During the public event declarations were made by the representa ives ofSavills that the local authority fully endorsed this application, but this reportdoes in anyway confirm this. It raises real concerns.

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NEWPORT CITY COUNCILLOCAL IMPACT REPORT

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PINS Reference Number DNS/3216558 - Wentlooge renewable energy hub

Applicant Wentlooge Farmers' Solar Scheme Limited

; Applicants' Agent Savills

LPA Reference Number 20/0407

Application Type Development of National Significance

Proposed Development Erection of a Renewable Energy Hub comprising groundmounted solar panels, battery storage units (160 units)with a combined installed generating capacity of up to125MW, underground cabling, grid cornection hub,associated infrastructure, landscaping andenvironmental enhancements for a temporary period of40 years.

Application Site Land North Of Greeacre Farm, Coast RoadSt Brides, Wentlooge, Newport

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1.0 Preamble

1.1 This Local Impact Report (LIR) has been prepared to meet the requirements ofSection 62K of the 1990 Act, and Regulation 25 of the Developments of NationalSignificance (Procedure) (Wales) Order 2016.

1.2 Limitations: This LIR is reliant upon information available within the submitteddocuments and prior knowledge of the site. Limited internal cons4ltation has beenundertaken within the Council but no specialist or technical consult e outside of theCouncil has been consulted. Further limitations are placed b  the prescribedtimescales for response. This LIR takes note of the relevant procedural guidancecontained at Appendix 5 of the Welsh Government's 'Guidance on Developments ofNational Significance'.

1.3 We understand the LIR is a factual document that should not weigh evidence ormake recommendations but should state whether impacts are Jnticipated to bepositive, negative or neutral. As such this LIR will not qualify impacts beyond thosewords since to do so would be to apply weighting which is expressll> excluded in therelevant advice.

.4 This LIR considers the solar hub and battery storage as a single development.

2.0 RELEVANT SITE HISTORY

3.0 LOCAL PLANNING POLICY

3.1 Adopted Local Development Plan 2011-2026

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Ref. no. Description Dhclsion & datePN/18/0213 SCOPING OPINION FOR PROPOSED SOLAR FARM Scoped

AND WIND TURBINE DEVELOPMENT (49.9MW) 1ACCOMPANIED BY BATTERY STORAGE UNITS, 10/12/2019SUBSTATION BUILDINGS AND ASSOCIATED PLANT

Policy WordingSP1 - Sustainability Proposals will be required to make a positive   contribution to

sustainable development by concentrating development insustainable locations on brownfield land within   the settlementboundary. They will be assessed as to their poten ial contributionto:

i t reu ofp viously developed land and em ty properties inpreference to greenfield sites;

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iii) transportation systems, as well as encouraging the co-locationof housing and other uses, including employment, which togetherwill minimise the overall providing integrated need to travel, reducecar usage and encourage a modal shift to more sustainable modesof transport;iv) reducing energy consumption, increasing energy efficiency andthe use of low and zero carbon energy sources;v) the minimisation, re-use and recycling ofwaste;vi) minimising the risk of and from flood risk, sea level rise and theimpact of climate change;vii) improving facilities, services and overall social andenvironmental equality of existing and future comrhunities;viii) encouraging economic diversification and in particularimproving the vitality and viability of the city ce¢,tre and district

 nc serving, enhancing and linking greer·  infrastructure,protecting and enhancing the built and natural en ironment;x) conserving and ensuring the efficient use of resources such aswater and minerals. 1

SP3 - Flood Risk Newport's coastal and riverside location ne cessitates thatdevelopment be directed away from areas whfre flood risk isidentified as a constraint and ensure that the risk of flooding is notincreased elsewhere. Development will only be permitted in floodrisk areas in accordance with national guidance. Whereappropriate a detailed technical assessment will be required toensure that the development is designed to cope with the threatand consequences of flooding over its lifetirre. Sustainablesolutions to manage flood risk should be prioritised.

SP4 - Water Development proposals should minimise wate  consumption,Resources protect water quality during and after construction and result in no

net increase in surface water run-off through the sustainablemanagement of water resources by:i) the use of sustainable drainage systems;ii) the reuse of water and reduction of surface water run-offthroughhigh quality designed developments;iii) careful consideration of the impact upon finite water resources,particularly in terms of increased pressures on abstraction and theimpact of climate change;iv) ensuring development is appropriately located and phased sothat there is capacity in the waste water, sewel,age and watersupply as well as the protection of water quality. 1

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SP5 - Countryside Development in the countryside (that is, that area of land lyingbeyond the settlement boundaries shown on the proposal andinset maps) will only be permitted where the use s appropriate inthe countryside, respects the landscape character and biodiversityof the immediate and surrounding area and is appropriate in scaleand design. Housing development, rural diversifi:ation and ruralenterprise uses, beyond settlement boundaries, will only beappropriate where they comply with national planning policy.

SP7 - Green Wedges Green Wedges have been identified in orcler to preventcoalescence between the following settlements:i) Newport and Cardiff;ii) Rogerstone and Risca;iii) Bettws, Malpas and Cwmbran;iv) Caerleon and Cwmbran.Within these areas development which prejudices the open natureof the land will not be permitted. An increase in size of a dwellingof more than 30% of the volume of the original sizel of the dwelling,or as existed in 1948, will not be approved.

SP8 Special Special Landscape Areas are designated as follotws within whichLandscape Areas proposals will be required to contribute positiv ly to the area

through high quality design, materials and managgment schemesthat demonstrate a clear appreciation of the i area's specialfeatures:i) North of Bettwsii) West of Rhiwderiniii) Wentlooge Levelsiv) River Uskv) Caldicot Levelsvi) Wentwood

SP9 - Conservation The conservation, enhancement and manageme* of recognisedofthe Natural, Historic sites within the natural, historic and built environment will beand Built Environment sought in all proposals.GPl - Climate Development proposals should:Change i) be designed to withstand the predicted chances in the local

climate and to reduce the risk of flooding on site ar,d elsewhere bydemonstrating where appropriate that the risks anc consequencesof flooding can be acceptably managed, including avoiding the useof non-permeable hard surfaces;

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ii) be designed to minimise energy requirements'and incorporateappropriate renewable, low or zero carbon energy sources,including on site energy provision where practicable;iii) be designed to reuse or recycle existing construction materialspresent on the site;iv) meet the relevant breeam or code for sustainable homes level.

GP2 - General Development will be permitted where, as applicable:Amenity i) there will not be a significant adverse effect on local amenity,

including in terms of noise, disturbance, privacy, overbearing, light,odours and air quality;ii) the proposed use and form of developm nt will not bedetrimental to the visual amenities of nearby otcupiers or thecharacter or appearance of the surrounding area;  iii) the proposal seeks to design out the opportunity for crime andanti-social behaviour;iv) the proposal promotes inclusive design both for the builtdevelopment and access within and around the development;v) adequate amenity for future occupiers.

GP3 - Service Development will be permitted where, as applicable:Infrastructure i) necessary and appropriate service jnfrastructure either exists or

can be provided;ii) in areas served by the public foul sewer, there is  capacity for thedevelopment within the system or, if not, satisfactoryimprovements are provided by the developer;In areas served by the public foul sewer, development will not bepermitted with connections to private facilities unless there areexceptional circumstances that prevent connection to the publicsewer.

GP4 - Highways and Development proposals should:Accessibility i) provide appropriate access for pedestrians, cyclists and public

transport in accordance with national guidance; Tii) be accessible by a choice of means of transport;iii) be designed to avoid or reduce transport severance, noise andair pollution;iv) make adequate provision for car parking and cycle storage;v) provide suitable and safe access arrangements;vi) design and build new roads within private development inaccordance with the highway authority's design guide and relevantnational guidance;

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vii) ensure that development would not be detrimental to highwayor pedestrian safety or result in traffic generatioA exceeding thecapacity of the highway network.

GPS - Natural Development will be permitted where, as applicable:Environment i) the proposals are designed and managed  to protect and

encourage biodiversity and ecological conned,ivity, includingthrough the incorporation of new features on or dff site to further

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the uk welsh and/or newport biodiversity action plpns;ii) the proposals demonstrate how they avoid, or mitigate andcompensate negative impacts to biodiversity, enduring that thereare no significant adverse effects on areas of nature conservationinterest including international, european, nationa], welsh section4232 and local protected habitats and species, and protectingfeatures of importance for ecology;iii) the proposal will not result in an unacceptable impact on waterquality;

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iv) the proposal should not result in the loss or reduction in qualityof high quality agricultural land (grades 1,2 and 3a);v) there would be no unacceptable impact on landscape quality;vi) the proposal includes an appropriate landscapd scheme, whichenhances the site and the wider context including greeninfrastructure and biodiversity networks;Vii) the proposal includes appropriate tree planting or retentionwhere appropriate and does not result in the unacceptable loss ofor harm to trees, woodland or hedgerows that have wildlife oramenity value.

GP6 - Quality of Good quality design will be sought in all forms of development TheDesign aim is to create a safe, accessible, attractive and convenient

environment. In considering development proposals the followingfundamental design principles should be addressed:i) context of the site: all development should be sensitive to theunique qualities of the site and respond positively to the characterof the area;ii) access, permeability and layout: all development shouldmaintain a high level of pedestrian access,Connectivity and laid out so as to minimise noise pollution;iii) preservation and enhancement where possible developmentshould reflect the character of the locality but avoid theinappropriate replication of neighbouring architectural styles. Thedesigner is encouraged to display creativity and innovation indesign;

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iv) scale and form of development: new deve.opment shouldappropriately reflect the scale of adjacent townscape. Care shouldbe taken to avoid over-scaled development;v) materials and detailing: high quality, durable and preferablyrenewable materials should be used to complement the sitecontext. Detailing should be incorporated as an integral part of thedesign at an early stage;vi) sustainability: new development should be in ierently robust,energy and water efficient: flood resilient and adaptable, therebyfacilitating the flexible re-use of the building.  Vhere existingbuildings are present, imaginative and sensitive solutions shouldbe sought to achieve the re-use of the buildings.

GP7 - Environmental Development will not be permitted which would cAuse or result inProtection and Public unacceptable harm to health because of land contlmination, dust,Health instability or subsidence, air, heat, noise or light pollution, flooding,

water pollution, or any other identified risk to environment, localamenity or public health and safety.

CE4 - Historic Sites included in the register of landscapes, parks  and gardens ofLandscapes, Parks, special historic interest and identified historic battlefields should beGardens and protected, conserved, enhanced and where appro riate, restored.  Battlefields Attention will also be given to their setting.

CE6 - Archaeology Development proposals will normally be required Fo undertake anarchaeological impact assessment before the proposal isdetermined:i) where groundworks and/or the installation ef services areproposed within the archaeologically sensitive areas of caerleon,the levels, lower machen and the city centre, or;ii) within other areas of recognised archaeological interest.

CE9 - Coastal Zone Development will not be permitted in the coastal area or adjoiningthe tidal river unless:i) in the undeveloped coastal area such developrient is requiredto be on the coast to meet an exceptional need which cannotreasonably be accommodated elsewhere;ii) the area is not itself at risk nor will the proposed developmentexacerbate risks from erosion, flooding or land instabilityDevelopment which requires a coastal location should be sitedwithin the developed coastal zone.

CE10 - Renewable Renewable energy schemes will be considered favpurably, subjectEnergy to there being no over-riding environmentab and amenity

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considerations. Small scale micro-generation will I be encouragedwithin the settlement boundary. Large scale prlposals may bemore appropriately located outside of the defined settlementboundary if no appropriate brownfield sites exist  The cumulativeimpacts of renewable energy schemes will be an importantconsideration.

T2 Heavy Developments which generate heavy commercial vehicleCommercial Vehicle movements will be favoured in those locations which allow accessMovements to a railway line, wharf or dock. Where it can be demonstrated that

this is not appropriate, locations readily accessible to strategic andprincipal routes will be favoured. Elsewhere, such c evelopment willnot be permitted.

T3 - Road Hierarchy In order to facilitate the effective and safe use  of the highwaynetwork a hierarchy of roads will be established. This roadhierarchy will be used to determine the principle of access for newdevelopments, it comprises the following:i) strategic routes - these consist of the M4 motorviay, trunk roadsand the A4051 from the M4 to the Woodlands rouniabout, Malpas.These roads carry a substantial element of traffic: to and aroundthe city to major centres of population and commerce elsewhere.To facilitate the free movement of through traffic, strategic routesshould have a limited number of junctions with parking limited todesignated laybys or service areas. Only in exceptionalcircumstances and having regard to the strategic importance of adevelopment will new direct access be permitted.ii) principal routes - these consist of all principal routes which linkthe major population and employment areas in the sub-region toeach other and to the strategic routes. As a general principle, theprovision for on-street parking, new frontage access and turningmovements will be restricted in the interests of road safety and theefficient movement of traffic.iii) local roads - these provide for the main mcvements withinurban and rural areas, as well as giving access to tie strategic andprincipal road network. Where appropriate, and esoecially in orderto facilitate public transport, parking and turning niovements maybe restricted and the number of frontage accesses limited in theinterests of road safety and the efficient movement of traffic.iv) access routes - these provide access to residential areas,industrial areas, the city centre and small rural communities andbusinesses. If necessary, and for reasons of safety and amenity,traffic movements and speed will be restricted. Walking, cycling

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3.2 Supplementary Planning Guidance

e Wildlife and Development SPG (Aug 2015)• Archaeology and Archaeologically Sensitive Areas SPG (Aug 2015)• Trees, Woodland, Hedgerows and Development Sites SPG (Jan 2017)• Air Quality SPG (Feb 2018)e Parking Standards (August 2015)• Draft Sustainable Travel SPG (October 2019)

ASSESSMENT OF LIKELY IMPACT OF THE PROPOSAL

4.1 The applicant confirms the proposal is for a solar farm of 125 MW co'/ering an area of155 hectares.

The Location of the Development

4.2 The site is part of a complex landscape of historic, archaeological, ecological andrecreational value. It has significant designations as follows: 1

® Sites of Special Scientific Interest (St Brides) - extensive areas of re,:laimed wet, richflora and fauna;

• Adjacent to other statutory designations with significant bird interest, namely the RiverSevern Estuary (SSSI, SAC / SPA & Ramsar Site)

e Archaeological Sensitive Area;• Landscape of Outstanding Historic Interest;

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and bus routes will be incorporated into layouts wh,9re appropriate.These roads will often give greater priority to F edestrians andcyclists.

T4 - Parking Development will be required to provide appro priate levels ofparking, within defined parking zones, in accordan:e with adoptedparking standards.

T7 - Public Rights of Any public footpath, bridleway or cycleway affected byWay and New development proposals will require retention or the provision of aDevelopment suitable alternative. Provision of additional routes, where

appropriate, will be sought in new developments, with linkages tothe existing network.

TB-All Wales Coast Development proposals should protect and enhance the all walesPath coast path. The provision of additional routes to I nk to the coast

path will be encouraged.

• Special Landscape Area;• Important Recreational Route (All Wales Coastal Path)• Countryside and Green Wedge• Undeveloped Coatal Zone

1 • The site is within Flood Risk Zone Cl;e The records show the site to be located within Agricultural Land Classification 4.

4.3 The key Issues relating to the development as proposed are considered to be:• Landscape & Visual Impact (character & appearance);e Impact on Bio-diversity issues - Gwent Levels SSSls and bird assemblages in the

Marine SAC / Ramsar Site / SPA (River Severn);e Impact on Historic Landscape;e Impact on Archaeological Sensitive Area;e Flooding;e Undeveloped Coastal Zone;e Highways Issues;• Rural Character / Mitigation;e Noise; and• Glint and Glare

4.4 Landscape and Visual Impact

4.4.1 The key landscape documents submitted are:• Landscape and Visual Impact Assessment (within the Environmentad Statement)9 Landscape and Ecological Management Plan (LEMP) report and plan

There are some gaps in the LVIA: not al[ elements of the proposell are assessed;local (within 100m) impacts are underplayed; and landscape mitigatidn is insufficient.

The LEMP is focussed on ecological enhancement. No site-bfised landscapeappraisal has been submitted and no detailed landscape mitigation p an.

LVIA comments4.4.2 The operational phase is for a period of 40 years and across an area  of 155ha within

a number of local and national landscape, heritage and biodiversity designations,however there is no strategic capacity study for solar farm development within theWentlooge Levels to be able to assess the proposal against.

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4.4.3 The LVIA follows the industry standard and has a computer g nerated Zone ofTheoretical Visibility which has been ground tested through the use of eight'representative' viewpoints.

4.4.4 All elements of the proposal should be incorporated into the LVIA. It isunderstandable given the scale of the solar arrays, but there are a  number of gaps.The LVIA should also include a description and assessment of smaller elementswhich may have a more local landscape impact:

• Proposed 16m high telecoms tower and CCTV poles; 2m high boundary fencing;battery storage unit; Grid Yard

e The proposal to remove 1.Sign of hedgerow along reens within the site (to meetecological objectives) is not assessed; the existing vegetation withirt the site helps tovisually break-up the expanse of the solar farm and is clearly shown in thephotomontage for viewpoint 1

• The LEMP includes 22.1 ha of grassland for lapwing as compensatory habitat. Noinformation on this is included other than removal of hedges, scrub, trees will beundertaken to create open habitat. This may be conditioned. but the impacts ofvegetation removal on landscape character and visual amenity should be assessedwithin the LVIA.

• There is no assessment of existing poor views. New boundary planting would not onlysoften views of the solar arrays, but could also have a positive benefit in softeningexisting poor views outside the site, for example views from the 84239 to highlyreflective farming and industrial buildings.

4.4.5 There is no cross referencing to other related documents:• The ASIDOHL identifies a severe impact for the landscape character area Maerdy

HLCA21 which includes the majority of the site.• The Glint and Glare report identifies mitigation is required for five dwellings (ref 8.5). but this is not in either the LVIA or LEMP

4.4.6 The LVIA plan reference L31 shows photomontages from all 8 of the selectedviewpoints.

• The greatest impact is evident at viewpoint 1. It is not clear whether this is intended tobe 'representative' of views adjacent to the site and a ground- level viewpoint fromBroadway or the 84239 may have been more representative as viewpoint 1 is elevatedin the otherwise flat landscape.

• There are no photos taken from within the site looking out to demonstrate the extentof views.

• Viewpoint 1 photomontage shows the landscape character impact will be more thanminor-negligible (10.6.54 and 10.6.55) and visual effects more than minor for all usergroups including overlooking residents (10.6.102).

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• The impact of a minor change from the Wales Coast Path may also be underplayed(10.6.39). Although the closest point to the site is 60Om, photomontage 4 at 95Omdistance appears to show more than a minor change may be experienced. The detailon several photomontages is difficult to view. Showing the wireframe separately fromthe rendered image may help better understand the impacts. 1

4.4.7 The operational phase landscape character and visual amenity impacts are generallyunderplayed for the site and immediate setting. Examples include:  

' ® 10.6.42 mentions the lack of boundary vegetation and the open views from Hawse' Lane, 84239 and Broadway, but concludes a minor-negligible adVerse landscape

character impact. 1• 10.6.45 states the impact of the character change for local reside ts will be minor

adverse.• 10.6.49 identifies the magnitude of change is identified as small within 1km.

. 0 10.6.55 Landscape Effects during the 40 year operational phase  re identified asminor adverse to negligible

• 10.6.102 Visual Effects during the 40 year operational phase are id4ntified as minoradverse (moderate adverse for walkers and cyclists)The photomontage from viewpoint 1 demonstrates there will be m6re than a minorimpact on neighbouring residential properties and from drivers using all boundaryroads, in particular Broadway and the 84239 which are frequently us'ed.

4.4.8 Paragraph 10.7.1 - recognises that to meet local authority polices, landscapeenhancement measures are required, but none have been proposed.

• 10.5.1 states the grid yard and battery storage to be screened with additionalhedgerow

0 10.6.13 states new hedgerow to strengthen existing boundariese 10.6.100 identifies visual effects as Moderate Adverse within 10Om but no mitigation

. is proposed• The mitigation section of the Environmental Statement (17.2) mentions the need for

new planting under Cultural Heritage and Landscape and Visual.e Constraints on new planting have not been fully explored in the LVIA or shown on a

site analysis plan. In contradiction to sections highlighting the need for new planting,other sections mention constraints to maintain the historic open character and toconserve rush pasture habitat. As the existing baseline information for the site andboundaries has not been fully assessed and there are no new planting proposals, it isdifficult to judge whether a balance has been struck between the need for new plantingand the constraints.

4.4.9 There is a lack of detail for the following elements which are urban elements that willbe introduced into a flat rural landscape:

• 16m high telecoms tower

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• battery storage unit, no dimensions or materials are confirmed, the colour is identifiedin the LVIA as 'green' and elsewhere in the ES [17.2 Landscape anc·of mitigation measures] as green or brown. A colour assessment is

Visual summaryrecommended to

ensure the hue selected blends in with the natural colour palette of the WentloogeLevels.

e Sm high CCTV pole - materials, colour, locations are not clear.

4.4.10 There are insufficient landscape mitigation measures:• The LVIA should include a detailed assessment of local visual impacts and the

potential for mitigation both within the site and at the site boundaries.

LEMP comments4.4.11 The document contains no detail of landscape mitigation measures and landscape

objectives are missing from section 4. The mitigation is entirely Ecological: hedge

. removal to improve SSSI condition, bird and dormice boxes, habitat piles.

4.4.12 The mitigation proposals from a landscape viewpoint do not meet the LocalDevelopment Plan policy GP5 General Development Principles - Natural Environmentvi:  the proposal includes an appropriate landscape scheme.........'.

4.4.13 No management prescriptions for boundary reens are included. Botti reed and hedgemanagement regimes should be specified with the objective of maintaining the limitedscreen.

4.4.14 A site based analysis and landscape plan response is required imaintenance/management plan covering both new and existingplanting.

and a long termhedge and reed

  4.4.15 The Council considers that the Landscape & Visual impact of the proposal would benegative. The Council also considers the impact on the Wentlooge Levels SpecialLandscape Area to be negative. See SLA3: Wentlooge Levels; Specia[ LandscapeAreas Background Paper (June 2013) and the submitted LVIA.

4.5 Ecological Impact

4.5.1 Insufficient information has been provided for the Welsh Government to consider the'Three Tests' under the Conservation of Habitats and Species Regulations 2017 andappropriately fulfil the wider duties under that same legislation and the Wildlife andCountryside Act 1981 and Environment (Wales) Act 2016.

4.5.2 The surveys of the proposed development site have been co prehensive andfollowed the requirements detailed in the NRW scoping opinion. Hodever there havebeen no surveys undertaken of the off-site lapwing mitigation area.

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Off-site Lapwing Mitigation Area4.5.3 The Environmental Statement (ES) and Landscape and Ecological Management Plan

(LEMP) refer to a 22 ha area off-site that will be enhanced and managed for winteringlapwing to compensate for on-site loss of habitat. Only a blue line boundary isprovided of this off-site compensation area, with other details promi ed in a LapwingManagement Plan. No details of the current habitats or species present in the off-sitemitigation area have been provided, but Section 5.1.3 of the LEMP states thatgrassland created for lapwing through the "removal of hedges, scrub and trees tocreate an open habitat". This is likely to result in the loss of priority h'abitat, potentiallyincluding habitat supporting European protected species (dormice and bats).Furthermore, the site may potentially already support lapwing,   and cannot beenhanced to provide space for the numbers displaced from the development site.

  4.5.4 The Council considers that the absence of sufficient information would result in anegative impact on the local overwintering lapwing population. As ah interest featureof the Severn Estuary Special Area of Conservation (SAC) and Ramsar site, furtherinformation on mitigation for overwintering birds is needed ta inform HabitatRegulations Assessment required by Regulation 63 of the Conservation of Habitatsand Species Regulations 2017, in accordance with the EC Habitats Directive (CouncilDirective 92/43/EDC) before the 'Competent Authority' under the Regulations cangrant permission for the project.

4.5.5 The proposed "enhancements" of the mitigation area would result in the loss of habitatwith potential to support European Protected Species. There is insufficient data toconsider the whether the proposals will be detrimental to the maintenance of thepopulation of European Protected Species at a favourable conservation status in theirnatural range. The assessment can therefore not fulfilthe "three tests" requirements,under Regulation 55 of the Conservation of Habitats and Species Regulations 2017.

Development Site4.5.6 The development site lies wholly within the Gwent Levels St Brides Site of Special

Scientific Interest (SSSI). The surveys have confirmed that the development site is ofnational importance for wildlife as would be expected of a SSSI designated site.Almost all the site is classified as Coastal and Flood Plain Grazing Marsh priorityhabitat, which is defined by proximity to water, topography and mahagement ratherthan the underlying substrate or the vegetation. The habitat is not often botanicallydiverse but is important for the range of bird and invertebrate species supported byseasonally inundated pastures. On site, the habitat comprises a range of grasslandfrom marshy grassland to improved grassland, and the reen and ditch system whichvaries in condition. The ES would benefit from providing a quantitative analysis of howmany of the reens and ditches of the Gwent Levels St Brides SSSI will be affected bythe proposal, and the extent of ditches that will be brought back in to favourablecondition by the mitigation.

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4.5.7 1nvertebrate surveys confirm that the site supports nationally important assemblagesof species including nationally notable species such as the shrili carder-bee andbrown-banded carder-bee. In addition to this, surveys have confirmed the presenceof other protected and priority species such as dormouse and grass snake. Many birdspecies were recorded with 30 species confirmed or probablb breeding andoverwintering birds which are associated with the Severn Estuary, including 300+lapwing.

4.5.8 A LEMP is provided which provides a summary of the existing ecological features,recommendations to be included in a CEMP to protect features during construction,and recommendations for future management. To avoid and mitigate impacts duringconstruction a Construction Environmental Management Plan (CEMP) isrecommended in the ES and LEMP, but has not been provided to date and thereforewill need to be secured with a condition.

4.5.9 The ES predicts that with mitigation the development will result in a neutral or positiveimpact on most of the wildlife supported by the site, as a result of reduced fertilizerinput and more sensitive management practices. However, the LEVIP is not robustenough to secure enforceable actions that will result in protectior  of species andenhancement of habitats, for the reasons summarised below:

• Habitat creation/enhancemento How many 'cattle watering features' will be retained and created? How will they

be maintained as open features? Locations should be shown on a map.o What species will be used to plant up gaps in hedgerows? Which hedgerows

will be enhanced? Specification of planting stock should be provided.o The area of habitat created for shrill carder bee does not cor¢espond between

the ES (2.6 ha) and the LEMP (3.2 ha).o The LEMP states that one of the reen buffers will be managed for invertebrates

to link with the fields around the fishing ponds; this is not shown on the plan.o It is unclear if the fields around the fishing ponds will be enhanced/managed for

invertebrates; it should be highlighted on the map.o The detail of how species-rich grassland will be created is insufficient.o See comments above on the creation of the off-site Lapwing mitigation area.

Habitat managemento The detail on how reen casting will be carried out should be included.o The LEMP states that the "selected buffers" will be managed for shrill carder

bee; the minimum length of buffer that will be managed each year and theirlocation (on a rotational basis if required) should be provided.

o No details on how the fishing ponds and the surrounding fields will be managedare included.

o It is recommended that rotational management of hedgerows ls reduced to 2-3years and the cutting time is restricted to winter months to retain the berryresource throughout the autumn. 1

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o No details on the stocking density of the solar array fields has been providedo No fertiliser is specified on the fields managed for shrill carder bee, but this

implies it can be used on fields housing the solar arrays.

4.5.10 The LEMP refers to a forthcoming Monitoring and Contingency plan. BS 42020specifies that the LEMP should include details of monitoring and remedial areas.Without this detail, it is not possible to assess whether appropria e mitigation andcontingency is feasible should there be negative impacts as la result of thedevelopment. Additionally, section 7.2.2 of the LEMP refers to action s relating to windturbine blades with regards to bat fatalities, which are obviously not applicable here.

4.5.11 The species assemblage of Coastal and Flood Plain Grazing Marsh is likely to changeas a result of shading from the solar arrays. Whilst this does not 6ffect the priorityhabitat designation, it is likely to have consequences for the invertebrate species

. supported by it. At present, due to the wording of the LEMP, it is  only possible toenforce habitat management suitable for invertebrates on the area of created habitaton the west boundary of the site. Although managing "selected buffers" and the fieldsaround the fishing ponds is referred to (Sections 6.2.3 and 6.3.3 respectively), thedetail is insufficient to compare the area of post-development habitat available toinvertebrates, and also to ensure that suitable management practicfs are followed inthese areas. Given that 128 ha of Coastal and Flood Plain Grazing Marsh will be

+ modified a significant increase in the area of habitat managed for invertebrates shouldbe secured.

4.5.12 Planning Policy Wales requires that "development should not cause significant loss ofhabitats or populations of species, locally or nationally and must provide a net benefitfor biodiversity". The information provided to date does not provide certainty thatsuitable management can be enforced to guarantee that the development does notresult in a loss for biodiversity. Furthermore, management in compensation for habitat. loss does not equate to an overall enhancement, and the opportunity to create newhabitats by making the fishing pond suitable for wildlife should be considered.

4.6 Historic Landscape

4.6.1 The site lies entirely within the Gwent Levels Historic Landscape. The site partiallycovers two character areas within the wider Gwent Levels HLW: Western St Bridesand Maerdy. An assessment using the Assessment of the Impact of Development onHistoric Landscapes 2 methodology has been undertaken. Whilst comments fromthe Glamorgan Gwent Archaeological Trust and CADW will be cr tical the Councilnotes that the ASIDOHL 2 carried out by the Archaeology Coliective concludes thatthe overall significance of impact on the Western St Brides HLCA is moderate andon the Maerdy HLCA is severe.

4.6.2 The Council concludes that the impact would be negative.

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4.7 Archaeological Impact

4.7.1 The site lies within an Archaeological Sensitive Area. Impacts on tile archaeologicalresource could be permanent and irreversible depending on the extent of groundintrusion. It is noted that the ES concludes that there is a moderatesignificance of effect if archaeological remains are found; and there

to major adverseis a moderate to

high potential for this to happen during the construction phase. It i 3 also noted thatthe ES states that a programme of archaeological works can be conditioned,comprising an archaeological watching brief with contingencies. The Council notesthatthere is ongoing work with GGAT to agree the programme of worl:s. Without agreemitigation there would be a neciative impact.

4.8 Flooding

. 4.8.1 The site lies within a defended floodplain (Cl) as identified in the WeIBh Government'sDevelopment Advice Maps. It will be necessary to show that the effecls of tidal floodingcan be acceptably managed on the site.

4.8.2 Technical Advice Note 15 requires that location of the developmen 1 within the floodplain is justified. The test at Paragraph 6.2 of the TAN reads as folknvs:

i. Its location in zone C is necessary to assist, or be part of, a local authorityregeneration initiative or a local authority strategy required to suatain an existingsettlement; or,ii Its location in zone C is necessary to contribute to key employment objectivessupported by the local authority, and other key partners, to sustain an existingsettlementor region;and,iii It concurs with the aims of PPW and meets the definition of prev,ously developedland (PPW fig 2.1); and,iv The potential consequences of a flooding event for the particular type ofdevelopment have been considered, and in terms of the criteria contained in sections5 and 7 and appendix 1 found to be acceptable.

4.8.3 The test requires that the scheme is necessary in the proposed location whichsuggests that no other site was suitable or available. Notwithstanding the negativeecological, landscape and historic impacts idenitifed above, which need to be weighedin the balance, the Council notes that the submission includes a Site SelectionSequential Test, which concludes that there are no suitable, ViE ble or availablealternative sites in the search area that are capable of accommodating the proposeddevelopment.

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4.8.4 The site is not Previously Developed Land for the purposes of PPW and on its facethe proposal cannot be justified in the chosen location.

4.8.5 The Council notes that the applicant has submitted a Flood ConsequencesAssessment and we defer to Natural Resources Wales for their advice on thatmatter. Notwithstanding this, if the proposal is unjustified developmdnt within a floodplain then the impact would be negative. If the development can be, justified and thesubmitted flood Consequences Assessment shows a flood event is manageable,consideration should be given to the impact of powerless from the grid. Subject tojustification the impact of the scheme in flooding terms is likely to bd negative due tothe replacement of a less vulnerable use with a more vulnerable us4.

4.9 Coast

  4.9.1 The site is located within the undeveloped coastal zone and this designation requiresthat only development which is required to be on the coast to meet an exceptionalneed which cannot be met elsewhere. If the site is in a flood risk area, this must notexacerbate erosion, [and instability or flood risk. An exceptional ' need should bedemonstrated to satisfy NLDP policy CE9 (Coastal Zone).

4.9.2 The Welsh National Marine Plan will need to be satisfied. It is noted that this plan isnot mentioned in the planning statement. It is considered that it should be consideredif only to screen it out.

4.10 Access and Highways

4.10.1 The development would have its biggest impact during the construction and de-commissioning phases. The impacts are considered to be negative without mitigationunder conditions.

4.10.2 The chosen route set out for all construction traffic, except abnormal loads, is from theA48, onto the A4232 to Lamby Way, Wentloog Avenue (84239) then finally ontoBroadway. The construction traffic will need to be controlled so as to, avoid any peakhour flows. The maximum number of HGV movement is typically 23 per day, this willbe on weeks 8 and 9 only of the 12-week construction phase.

4.10.3 For the occasional abnormal load, the route will be from junction 28 of the M4, alongthe A48 to Castleton, turning onto Marshfield Road. Using this route reduces the timean abnormal load is on the highway network. An abnormal load travelling through theCastleton area should do so when the school (Marshfield Primary) is closed. It is notedthat there is not expected to be many, if any abnormal load movements.

Existing Highways4.10.4 A road condition survey will need to be carried out jointly by the applicant and the

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Council. This will identify any locations where the highway may be substandard, so itcan be monitored and/or repaired as necessary. This can be :3et out within aplanning condition.

Access onto the Development Site4.10.5 Within the construction phase the main access will be off Broadway. Drawing 194740-

AO-01 sets out tracking diagrams for a maximum legal length HGV. The trackingshows that the vehicle uses all the available road and access space. There is noleeway for error and this could lead to verge damage. This access point may be subjectto improvement works, with part of this works carried out within the highway. Longterm, other entry points are expected to be required for maintenance purposes.

Parking4.10.6 Sufficient parking space should be allowed for onsite with strict instruction that no on-

. road parking will be allowed. This should form part of a Construction TransportManagement Plan (CTMP) detail. A CTMP should be a requirement set out in aplanning condition.

4.10.7 Al[ highway entry points must meet the required construction and visibility standards.These details can be controlled through a condition.

Transport Assessment4.10.8 The traffic count information for Marshfield Road contained within tte Environmental

Statement is considered to be dated (table 8.3). This should be updated to reflect ayear within 5 years of the date of the submission.

4.10.9 Table 8.1 sets out two traffic surveys however, the ATC location plari sets out threeATC count locations. The anomaly should be addressed.

  4.11 Rural Character / Mitigation

4.11.1 Consideration should be given to any proposed mitigation to protect the rural characterof the area. Proposed planting and use of materials in traci<,vays should beconsidered. The scale and location of any structures to house switch gear etc. shouldbe assessed and sited sensitively. Proposed lighting and signage  should be fullycognisant of the site's rural location as should any workto improve acqess, for exampleopening of field gates or the improvement of visibility splays.

4.11.2 Mitigation secured under condition is likely to reduce adverse impacts but there will bea significant and prolonged change in the character of the area shduld the proposalgo ahead. This will be negative in landscape and visual terms. Hov/ever large solarfacilities are not atypical in rural areas and there is no presumption against them.

4.12 Noise

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4.12.1 There are residential properties adjacent to and opposite the development site. Uponreview of the submitted noise assessment, it is noted that there are many unknowns;site layout isn't known, plant type isn't known, location of plant isn't known, quantities

I of plant aren't known and therefore a lot of assumptions are made.

4.12.2 Tonality Factor - the report states that tonality isn't possible to determine from themanufacturers data and it is not expected to be tonal however, if the plant isn'tselected yet we can't be sure there is no tonal element. Once the plant has been

i selected, the manufacturers data sheets could be obtainable (and tterefore the 1/3rdoctave data).

4.12.3 Intermittency factor - the noise report also assumes the plant will -un continuously,, however it is possible that the fans would cut in and out for cooling. Again, this is

unknown at this stage.

4.12.4 All of the above could vastly change the outcome of the assessment as no correctionfactors have been applied. The impact on residential properties could be negative

, without mitigation, which should be controlled by condition.

1.13 Glint and Glare

4.13.1 The technical assessment of glint and glare concludes that potentially glint and glarecould occur at 5 dwellings. However, through the subsequent detailed assessment itwas determined that the nature of these effects would be reduced due to a range ofmitigating factors. Consequently, it was considered that only a low significance of

i effect would occur in respect of all identified receptors. The impact of glint and glareis considered to be neutral.

;4.12 Power Generation

4.12.1 The scheme would generate 49.9MW of electrical power sufficient to power 15,000homes and prevent the release of 21,000 tonnes of CO2 per year. This would bepositive. ,

5.0

5.1 This is attached to this LIR (see Appendix A).

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SUGGESTED CONDITIONS

PLANS: This proposal shall be carried out in accordance with the following plans:Drawing 4929574/01/E Site Location PlanDrawing 4929574/02/F Site Layout PlanDrawing 4929574/04/D Field Numbering PlanDrawing 1045592/07 Typical Details - Sheet 1Drawing 1045592/08 Typical Details - Sheet 2Reason: to comply with Paragraph 4.16 of Welsh Government Circular 016/2014(Conditions).

LIFETIME OF THE PROPOSAL: The permission hereby granted shall exp re 40 years fromthe date when electrical power is first exported ('first export date') from the solar farm to theelectricity grid network, excluding electricity exported during initial testing an£i commissioning.

  Written confirmation of the first export date shall be provided to the Local Planning Authorityno later than one calendar month after the event.Reason: the proposed scheme has a 40 year lifespan.

CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN: No development shallcommence until a construction environment management plan has been :;ubmitted to andapproved in writing by the Local Planning Authority. The constructio 7 environmental

, management plan shall set out details of all on-site construction works;reinstatement; drainage; mitigation; and other restoration, together wittimetabling. It shall include details of, and measures to secure:(a) the phasing of construction works;(b) the formation and position of the temporary construction compounds;(c) contractor and operational on-site vehicle parking;(d) dust management and suppression;

post-constructiondetails of their

(e) cleaning of site entrance, facilities for wheel washing and cleaning the adjacent public  highway;

(f) pollution control, including the protection of water courses and grourd water; subsoilsurface water drainage; bunding and siting of fuel storage areas; sewag 3 and foul waterdrainage and disposal; and emergency procedures and pollution response olans;(g) temporary site illumination during the construction period;(h) the methods to be adopted to reduce the effects of noise occurring during the constructionperiod to the lowest practicable levels and in accordance with BS 5228: ,\loise control onconstruction and open sites;(i) storage of materials and disposal of surplus materials;(j) the construction of the accesses into the site, the erection of any entrante gates and thecreation and maintenance of associated visibility splays;(k) access tracks and other areas of hardstanding, including areas of temporary road matting;(1) the carrying out of foundation works, including the foundation of the solar arrays and anyother structures to be installed on the site;

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(m) method of working cable trenches, including soil storage and back-filling; and details ofcable boring methodologies below reens / ditches / other water courses and below hedges;(n) general soil storage and handling; o) post-construction restoration/reinstatement of the working areas, including cable trenchesAnd area covered by any matting or other areas where the soil has b en disturbed orcompressed;(p) the sheeting of al[ heavy goods vehicles construction materials to, or spoil from, the site

t)pitta ilt 5 15veeti  s 3 befus      s te dthr g ico  ruction activitiE S0 details of control of surface water to prevent it entering the public highway or carryingsediment to the surface water drainage network in the vicinity of the site.ls) identification of buffer strips adjacent to water courses or retained vegetation featuresAuch as hedges or trees and sites where birds are nesting; t) means to exclude small animals from excavations.

  The works shall proceed in full accordance with the agreed construction method statement.Reason: to protect the interests of the rural character of the area, the intedrity and safety ofthe highway network and to protect the amenity of residents, ecological interests and to4nsure the site is appropriately restored.

ANALYSIS OF LANDSCAPE ENHANCEMENT: Notwithstanding the information submittied1no development shall commence until a site based analysis and landscape plan has been ubmitted to and approved in writing by the Local Planning Authority. The analysis shall onsider the balance of providing appropriate landscape enhancement and maintaining thehistoric open character. In accordance with the outcome of that analysis the landscape planshall detail a scheme of landscape enhancement. Any new planting shall be implemented bythe end of the first full planning season (October to March inclusive) available after the firstexport date.Reason: to protect the historic and special landscape character of the area.

NDSCAPE MANAGEMENT AND MAINTENANCE: Notwithstanding   the informationsubmitted no development shall commence until a long term maintenance/management plan,which covers both new and existing hedge and reed planting, shall be submitted to anapproved in writing by the Local Planning Authority. All landscape features shall bemaintained and managed in accordance with the approved plan.Reason: to protect the special landscape character of the area.

HEDGEROW REMOVAL: Notwithstanding the information submitted full details of anyhedgerow, scrub and tree removal shall be submitted to and approved in writing by the LocalPlanning Authority. The details shall include:

• Precise location of hedges to be removed• Removal methodology• Timing of Removal• Mechanism to prevent disturbance to nesting birds and other fauna

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No hedge, scrub or trees shall be removed until the details are agreed in vuriting. No hedge,scrub or tree shall be removed that has not been identified for removal.  Reason: to provide ecological enhancement, to protect landscape features and to protect theinterests of fauna and the relevant SSSIs.

DETAILS OF ANCILLARY PLANT AND EQUIPMENT: Prior to their installation details ofmaterials, colour and position of the battery storage unit, 16m high telecoms tower and 5mhigh CC-TV poles shall be submitted to and approved in writing by thJ, Local PlanningAuthority. The storage unit and equipment shall be finished in accordance with the approveddetails.Reason: to reduce their visual impact and to protect the special landscape character of thearea.

LIGHTING: There shall be no permanent illumination on the site unless otherwise agreed in  writing by the local planning authority.

Reason: to protect the rural character of the site.

HABITAT CREATION/ENHANCEMENT: Notwithstanding the informaticn submitted nodevelopment shall commence until the Landscape and Ecological Management Plan (LEMP)is updated and submitted to and approved in writing by the Local Planning Authority. TheLEMP shall include the following details: I

• The number of 'cattle watering features' to be retained and created. How they bemaintained as open features and their locations shown on a map.  

• The species to be used to plant up gaps in hedgerows and a specification of plantingstock.

• Confirmation of the area of habitat to be created for shrill carder bee• A plan showing the position of the reen buffer to be managed for invertebrates to link

with the fields around the fishing ponds.• A plan highlighting the field around the fishing ponds to be enhanced/managed for

invertebrates.• How species-rich grassland will be created.e How reen casting will be carried out.• The minimum length of buffer that will be managed for Shrill card er bee and their

locations.• Management of fishing ponds and the surrounding fields.• Stocking density of the solar array fields• The use, if any, of fertiliserto be used on fields housing the solar arrays.

Reens, ditches and associated buffers, fields containing solar panels and Shrill Carder Beemitigation and enhancement area shall be managed and monitored in acc rdance with theupdated LEMP. Invertebrate surveys; and Water Vole and Otter mitigation strategies shallalso be carried out in accordance with the updated LEMP.Reason: to ensure ecological mitigation and enhancement is achieved.

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LAPWING MANAGEMENT PLAN: No development shall commence until a LapwingManagement Plan for the off-site compensation area (as shown in 0475/LEMP Fig 1Landscape and Ecological Management Plan) has been submitted to and approved in writingby the Local Planning Authority. The Lapwing compensation area shall oe provided andmanaged in accordance with the approved plan.Reason: to ensure ecological mitigation and enhancement is achieved.

MONITORING AND CONTINGENCY PLAN: No development shall  ommence untilmonitoring and contingency plans for bats and Water Vole have been qubmitted to andapproved in writing by the Local Planning Authority. The development shall be carried out inaccordance with the approved plans.Reason: to ensure ecological mitigation is achieved.

TREES: No trees shall be removed other than identified in the Arbcricultural Impact  Assessment (Savills, March 2020). No tree shall be removed until it has teen confirmed it

does not contain nesting birds or a bat roost.Reason: to protect the ecological interests, protected species and the landscape characterof the area.

ARCHAEOLOGY: No development, to include demolition, shall takeimplementation of a programme of archaeological work has been secured in

place until theaccordance with

a written scheme of investigation which has been submitted by the applicent and approvedin writing by the Local Planning Authority.Reason: To identify and record and features of archaeological interest discovered during theworks, in order to mitigate the impact of the works on the archaeological resource within anArchaeologically Sensitive Area.

FOUNDATION DETAILS & LEVELS: Prior to the installation of the battfpry storage unitsdetails of the platforms they will be sited on and the slab level of those platforms shall be

  provided in writing to the Council. Following the Council's written agreemi:nt the platformswill be built as agreed.Reason: to protect visual amenity and to limit ground intrusion in the interests of archaeology.

ROAD CONDITION SURVEY: No development shall commence until a road condition surveyhas been submitted to and approved in writing by the Local Planning Authority. The surveyshall identify any locations where the highway may be substandard; and jointly with theCouncil's City Services set out a timetable for monitoring and/or repairs. The monitoringand/or repairs shall be carried out in accordance with the approved timetabje.Reason: To protect the integrity and safety of the highway network.

DETAILS OF ACCESS: No development shall commence until details of the main access offBroadway have been submitted to and approved in writing by the Local Planning Authority.The details shall include track testing and improvement works to ensure HGV's do not cause

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damage to the highway verge. The access shall be provided in accordance ¥,ith the approveddetails.Reason: To protect the integrity and safety of the highway network.

DETAILS OF TRACKWAY CONSTRUCTION: No tracks shall be constructed on the site untildetails of their construction have been provided in writing to the Local Planning Authority.Following the Local Planning Authority's written agreement any tracks shall be constructedfully in accordance with the agreed details.Reason: to ensure any tracks are constructed in a fully reversible way in the long4erminterests of appropriately restoring the site to reduce the risk of increased rates of run-off.

TRAFFIC MANAGEMENT PLAN: No HGV shall access the site until details of a trafficmanagement plan (TMP) has been submitted to and approved in writi "g by the LocalPlanning Authority. The TMP shall include details of:

.. Signage;· Details of temporary traffic management measures, such as traffic lights;· HGV routes and timings to avoid peak hour flows; and school drop off*ick up times.Reason: to protect the integrity and safety of the highway network.

NOISE ASSESSMENT: Notwithstanding the information submitted no development shallcommence until an updated noise assessment has been submitted to and a proved in writingby the Local Planning Authority. The assessment shall . The assessment ,'.which should becarried out in accordance with BS4142 :2014) should jnclude full details  of all plant andequipment, manufacturers data upon which they rely, full details of calculations, correctionsand predictions and details of any enclosures. Any mitigation shall be identified, agreed andimplemented prior to the operation of the plant.Reason: to protect residential amenity.

CONTAMINATION: Any unforeseen ground contamination encountered dufing development,I  to include demolition, shall be notified to the Local Planning Authorit  as soon as is

practicable. Unless otherwise agreed in writing by the Local Plannihg Authority asunnecessary, an appropriate ground investigation and/or remediation strategy shall besubmitted to and approved in writing by the Local Planning Authority, and the approvedstrategy shall be implemented in full prior to further works on site. Following' remediation andprior to the occupation of any building, a Completion/Verification Repori, confirming theremediation has being carried out in accordance with the approved details, shall be submittedto and approved in writing by the Local Planning Authority.Reason: To ensure that any potential risks to human health or the wider er»onment whichmay arise as a result of potential land contamination are satisfactorily addressed.

DECOMMISSIONING: Decommissioning and restoration: Not later than 12 months beforethe expiry of this permission, a decommissioning and site restoration Acheme shall besubmitted for the written approval of the Local Planning Authority. The sc eme shall makeprovision for the removal of the solar panels and all other associated equipment &

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paraphernalia and the subsequent restoration of the site. The scheme shall include detailsOf:

• the extent of equipment and foundation removal and the site restoration to be carriedout;

• the management and timing of any works;e a traffic management plan to address likely traffic impact issues during the

decommissioning period;e an environmental management plan to include details of measures to be taken during

the decommissioning period to protect wildlife, habitats and tree feat res on the site;e identification of access routes;• location of material laydown areas;e full details of the removal of the solar arrays, associated buildings and plant, any

trackways and sub-surface cabling and al[ associated works of gtound restorationincluding trench backfilling;. , full details of all works to restore the land to allow for agricultural production followingthe removal of structures from the site;

• a programme of implementation.The approved scheme shall be implemented within 6 months of the expiry of this permissionand then proceed fully in accordance with the agreed details in accordance with thedecommissioning programme. 6Reason: to ensure the site is fully restored and to maintain the rural appearance of the area.

REPAIR, REPLACEMENT AND REMOVAL OF SOLAR FARM: If the s61ar farm herebypermitted fails to produce electricity for supply to the grid for a continuous period of 6 months,a scheme shall be submitted to the Local Planning Authority for its written approval within 3months of the end of that 6 month period for the repair or removal of the solar farm. Whererepairs or replacements are required the scheme shall include a proposed programme ofremedial works. Where removal of the solar farm is required the scheme shal[ include the

  same details required under the decommissioning condition of this permission. The relevantscheme shall thereafter be implemented in accordance with the approved details andtimetable.Reason: to ensure the solar farm beneficially generates electricity or is otherwise removed tothe benefit of the character and appearance of the area.

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