffer zone, there should be no movement of plant, excavations or installation of array structures or buried cabling for the life of the scheme. Protective fencing and signage should be installed at the beginning of the construction phase. The PEA concludes that there is a need for a further, brief investigation of marsh fritillary butterfly habitat and of breeding skylark and meadow pipit in a very limited number of fields. Finally, the PEA concludes that because tree felling and hedgerow damage/removal can be entirely avoided through construction phase protection measures, no further investigation for otters, water voles, dormice, bats roosting in trees, amphibians or reptiles is necessary. There are several opportunities for the project to result in a real significant and cost-effective contribution to local biodiversity priorities and Biodiversity Net Gain. These are:

• The restoration through targeted land management of a small number of fields to species-rich traditional meadow and marshy grassland. This would contribute to

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regional conservation priorities for nearby protected landscapes and species. The target areas TN4 and TN5 in the below extract from the Habitat and Target Note Map are areas which could be restored to traditional meadow and diverse grassland.

• The improvement of floral diversity of many fields to species-rich grassland by ceased or low-level grazing, cessation of fertiliser application and timed cutting.

• Planting of new and gapped-up traditional species-rich hedgerows where currently

fragmented.

• Installation of features such as bat boxes, bird boxes and invertebrate/reptile/amphibian hibernacula.

The Habitat and target Note Map included below identifies the features noted above. This should be read in conjunction with the supporting PEA.

Figure: Habitat and Target Note Map from the supporting PEA It is considered that the proposed solar farm will allow the land to recover from decades of intensive farming. The land on which the panels will sit will be carefully managed to encourage the growth of species-rich meadows that will support local wildlife populations. Any future planning application will include a mitigation strategy setting this out in full. An extract of the Lle Cymru interactive map showing nearby ecological designations is included below.

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Figure: Extract from the Lle Cymru Online Map

Heritage Assets According to the Historic Wales interactive map2, there are no Listed Buildings on site. The closest listed Building is the Plas-Newydd Mill c. 1km to the north-west of the site. There are no Scheduled Ancient Monuments (SAM) or World Heritage Sites situated within the parcel of land. The closest SAM is the Bryn-Y-Rhyd Standing stone, c. 60m from the site boundary. There are no Conservation Areas within a 2km radius of the site.

2https://historicwales.gov.uk/#zoom=5&lat=208271.12983&lon=259121.71455&layers=BFFFFFFFFTT

https://historicwales.gov.uk/#zoom=5&lat=208271.12983&lon=259121.71455&layers=BFFFFFFFFTT

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Figure: Extract from the Lle Cymru Online Map

Agriculture Turing to agricultural land classification, the Predictive Agricultural Land Classification (ALC) Map3 notes the site to be mostly consisting of Sub Grade 3b, Grade 4 and Grade 5 agricultural land.

Figure: Extract from LLe Cymru Predictive ALC Map

Sensitive Human Receptors

3 http://lle.gov.wales/map/alc#m=-4.03275,51.75555,15&b=europa&l=908h;893h;1326;

http://lle.gov.wales/map/alc#m=-4.03275,51.75555,15&b=europa&l=908h;893h;1326

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The site is located within the surroundings of the following residential properties:

• Bryn-Y-Rhyd located within the red line boundary; • Bryn Awel located adjacent to the northern site boundary; • The old Stableyard located less than 50m from the northern site boundary; • Gelli Organ located adjacent to the site to the south-east; • Tirgwaidd located adjacent to the southern boundary of the site.

The area is characterised as open countryside with a lack of nearby residential development. Llanedi, a small village, is located c. 0.6km to the south-west of the site. Landscape and Visual There are no landscape features either within or immediately adjacent to the land which have any particular sensitivity that would inhibit the development of a well-designed solar farm at this location. The site is not situated within or near a designated Area of Outstanding Natural Beauty (AONB). The site is located within the eastern cusp of the Welsh Government Priority Area for Solar Energy [Priority Area No. 13]. The site stretches across two National Landscape Character Areas – NLCA33 Gwendraeth Vales and NLCA37 South Wales Valleys. Gwendraeth Vales is a lowland area, marking a transition between the urban and industrialised landscapes of Swansea and the Valleys to the east, and rural Carmarthenshire and estuaries to the west. It is also the western limit of the M4 motorway from London. This is an area of rolling hills, ridges and minor valleys, comprising the area between the coastal and valley parts of the Tywi, the South Wales Valleys and the Black Mountain part of the Brecon Beacons. The main area has been heavily mined for coal and quarried for limestone. In consequence, this part of the area has developed a distinctive linear or ribbon pattern of settlement along roads. Today, modern residential and industrial estate development breaks the ribbon pattern but nevertheless focuses new development around existing settlements and road crossings. South Wales Valleys contains many deep, urbanised valleys dissecting an extensive upland area. Extensive ribbon development fills many valley bottoms and lower slopes. Their urban and industrial character is juxtaposed with dramatic upland settings with steep hillsides, open moors or forests. According to the Carmarthenshire Renewable and Low Carbon Energy Assessment 20194, the site does not fall within a Registered Landscape of Historic Interest. Traffic and Transport Access to the site will be gained via the B4297 which provides connection to the A483, the A48 and beyond that, the M4. The A422 is a c. 6m wide, two-way highway that frequently accommodates agricultural vehicles of a size similar to the HGVs that will access the site during construction.

4https://www.carmarthenshire.gov.wales/media/1221628/carmarthenshire-renewable-and-low-carbon-energy-assessment-2019-v3-maps-2019-12-11-en.pdf

https://www.carmarthenshire.gov.wales/media/1221628/carmarthenshire-renewable-and-low-carbon-energy-assessment-2019-v3-maps-2019-12-11-en.pdfhttps://www.carmarthenshire.gov.wales/media/1221628/carmarthenshire-renewable-and-low-carbon-energy-assessment-2019-v3-maps-2019-12-11-en.pdf

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During construction / installation of the solar farm, there would be trips associated with the delivery of materials to site and arrivals and departures of construction staff. Construction material deliveries will mainly consist of small to medium HGVs while staff trips will mainly consist of vans. During construction / installation of the solar farm the proposals would generate an insignificant number of traffic movements along the local highway. If the development is built out through a continuous single phase, it is anticipated the construction period will last approximately three to six months, with piling and frames being installed first and then panels being delivered to the site at a rate of around one lorry load per day during the panel installation phase. Any future planning application will be accompanied by a Construction Traffic Management Plan, developed in correspondence with Carmarthenshire County Councils Highways Team, to ensure that construction traffic has a negligible impact on the local highway.

3. DEVELOPMENT PROPOSAL

The proposal is the construction, operation, maintenance and decommissioning of a ground mounted solar farm with a maximum export capacity of c. 36MW. The proposed development would, typically, have a life of up to 40 years at the end of which the modules would be decommissioned and removed from the site. As a general design principle for the ground mounted solar, the layout will be based on fixed solar panels set out in an east-west direction across the site. The top height of the panels is expected to be c. 3m. The site would be retained as grassland able to be grazed by sheep. The application proposal would also include a package of landscape, ecological and biodiversity benefits that could include the installation of barn owl boxes, bird nesting boxes, bee hives, log piles, restoration of traditional field boundaries, and other hibernacula such as small buried rubble piles suitable for reptile species, amphibians and insect life. These biodiversity enhancement measures would be set out in any future application if populations of such species are found to be in or around the site. Any future planning application would be accompanied by an Ecological Impact Assessment, which will set out any mitigation strategies for the determining authority. Land between and beneath the panels can be used for biodiversity enhancements and seasonal grazing. Existing hedgerows surrounding the site would be bolstered with additional hedgerow and tree planting. The new hedgerows would deliver biodiversity enhancements by providing green ecological corridors. The extent of the additional planting will be set out in a Planting Plan that will accompany any future planning application. The arrays would be set within a 2.0m high stock-proof fence. The distance between the proposed fencing and existing hedges would vary across the site and would typically be around 5m. The security measures that will accompany the scheme include CCTV.

4. EIA REQUIREMENTS

For the purpose of this Screening Request we have considered the EIA Regulations. The EIA Regulations set out the legal framework in relation to Environmental Impact Assessment. The EIA Regulations contain two development schedules (Schedule 1

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development and Schedule 2 development). Schedule 1 contains a list of development where EIA is mandatory. The screening proposal does not fall within Schedule 1 Development. Schedule 2 contains a list of development, coupled with development thresholds, where EIA may be considered. The Local Planning Authority must screen every planning application falling under the Schedule 2 development thresholds to determine whether or not EIA is required. When a local planning authority has to decide whether a Schedule 2 development is EIA development, Schedule 4 sets out how the LPA must take into account the information provided by the applicant; the results of any EU environmental assessments which are reasonable available; and, the selection criteria set out in Schedule 3 as are relevant to the development. Schedule 2 contains a list of development descriptions (categories) and applicable thresholds and criteria for the purpose of classifying development as Schedule 2 development. The development description pertinent to this development proposal is ‘Energy Industry’. Type Development description Applicable threshold

and criteria 3. Energy Industry (a) Industrial installations for

the production of electricity, steam and hot water (unless included in Schedule 1).

The area of the development exceeds 0.5 hectares.

Given the final site area exceeds the applicable thresholds, it is appropriate to screen the proposal with the Planning Inspectorate to clarify if there are potential significant effects likely to arise from the proposal which constitute EIA Development. Regulation 6(4) of the Act sets out how a screening request, where relevant, must take into account the criteria set out in Schedule 3 which consider the characteristics of development, the location of the development and the types and characteristics of the potential impacts. The relevant issues are considered in this screening request. Physical Scale of Development and Visual Impacts As stated elsewhere, the development site extends to approximately 65 hectares and comprises a collection of medium scale geometrical and irregular fields. The land in the vicinity of the application site is in mainly agricultural or woodland use. The solar arrays would appear set within the undulating landform with partial enclosure provided by the framework of hedgerows and small blocks of woodland or spinneys. The undulating land acts to contain views to the short distance. To the north-east, the site is surrounded by dense mature woodland which would act to obscure views from the north and east, these woods would also assist in providing visual screening between the existing and proposed development proposal. The potential for cumulative impacts would be considered in details as part of a Landscape and Visual Impact Assessment. The proposed solar PV development would provide opportunities to enhance green infrastructure and provide a biodiversity net gain (BNG) through the provision of new hedgerows and trees, the retention of field margins, and wildflower meadow habitats

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beneath the solar arrays. This is set out in full in the accompanying PEA. A full Landscape and Visual Impact Assessment will be prepared at full planning stage to inform mitigation planting strategies. The proposal site is situated within an Area of Greatest Opportunity for solar energy development according to the Welsh Government’s Assessment of Onshore Wind and Solar Energy Potential in Wales (March 2019); however, does not fall within a designated priority area. The site falls within less than 5km of Solar Priority Area No. 13. Levels of Emissions to Air and Arrangement for Transport of Fuel The screening proposal is for the installation of a solar farm, the characteristics of the development is that, during generation, it would not give rise to any adverse impacts with regards to the production of waste, pollution nor nuisance. There is therefore no identified risk to human health with regards to matters such as air pollution or contamination. In addition, there is no requirements for the transportation of fuel to site.

5. CONCLUSIONS

The nature of the proposed development is for a solar farm on land currently being used for agriculture. It is therefore not expected to result in any unusual, complex or potentially hazardous environmental effects. Nor would any effects extend over particularly wide area. Given the low impact of the proposal, it is considered that whilst there will be some effects upon the environment as a consequence of the scheme, none of these are considered to constitute ‘significant effects’ upon the environment, as set out in the relevant guidance. Accordingly, it is considered that the screening proposal is Non-EIA Development. For the reasons identified and discussed in this letter and summarised below, we consider an Environmental Impact Assessment is not required for the proposed development since:

• The site is located within Welsh Government's priority search area for solar development.

• The site is within Flood Zone A;

• Given the low level of trip generation onto the highway, it is apparent that the

proposals will not have a material impact and will certainly not give rise to any potential significant effects with regards to highway movement, vehicular pollution (noise and emissions);

• There are no sites of ecological importance within the boundary of the site. The

proposed development will allow the land to recover from decades of intensive farming. The land on which the solar panels would sit will be turned into species-rich meadows to support the local wildlife population. The development intends to provide a net biodiversity gain. Any planning application will be supported by extended ecological surveys as required. These surveys will provide an evidence base for a Landscape and Ecological Management Plan (LEMP), which will accompany any future submission without the need for an Environment Statement;

• Due to the local topography and existing boundary screening, the proposed

development would not appear incongruous and is not visible from all angles. The location, mass, scale and form of the proposed solar PV development is considered appropriate to the character and appearance of the landscape. Any

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long-distance visibility can be mitigated through a Planting Plan that would support any future planning application without the need for an Environment Statement;

• The scheme does not have any complex or hazardous environmental effects

both during construction and operation; and

• Any formal planning application submission would be supported by detailed LVIA and an ecological assessment. Other studies with regards to traffic, drainage, heritage and ground contamination would also be submitted and as such any adverse impacts in this regard would be identified and fully mitigated without the need for an EIA.

We look forward to receiving the Planning Inspectorate’s Screening Direction within the timeframe specified by the EIA Regulations. Should additional information be required from either the Planning Incorporate or statutory consultees please do not hesitate to contact me directly. Yours faithfully

Christine McNulty

Enc

CM/P20-13361. Background2. The development site3. Development Proposal4. EIA Requirements5. conclusionsYours faithfullyChristine McNultyDirectore-mail: christine.mcnulty@pegasusgroup.co.ukEnc