Report A4 TMPL NP - GOV.UK€¦ · ForeSite™, vuWind™, ... Summary, Residual and Synergistic Effects and Mitigation.....70 21. ES Accompanying documentation .....70 22. Responding

Alwen Forest Wind Farm

Scoping Report

28 June 2018

1171877

Innogy Renewables UK Ltd

NATURAL POWER CONSULTANTS LIMITED, THE NATURAL POWER CONSULTANTS LIMITED, NATURAL POWER SARL,

NATURAL POWER CONSULTANTS (IRELAND) LIMITED, NATURAL POWER LLC, NATURAL POWER S.A, NATURAL POWER

SERVICES LIMITED AND NATURAL POWER OPERATIONS LIMITED (collectively referred to as “NATURAL POWER”) accept no

responsibility or liability for any use which is made of this document other than by the Client for the purpose for which it was originally

commissioned and prepared. The Client shall treat all information in the document as confidential. No representation is made regarding

the completeness, methodology or current status of any material referred to in this document. All facts and figures are correct at time of

print. All rights reserved. VENTOS® is a registered trademark of NATURAL POWER. Melogale™, WindCentre™, ControlCentre™,

ForeSite™, vuWind™, WindManager™ and OceanPod™ are trademarks of NATURAL POWER.

Copyright © 2018 NATURAL POWER.

For full details on our ISO and other certifications, please visit: naturalpower.com/company

Local Office: Registered Office:

Harbour House Y Lanfa Aberystwyth SY23 1AS WALES UK Tel: +44 (0) 1970 636 869

The Natural Power Consultants Limited The Green House

Forrest Estate, Dalry Castle Douglas, Kirkcudbrightshire

DG7 3XS

Reg No: SC177881

VAT No: GB 243 6926 48

Document history

Author Ffion Edwards, Senior Project Manager 28/06/2018

Checked Lesley Rice, Project Support Officer 04/07/2018

Approved John Woodruff, Head of Projects 03/08/2018

Client Details

Contact Jeremy Smith

Client Name Innogy Renewables UK Ltd

Address Baglan Bay Innovation Centre,

Central Avenue,

Baglan Energy Park,

Port Talbot.

SA12 7AX

Issue Date Revision Details

A 28/06/2018 First Draft to innogy

B 05/07/2018 Second Draft issued to NRW

C 03/08/2018 Final Scoping Report submitted to PINS


Contents

1. Introduction ....................................................................................... 1

2. The Proposed Alwen Forest Development ....................................... 2

3. Consultation ...................................................................................... 9

4. Approach to the Environmental Impact Assessment (EIA) ............... 9

What the EIA will Assess ................................................................ 10

Gathering Baseline Information ....................................................... 11

Prediction and Evaluation of Impacts and Effects ........................... 11

5. Legal and Policy Context ................................................................ 13

6. Environmental Statement ................................................................ 14

7. Embedded Mitigation and Further Layout Iterations ....................... 15

8. Purpose of this Scoping Report ...................................................... 15

9. Ecology ........................................................................................... 16

10. Ornithology ...................................................................................... 23

11. Landscape and Visual ..................................................................... 28

Assessment Methodology ............................................................... 30

Cumulative Assessment .................................................................. 34

Residential Visual Amenity .............................................................. 36

12. Hydrology, Geology and Hydrogeology .......................................... 36

13. Cultural Heritage ............................................................................. 45

Environmental Baseline and Potential Sources of Impact .............. 45

Method of Assessment .................................................................... 46

Consultation .................................................................................... 51

Matters Scoped Out ........................................................................ 51

14. Traffic and Transport ....................................................................... 51

Previous Wind Farm Assessments ................................................. 52

15. Noise ............................................................................................... 56

Construction Noise .......................................................................... 60

16. Forestry ........................................................................................... 61

Introduction ..................................................................................... 61

Consultation .................................................................................... 61

Legislation and Guidance ................................................................ 62

Methodology .................................................................................... 62

17. Socio-Economics ............................................................................ 63

Introduction ..................................................................................... 63

Methodology .................................................................................... 63

18. Health and Public Safety ................................................................. 64

Shadow Flicker ................................................................................ 64

Ice Throw ........................................................................................ 64

Lightning .......................................................................................... 65

Health & Safety ............................................................................... 65

Impact Assessment ......................................................................... 65

19. Aviation and Existing Infrastructure ................................................. 66

Other Existing Infrastructure ........................................................... 69


20. Summary, Residual and Synergistic Effects and Mitigation ............ 70

21. ES Accompanying documentation .................................................. 70

22. Responding to the Scoping Report ................................................. 71

Appendix A: Proposed Turbine co-ordinates ............................................ 72

Appendix B: Consultation Meeting Notes ................................................. 73

List of Figures

Figure 2.1: Regional Context

Figure 2.2: Preliminary Site Layout

Figure 2.3: Site Constraints

Figure 9.1: Statutory Designated Sites

Figure 10.1: Vantage Point Locations and Viewsheds (canopy height)

Figure 11.1: Zone of Theoretical Visibility to Turbine Tip (200 m) to 45 km

Figure 11.2: Zone of Theoretical Visibility to Turbine Tip (200 m) to 15 km

Figure 11.3: Cumulative Wind Farms

Figure 13.1a: Designated Sites, Monuments and Designed Landscapes

Figure 13.1b: Designated Sites, Built Heritage

Figure 13.2: Denbigh Moors Character Areas

Figure 13.3: Non-designated heritage assets (CPAT HER data)

Alwen Forest Wind Farm 1

1. Introduction

1.1.1. This Scoping Report has been prepared by Natural Power Consultants Limited (Natural Power) on

behalf of Innogy Renewables UK (innogy) in anticipation of an application for a Development of National

Significance (DNS) for a wind farm development located approximately 4 km north of Cerrigydrudion

within Conwy County Borough Council (CCBC) and Denbighshire County Council (DCC). This scoping

request is made in relation to a Development of National Significance for the purposes of section 62D of

the 1990 Act.

1.1.2. Under the statutory procedures set out in The Town and Country Planning (Environmental Impact

Assessment) (Wales) Regulations 2017 (EIA Regulations) it is proposed that any such application is

accompanied by an Environmental Statement (ES).

1.1.3. The purpose of this Scoping Report is to provide sufficient information for consultees to agree the scope

of the ES. Information has been provided on what the applicant intends to assess within the ES. When

the applicant is proposing to ‘scope out’ particular elements sufficient information and justification has

been provided in this report. The intention is to ensure the focus in the ES is on any receptors impacted

by the proposed development that may experience significant effects.

1.1.4. Consultees will note that the Scoping Report contains a number of questions, which it would be useful to

receive a response on. Not all questions will be relevant to all consultees; therefore we request that

consultees provide feedback only on those questions appropriate to them. The questions should not be

considered an exhaustive list, and consequently, consultees are invited to provide further responses on

any issue they consider relevant to the proposed development. If consultees elect not to respond,

innogy will assume that consultees are satisfied with the approach adopted/proposed.

The Applicant

1.1.5. The applicant, Innogy Renewables UK Limited (innogy), develops, builds and operates projects to

generate power and extract energy from renewable sources. It is part of Innogy SE; an established

European energy company which was formed from the restructuring of the RWE Group and started

operations on 1 April 2016. innogy firmly believes in making our planet a better place. innogy has eight

offices across the UK and operates more than 1 gigawatt of renewable energy capacity. In the UK,

innogy currently operates 18 onshore wind farms, 3 offshore wind farms and 24 hydro sites.

1.1.6. innogy has a significant history of developing renewable energy infrastructure in Wales, having built the

UK’s first commercial offshore wind farm in Wales in 2003. innogy has four offices across Wales

(Baglan, Mostyn, Llanidloes and Dolgarrog) and employs 138 permanent or fixed term members of staff.

We currently operate three offshore wind farms and six hydroelectric power stations across Wales, with

three onshore wind farms under construction, namely Clocaenog Forest in North Wales (96 MW),

Mynydd y Gwair near Swansea (32.8 MW) and the soon to be inaugurated Brechfa Forest West in

Carmarthenshire (57.4 MW). These three onshore wind farms alone amount to a total capital investment

of circa £272 million and a green pipeline of 186 MW of renewable energy. Once these projects are

operational they will invest a further ~£1.4 m each year into the surrounding communities through their

associated Community Investment Funds. We have a 20 year track record of investing in the

communities that surround our developments and in 2017 renewable energy projects operated by

innogy invested over £900,000 into community projects across Wales.

1.1.7. The innogy team was able to use its local knowledge derived from the development of the Clocaenog

Forest and offices in North Wales, to assist its consideration of feasibility and design of the Alwen Forest

Wind Farm.


2. The Proposed Alwen Forest Development

2.1.1. Alwen Forest Wind Farm lies within commercial forestry and is part of the Dŵr Cymru Welsh Water

estate leased to Natural Resources Wales (NRW). The majority of the site boundary is located within

Conwy County Borough Council (CCBC) local authority area, with a small part of the proposed site

boundary within the neighbouring Denbighshire County Council (DCC) local authority area. The entire

proposed infrastructure layout currently lies within CCBC, however, the small area within DCC may be

utilised as part of the application and therefore remains as part of the site boundary for the purpose of

scoping.

2.1.2. Technical Advice Note 8, published in 2005, was prepared by Welsh Government, identifying seven

areas in Wales suitable for large scale wind farm developments. The site is located within Technical

Advice Note 8, Strategic Search Area A, as shown on Figure 2.1.

2.1.3. The proposed wind farm lies in the vicinity of the Brenig and Clocaenog wind farms, which are currently

at the construction stage, the operational Tir Mostyn Wind Farm, and consented Pant y Maen and

Derwydd Bach wind farms. See Figure 2.1 found at the end of this document.

2.1.4. The proposed development is summarised as follows:

Up to 9 wind turbines up to 200 m to tip;

Turbine foundations;

External transformer housing;

Crane pads;

Access tracks and entrance points (new and upgrades);

Substation and control building, along with potential battery storage facilities;

Underground electricity cables between the turbines and the onsite substation;

Temporary borrow pits (number to be confirmed);

Drainage attenuation measures as necessary;

Temporary construction and storage compounds and ancillary infrastructure; and

Peat Restoration Area/Habitat Management Area.

2.1.5. The proposed development will have its own on-site substation. Figure 2.2 shows the location of the

‘proposed substation and energy storage’ and also an ‘alternative substation and energy storage’. Two

options have been presented at this stage as the grid route corridor is currently unknown. Only one out

of the two substation and energy storage options will be required as part of the proposed development,

2.1.6. It is expected that the turbines will be 3 Mega Watt (MW) or greater in capacity, with a total site capacity

possibly up to 33 MW. A separate connection to the wider distribution grid network will likely be at the

existing Clocaenog substation located to the north-east of the site, which has sufficient grid capacity for

the proposed development. Together with the level of wind resource in the area, the proposed

development is in an ideal location to help contribute to the UK and Welsh Government’s renewable

energy targets.

2.1.7. There has been considerable change in the onshore wind market in recent years. It is vital that onshore

wind farms maximise their efficiency, to reduce electricity costs for consumers. Therefore larger, more

productive turbines that maximise energy yields need to be considered.

2.1.8. The scoping report is presented for a wind farm which responds to Welsh Government’s commitment to

decarbonising electricity generation with a target of 70% of Wales’ electricity demand to be met from

renewable sources by 2030. The Alwen Forest proposed development maximises the potential of this


site to deliver on these objectives and has been designed in such a way as to balance society’s needs

for efficient sustainable energy generation with the relevant environmental considerations.

2.1.9. The number of smaller turbines, especially those suitable for use in forestry, available across Europe, is

reducing due to a lack of demand and advances in technology (see Diagram 2.1 which demonstrates

this point). Larger turbines need to be considered if onshore wind development is to continue to make a

contribution to the Welsh Government’s renewable energy targets.

Source: innogy

Diagram 2.1: Graph demonstrating how turbine tip height impacts on wind turbine availability in the market

Project Design

2.1.10. The following key considerations have been taken into account during the design process of the Alwen

Forest Wind Farm:

A commercially viable development (assuming no UK Government subsidy);

Relationship to the surrounding landscape;

Relationship with existing and consented developments; and

Technical and environmental constraints.

2.1.11. A key aim of the design process was to limit the overall footprint of the development. The proposed

layout aims to make best use of the site characteristics for the scale of project proposed, including use

of slopes and improving existing forestry tracks rather than building new tracks. The site has an

extensive system of forestry tracks that have been used to assist with the layout design. The forestry

tracks tend to run along the contours; issues arise when crossing contours however the illustrative layout

takes this into account and aims to optimise the improvement of existing tracks rather than building new

tracks.

2.1.12. The layout has been influenced by landscape and visual receptors within 20 km of the site, as this is the

distance within which significant effects are most likely to occur. However, it also considered effects on


Snowdonia National Park, and the Clwydian Range and Dee Valley Area of Outstanding Natural Beauty

(AONB) at greater distances because of the sensitivities associated with these designated areas. Within

and close to the site, the assessment considered effects on recreational users of the trails for walkers

and cyclists around Alwen Reservoir and Llyn Brenig. Properties close to the site boundary include

Hafod y Llan in the south east, Elorgarreg to the east, Craig yr Iyrchen to the south and Pen-y-ffrith and

Tan-y-graig to the north; larger communities include Pentre-llyn-cymmer to the south east and Cefn-brith

to the south, with many more along the A5 in the valley to the south of the site.

2.1.13. The layout of the development has followed an iterative process. The initial layout presented here

evolved in response to visual and landscape impacts and additional constraints or opportunities

identified through other environmental and technical feasibility studies. These set a cap on the

generation capacity of the site, and also identified areas that were potentially unsuitable for development

due to peat, ecology (e.g. known black grouse lek management areas adjacent to site) and cultural

heritage considerations (See Figure 2.1).

2.1.14. Design iterations considered lower-lying views from Snowdonia National Park where the turbines will be

seen on the skyline forming a relatively evenly spaced group. In more elevated and distant views

including the summit of Snowdon the turbines will be backclothed, and seen as part of a spread of

operational and under construction wind farms across the horizon including Tir Mostyn, Brenig,

Clocaenog, and Wern Ddu. From Moel Famau in the AONB, the wind turbines will be seen in the context

of Clocaenog and will not be seen in front of the distinctive skyline of the mountains of the National Park

including Snowdon.

2.1.15. A key design aim was to achieve a simple and coherent layout that responds well to the landform and

the pattern of existing wind farms on the horizon to the east.

Wind Turbines and Transformers

2.1.16. The specific turbine model has not yet been selected but it will be a three-bladed configuration; see

Photograph 2.1. The Applicant is scoping up to 200 m turbines to tip in order to capture as much energy

as possible, maximising efficient use of natural resource assisting in meeting Welsh, UK and

international renewable energy target, along with making the project financially viable. Other projects are

emerging across the UK with similar size turbines, including Kype Muir Wind Farm which is currently at

scoping stage with up to 220 m tip turbines, Fetteresso Wind farm, currently at scoping stage up to 200

m tip turbines, and Crystal Rig IV Wind Farm, currently at application stage with up to 200 m tip turbines

proposed. Turbines of this size and greater have been installed on numerous sites in Europe and the

technology, construction and operational issues well understood.

2.1.17. Such turbines are likely to have external transformers; see Photograph 2.2 for an example of an external

transformer. External transformers are generally preferred for health and safety reasons.

2.1.18. The proposed grid co-ordinates for the current nine turbine layout can be found in Appendix A.

2.1.19. Crane pads would be left in-situ following erection of turbines to allow for maintenance and replacement

of parts as necessary during the lifetime of the project, however, these would be allowed to naturally

revegetate when not in use with any vegetation being scraped away prior to use.

2.1.20. The proposed access route for the delivery of turbine components, transformers and the cranes would

be the same as that used for Brenig and Clocaenog (as discussed further in Section 14 of this report).


Source: innogy turbine at Brechfa Forest Wind Farm Source: Natural Power

2.1.21.

Photograph 2.2: Indicative external transformer

Photograph 2.1: Indicative turbine 2.1.22.

Battery Storage

2.1.23. The Applicant is exploring the possibility of installing battery storage within Alwen Forest Wind Farm

which would comprise lithium-ion or similar batteries housed in shipping containers or contained within a

building adjacent to the proposed substation. The battery storage will also contain electrical inverters

and transformers. Photograph 2.3 demonstrates an indicative battery storage proposal.

2.1.24. A potential location for the battery storage has been identified within the substation compound (see

Figure 2.2). Each assessment will assess all infrastructure therefore will include the battery storage

facility as part of the substation compound assessment.


Source: reNews

Photograph 2.3: Battery Storage at Pen y Cymoedd Wind Farm, South Wales

Access Tracks

2.1.25. Existing access tracks would be utilised where possible but additional site tracks would be required to

link the new turbines to the existing forestry site track network. Photograph 2.4 illustrates a typical wind

farm access track. The routes would be chosen to minimise potential impacts on the environment and

the ES will include rationale for their location.

2.1.26. The current layout for the main development area includes 7.6 km of upgrading to existing access track

and only 2 km of proposed new tracks. The link track to the substation will require upgrading of just over

1 km of existing track and 500 m of new track. The potential borrow pit tracks identified include

approximately 5.8 km of existing track that are likely to be adequate for heavy goods vehicles and

therefore possibly not requiring an upgrade (to be confirmed during further site work).

2.1.27. An alternative entry point to the site has been identified, as shown on Figure 2.2 and 2.3, close to

proposed Turbine 4. Both entry points into the northern section of the site will be investigated further as

part of the EIA process and only one option presented in the application. The alternative access

presented close to Turbine 4 includes 6.5 km of upgrading to existing access track (therefore reduced

length) and approximately 2 km of proposed new tracks.


Source: Natural Power

Photograph 2.4: Typical access track

Borrow Pits

2.1.28. Borrow pits may be used as sources of suitable quality aggregate if suitable locations are found on site.

It is proposed to use temporary borrow pits on site to reduce the potential effects on the environment

and transport network associated with transporting stone to site. The ES will include details of the

proposed locations for on-site borrow pits (See Figure 2.2 for preliminary borrow pit locations). A

detailed restoration strategy would be produced pre-construction as part of an appropriately worded

suspensive condition.

Construction Environmental Management Plan

2.1.29. A Construction Environmental Management Plan (CEMP) would be created and agreed with the CCBC

prior to construction commencing through an appropriately worded suspensive condition in order to

ensure the impacts from construction are kept to a practical minimum. The CEMP would set out the

method statements for constructing site infrastructure, measures that would be undertaken by

contractors to ensure good site practice with regards to construction practices and environmental

management. Such measures would include for the transport and storage of potentially polluting

substances such as oils and lubricants as well as waste management, for example.

2.1.30. Should the proposed development be consented best practice guidelines and method statements will be

adopted to ensure again that the development does not impact negatively on the local environment. Best

practice guidance and mitigation will apply during the construction, operational and decommissioning

phases of the wind farm.

Habitat Management Plan

2.1.31. A Habitat Management Plan (HMP) may be required as part of the proposed development in order to

mitigate or compensate for any likely significant effects resulting from the proposed development. The

provisions set out in any HMP may be delivered on-site or off-site.

2.1.32. The aims and objectives of such an HMP will evolve during the course of the EIA process as further

ecological baseline survey results and detailed peat probing surveys are obtained.


Grid Connection

2.1.33. The wind turbines for use on the proposed Alwen Forest would produce electricity at 690 - 1000 Volts.

The electricity would then be transformed to 33,000 Volts (33 kV) via a transformer likely to be located

immediately adjacent to the base of the tower of each turbine, however could be positioned within the

tower, depending on the final turbine model used. The transformers would be linked to the on-site

substation via high voltage underground cables placed in trenches, which would generally be adjacent to

and alongside the on-site access tracks. From the substation there will be a grid connection that links to

the wider electricity distribution network.

2.1.34. Connection to the wider electricity network will likely be at Scottish Power Energy Network’s Clocaenog

Forest substation located north east of the site, maximising use of the remaining spare capacity on the

132 kV connection to St Asaph. This is likely to be the lowest cost option for connection to the grid and

minimising the environmental impact. It is unknown at this stage whether this would be overhead line or

underground cable, or a combination of the two. It is likely that details of the grid route will be provided in

a separate application and will not form part of the wind farm application, although a brief assessment

will be undertaken for each discipline within the Alwen Forest Wind Farm ES as appropriate.

Operational Period

2.1.35. The wind farm would generally operate automatically, whilst being overseen by an operations team

located remotely. Each individual turbine would operate independently from the other turbines. Within

the operational wind speed range the pitch angle of the turbine blades of each individual turbine would

be automatically adjusted by the control system within the turbine, as appropriate for the measured wind

speed. Should sensors, placed within the nacelle of the turbine, register any instability in the structure or

any other malfunction in operation or should wind speeds increase over safe limits, then the turbine

would be automatically shut down. If the cause of the shutdown is high wind speeds then the turbine

would automatically recommence operation once average wind speeds fell to within the operational

range (generally between approximately 4 metres per second (m/s) and 25 m/s, i.e. 9 miles per hour

(mph) and 56 mph. Under other causes of shut down the turbine would remain shut down and in a safe

condition until manually restarted by a member of the operations and maintenance team.

2.1.36. The lifetime of the project would be up to 35 years from commissioning to decommissioning. To ensure

that turbines continue to operate with acceptable availability in addition to maintenance in the event of

malfunctions, regular pre-planned maintenance and servicing programmes are performed at the site on

each turbine. Minor scheduled maintenance checks tend to be carried out every 6 months with major

services being performed annually throughout the lifetime of the turbine. Each turbine would contain

lubricating and hydraulic oils. These are changed during regular maintenance operations. In the

unlikely event of a lubricant leak the fully sealed tower bottom would act as a bund containing the

spillage until it can be appropriately cleaned up.

2.1.37. Storage of other potentially polluting substances at the site during the operational period of the wind

farm would only take place where agreed with the relevant authorities.

2.1.38. Maintenance and operational staff on site would make use of a control building facilities located adjacent

to the proposed substation.

Decommissioning

2.1.39. At least six months prior to the decommissioning of the site a Decommissioning Method Statement

would be prepared and agreed with the relevant consultees. Best practice guidelines will be utilised at

this time. The applicant would expect to commit to a planning condition regarding decommissioning and

expected to set up a restoration fund should this development receive consent.


3. Consultation

Community Consultation

3.1.1. Natural Power and innogy believe public consultation is important throughout the development of a wind

farm. As this is a Development of National Significance project there is a requirement under article 11 of

the Developments of National Significance (Procedure) (Wales) Order 2016 that a DNS application must

be accompanied by a Pre-Application Consultation report.

The community within the area surrounding the proposed development will be consulted. This is

anticipated to include meetings and public exhibitions in local community venues, such as village halls

and will allow local residents an opportunity to view and discuss the proposal, provide comments and

ask any questions. English and Welsh speaking staff will be on hand as well as bilingual written

information. The events will be timed to allow any concerns to be raised and potentially addressed in the

final design. A project website will also be established and updated as development progresses. Contact

details for the project would be made available on the website and shared in the local community

including a dedicated project email address to field any queries and ensure two way communications.

Question 1: Do consultees have any comments in relation to the proposed approach to community consultation?

Other Stakeholder Consultation

3.1.2. Natural Power and innogy consider consultation with statutory and non-statutory consultees as an

integral part of the iterative EIA process and recognise the benefits in carrying out early consultation with

all concerned parties. The consultation will progress with the circulation of this Scoping Report and will

continue for the duration of EIA process.

4. Approach to the Environmental Impact Assessment (EIA)

4.1.1. The EIA is a statutory procedure which draws together in a systematic way an assessment of the likely

significant environmental effects arising from a proposed development.

4.1.2. As the process has numerous steps, it allows for the opportunity to ‘design out’ adverse environmental

effects at an early stage through the design of the project. This of course is generally preferable to

mitigation or remedy at a later stage.

4.1.3. An iterative design approach is already in process for this project and will continue to be adopted

throughout the EIA process, which will allow the proposed development to have adopted a design that

works well for both the local environment and environmental resources within the area, as well as being

an economically viable scheme with the ability to deliver on Welsh, UK and international renewable

energy targets.

4.1.4. The steps taken for informing and developing the EIA process are identified in the flow diagram below:


Diagram 4.1: EIA Process

4.1.5. For this particular project the collection of the baseline data has begun and preliminary data is

available. Along with innogy and Natural Power’s project experience in the area, we have a

comprehensive understanding of the site and the local vicinity. Likewise, statutory and non-statutory

consultees will also be aware of the environmental resources in the area, and the possible impacts from

the proposed development. This has allowed for the design identified within the Scoping Report to have

identified and ‘designed out’ impacts to the environment already.

4.1.6. The information within this Scoping Report will be sufficient to provide consultees with the information to

agree on those features and topics that are likely to experience a significant effect, and thus ‘scope out’

the rest. In doing so the impact assessment will be focussed and proportionate to those that will

actually influence the decision as to whether or not the project should receive consent.

4.1.7. The impact assessment will determine for those assessed receptors what the effect, either directly or

indirectly will be from the project, by comparing the baseline conditions with the conditions that would

prevail should the proposed development be constructed, operated (and decommissioned). The

environmental effects of the project will be predicted in relation to environmental receptors (i.e. people),

built resources and natural resources. A distinction will be made in the assessments between impacts

and effects, where:

Impacts are defined as the predicted change to the baseline environment attributable to the scheme;

and

Effects are the consequence of impacts on environmental resources or receptors.

What the EIA will Assess

4.1.8. The EIA will address the construction phase of the wind farm, the operational phase which would last up

to 35 years, and the decommissioning phase.

4.1.9. The geographical coverage of the EIA will take account of the following:

The physical extent of the proposed works;

The nature of the baseline environment and the manner in which effects are propagated; and the


National and Local planning and policy context for the scheme.

Gathering Baseline Information

4.1.10. Some of the baseline data has already been collected for this project, and the assessment team will

ensure that sufficient data is obtained to enable a robust assessment, appropriate to the nature and

scale of the proposed works. The extent of the baseline assessment will be determined using both

professional judgement and industry best practice. The EIA will also identify areas where the baseline

may change, prior to the construction and operational phases of the proposed development from current

conditions (for example, maturation of landscaping).

4.1.11. The collection of baseline data will be achieved through desk study (including the use of data gathered

for the previous developments in the area), consultation, field survey and monitoring and will be clearly

reported in the subsequent sections, or within the ES (should there be an expected significant impact

from the development). In line with the regulations, the ES will also indicate any difficulties encountered

in compiling environmental baseline conditions; such as access to land to carry out surveys where

permission was not granted.

Prediction and Evaluation of Impacts and Effects

4.1.12. The prediction of impacts examines the change to the baseline environment that could result from the

construction and operation of the scheme. The effects will be classified into one or more of the following:

Positive effects that have a beneficial influence, negative effects that have an adverse influence;

Temporary effects that persist for a limited period only, due for example to particular construction

activities;

Permanent effects that result from an irreversible change to the baseline environment or which

persist for the foreseeable future;

Direct effects that arise from activities that form an integral part of the proposed development;

Indirect effects that arise from activities not explicitly forming part of the proposed development;

Secondary effects that arise as a result of an initial effect of the scheme; and

Cumulative effects that arise from the combination of different impacts at a specific location, the

recurrence of impacts of the same type at different locations, the interaction of different impacts over

time, or the interaction of impacts arising from the scheme in conjunction with other development

projects.

4.1.13. There is no statutory definition of what constitutes a significant effect. A significant effect may be

broadly defined as an effect which, either in isolation or combination with others, should be

taken into account in the decision making process. This general definition will be used as the basis

against which the significance criteria for environmental disciplines will be developed. The threshold of

significance for predicted effects tends to vary between the environmental topics. The assessment team

will ensure that a consistent approach is applied where suitable to prevent undue weight being given to a

particular discipline to the detriment of another.

Cumulative

4.1.14. The list of cumulative sites to be considered for each individual assessment will be agreed with CCCBC

and any other relevant consultees. The proposed methodology for including cumulative projects is noted

where possible within each individual discipline discussed in this scoping report.

4.1.15. It is proposed however that the consented Derwydd Bach scheme is scoped out of the cumulative

assessment as the connection agreement between the grid supplier and Tegni Cymru Cyf was

terminated on 12 October 2015 (as noted in the Examining Authority Report for the North Wales Wind


Farms Connection 28/04/2016 in Paragraph 2.4.161), therefore it is considered that the developer is not

currently progressing this scheme.

Question 2: Do consultees agree that Derwydd Bach should not be assessed in the cumulative assessment?

Mitigation and Monitoring of Environmental Effects

4.1.16. Mitigation measures will be considered for each significantly adverse effect. The ES will include a

description of the measures envisaged to prevent, reduce and where possible remedy any significant

adverse effects. In line with the regulations, when identifying mitigation measures, the proposed

development will take into account the practicability and cost effectiveness of the proposals and their

efficiency in reducing environmental impacts. Where practical, mitigation measures will be set out as

commitments which will ensure they are implemented. Where the effects of the impact are significant,

and where there is uncertainty in the mitigation proposed, monitoring may be proposed to ensure that

the mitigation is both required and effective. Monitoring will allow for adaptation of the mitigation

measures to ensure that they are fit for purpose. Monitoring will be proportionate to the level of

significance experienced and not simply proposed as monitoring for monitoring sake.

4.1.17. Once the final design has been adopted and account has been taken of any mitigation measures,

residual effects will be listed. The significance of a residual effect will be determined by correlating the

magnitude of the change arising from the scheme with the sensitivity of the particular attribute under

consideration. The magnitude of change will be evaluated in accordance with Table 4.1.

Table 4.1: Magnitude of Change

Magnitude Description

High Total loss or major alteration to key elements/features of the baseline conditions

Medium Partial loss or alteration to one or more key elements/features of the baseline conditions

Low Minor shift away from the baseline conditions

Negligible Very slight change from baseline conditions


4.1.18. Where applicable in carrying out individual assessments, a scale of increasing sensitivity of the resource

or receptor will be defined. This may be defined in terms of quality, value, rarity or importance and can

be classed as ‘Low’, ‘Medium’ or ‘High’. For certain assessment areas, guidance will be taken from the

value attributed to elements through designation or protection under law. Where assessment of this

nature takes place the correlation of magnitude against sensitivity will determine a qualitative expression

for the significance of the residual adverse effect. This is demonstrated in the matrix below, Table 4.2:

1 Available from: https://infrastructure.planninginspectorate.gov.uk/wp-

content/ipc/uploads/projects/EN020014/EN020014-002551-

Examining%20Authority%20Recommendation%20Report.pdf [Accessed 04/07/18]

https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/EN020014/EN020014-002551-Examining%20Authority%20Recommendation%20Report.pdf




Table 4.2: Significance of Effect

Magnitude of Change

Sen

sit

ivit

y

Substantial Moderate Low Negligible

High Major Major/Moderate Moderate Moderate/Minor

Medium Major/Moderate Moderate Moderate/Minor Minor

Low Moderate Moderate/Minor Minor Minor/Negligible


4.1.19. Those residual adverse effects indicated as Major and Major/Moderate will be regarded as being

significant effects in terms of the relevant legislation. However, other factors may have to be

considered including the duration and the reversibility of the effect.

Question 3: Do consultees have any comments in relation to the Approach to the Environmental Impact Assessment and to mitigation and monitoring? We intend to focus the EIA on the significant effects and therefore propose to scope out non-significant effects.

Securing Commitments and Mitigation through Planning Conditions

4.1.20. Where commitments and mitigation have been discussed within this scoping report they will form part of

the ES and therefore ensure that they are secured if the proposal receives consent through specific

planning conditions.

5. Legal and Policy Context

5.1.1. The application will conform to the statutory requirements legislated by the Environmental Impact

Assessment (Wales) Regulations 2017.

5.1.2. A Planning Statement will accompany the application for consent and assess the proposed development

in a legal and policy context against the relevant legislation and planning policies in force. The Planning

Statement will assess such documents at international, national, regional and local levels, where

applicable, including but not limited to:

Planning Policy Wales Edition 9 (November 2016)

Technical Advice Note 8 (2005) Welsh Government

Conwy County Borough Council Local Development Plan (2013);

Conwy County Borough Council Supplementary Planning Guidance LDP 17: Onshore Wind Turbine

Development (January 2015)

Denbighshire County Council Local Development Plan (June 2013);

Denbighshire County Council Renewable Energy Supplementary Planning Guide (April 2016); and

Conwy and Denbighshire Landscape Sensitivity and Capacity Assessment for Wind Energy

Development (May 2013).

5.1.3. Any other emerging Supplementary Planning Guidance will also be accounted for in the submitted ES

with the appropriate weighting given relative to established policies.

5.1.4. It is recognised that this renewable energy development would contribute to the goals of the Well-being

of Future Generations (Wales) Act 2015, and meet the principles of the Sustainable Management of

Natural Resources (SMNR) as required by the Environment (Wales) Act 2016. The project would focus


on these and references provided on how the project helps meet the goals and principles set out in

these Acts.

6. Environmental Statement

6.1.1. The EIA process will result in the production of an Environmental Statement (ES). The ES will identify

those features/ receptors that have been agreed are likely to have a significant effect from the proposed

development (or cumulatively with other projects), and will have an influence on the decision process.

6.1.2. The ES will focus on each of the broad topics identified within this Scoping Report, plus any others that

develop throughout the remainder of the EIA process until submission.

6.1.3. Where features are considered, the assessment methodology, results, effects and mitigation proposed

(if any) will be included. This will allow for the residual effect from the proposed development to be

identified to allow the competent authority sufficient information to determine the application.

6.1.4. The ES will supplement the application and will also be accompanied by a Non-Technical Summary

(NTS) a Pre-Application Consultation (PAC) Report, and a Planning, Design and Access Statement.

6.1.5. The ES is likely to follow the structure in Table 6.1:

Table 6.1: Proposed ES structure

Section Title

Introductory 1 Introduction

2 Legal and Policy Context

3 Approach to EIA

4 Site Selection and Design

Evolution

5 Project Description

Biological Environment 6 Ecology Assessment

7 Ornithology Assessment

Physical Environment 8 Landscape and Visual Impact

Assessment (LVIA)

9 Cultural Heritage Assessment

10 Hydrology, Geology and

Hydrogeological Assessment

Population and Human

Health

11 Traffic and Transport Assessment

12 Noise

13 Forestry Assessment

14 Health and Public Safety

15 Aviation and Existing Infrastructure

Conclusion 16 Residual Effects & Mitigation


Question 4: Do consultees have any comments in relation to the proposed chapters to be included in the ES?

6.1.6. The ES will be produced both in a hard copy print and electronically. For the majority of consultees,

unless otherwise requested, the ES will be provided electronically. Upon submission of the application,

these documents will be made available for public inspection at appropriate locations to be agreed with


the determining body and local planning authorities and will be distributed to the relevant consultees. A

bilingual Non-Technical Summary will be submitted alongside the ES, which will provide a summary of

the main findings and will be written in a non-technical language to help enable a better understanding

and overview of the assessments for the general public.

7. Embedded Mitigation and Further Layout Iterations

7.1.1. The design of Alwen Forest Wind Farm to date has been an iterative process, and the layout has

avoided environmental and physical constraints as far as possible (embedded mitigation).

7.1.2. Throughout the remainder of the EIA process (until the submission of the ES), it may be that the layout

presented here in the Scoping Report, further develops (especially in light of the Scoping Opinion and

public consultations). Should the layout change from now to the application, it should be noted that the

layout presented within this Scoping Report represents a ‘worst case scenario’ (e.g. the layout

presents the maximum potential number and tip height) and therefore the proposal as identified now will

have the greatest environmental impacts, and generally any amendments to the design will not increase

the likelihood of a significant effect.

7.1.3. Should any changes occur that are likely to have a significant effect on the receptor these will be

included within the EIA. If the changes are not likely to have a significant effect, these will first be

discussed with the relevant consultees, to ensure that they too are in agreement with the applicants’

understanding before excluding them from the ES.

8. Purpose of this Scoping Report

8.1.1. The applicant and its competent experts, as well as stakeholders, have already gained a sound

understanding of the proposed development area from the work at adjacent wind farms.

8.1.2. For this application we propose to continue stakeholder consultation into the scoping stage in order to

provide information on the proposed development area’s baseline conditions and the possible impacts

from the development. Therefore this report utilises the existing information, experience from the

existing wind farms and data gathered to date to focus on key areas and likely significant effects in

agreement with consultees. Other minor and non-significant issues will be scoped out, and thus not

included within the final submission in the ES.

8.1.3. Whilst this larger Scoping Report will inevitably require more engagement from key consultees at an

early stage, the eventual ES submitted should be more streamlined than previous ES submissions and

focus only on likely significant effects. The applicant will ensure that regular and continued liaisons

with key stakeholders (including the community) are carried out and documented to agree the

assessment baseline, methodology and thus the EIA process and final ES documents will be more

efficient and streamlined.

Question 5: Do the consultees have any comments about the proposed approach to scoping and the purpose of the Scoping Report?

8.1.4. In the following sections the subject areas to be covered in the Scoping Report and ES are provided.

Where it is considered that certain subjects or particular aspects within subjects can be scoped out of

the ES, evidence and a rationale is provided.


9. Ecology

Introduction

9.1.1. This section sets out the proposed approach to assessing potential ecological effects of the Alwen

Forest Wind Farm.

Use of Existing Information to Inform the Interpretation of Impacts

9.1.2. Detailed existing baseline ecological information for Alwen Forest is limited to monitoring data for red

squirrel (Sciurus vulgaris), pine marten (Martes martes)2 and some information on peat depth and

associated semi-natural habitats, all of which have been collected and supplied by Natural Resources

Wales.

9.1.3. Other species and habitat information for the site is more ad hoc, albeit programmes of ecological

survey to inform the nearby (consented) Pant y Maen, Clocaenog and Brenig wind farm schemes

provide very useful context and an understanding of likely issues.

Embedded Mitigation and Layout Iterations

9.1.4. The current proposed site design incorporates the following:

A 100 m setback from all known watercourses. This is primarily a measure to minimise the potential

for impacts on potable water supplies (e.g. through sedimentation during construction); however it

will also reduce the potential for impacts on mammals, fish and invertebrates associated with

freshwater habitats.

Avoidance of known areas of deep peat for turbine placement. It is possible that one or more new or

upgraded access tracks will cross areas of peat in excess of 5 m depth, but preliminary layouts

indicate deep peat will be largely avoided.

The retention of most of the more mature stands of thinned plantation and connectivity within the

forest. These are of importance to the small red squirrel population that is present.

Avoidance of an area of ancient woodland close to Alwen Reservoir, and impacts on semi-natural

riparian woodland along the reservoir edge.

Legislation and Guidance

9.1.5. The approach to the collection of baseline ecological data will be based on industry standard guidance

wherever this is available and applicable to the site. For example, Phase 1 habitat survey has been

undertaken in accordance with Joint Nature Conservation Committee (JNCC) (2010) guidelines3, otter

survey will follow Chanin (2003)4, and bat survey has been designed to take account of emerging wind

farm guidance (Scottish Natural Heritage, in Press5) as well as the guidance it will supersede when

published (Bat Conservation Trust, 20126).

2 A radio-collared individual from the Welsh release scheme has been recorded regularly on site. The animal

has now lost its collar, but can be distinguished by its distinctive facial markings.

3 JNCC. (2010). Handbook for Phase 1 habitat survey - a technique for environmental audit. JNCC,

Peterborough

4 Chanin, P. (2003). Monitoring the otter Lutra lutra. Conserving Natura 2000 Rivers Monitoring Series No 10.

Peterborough, English Nature

5 Scottish Natural Heritage. (In Press). Bats and onshore wind turbines: survey, assessment and mitigation.

SNH, Inverness.

6 Bat Conservation Trust. (2012). Bat surveys: good practice guidelines. Second edition. BCT, London.


9.1.6. Particular consideration has been given to habitats and species listed under Annexes 1 and 2 of the

Habitats Directive (92/43/EEC), Schedules 5, 8 and 9 of the Wildlife and Countryside Act 1981 (as

amended) and Section 7 of the Environment Wales Act (2016) in deriving the detailed approach to the

work.

9.1.7. The approach to ecological impact assessment will be based on Chartered Institute for Ecology and

Environmental Management (CIEEM) guidance7.

Methodology

Consultation

9.1.8. A meeting was held with Natural Resources Wales (NRW) in February 2018. This was attended by

members of the North Planning and Energy Delivery teams, and by Matthew Ellis, Senior Species

Officer.

9.1.9. The aim of the meeting was to discuss and agree an approach to the ecological survey work, obtain

further information to inform the scope of the desk study, and to establish clear lines of communication

for further consultation at key stages in the baseline data collection programme. The minutes of the

meeting were subsequently agreed with NRW (see Appendix B at the end of this document).

9.1.10. The local authority ecologist for Conwy County Borough Council (CCBC), Barbara Owsianka, was

informed of the proposed approach to ecological and wider ornithological work via an initial letter (issued

14 May 2018). A response was received on 18 June 2018 and discussions will continue throughout the

development process.

Desk-based Review

9.1.11. Desk study initially involved study of open source aerial photography and Ordnance Survey mapping,

together with review of (limited) species data, and figures indicating the years of felling and the species

composition of forest coupes (provided by NRW). Data collected to inform nearby wind farm applications

was also reviewed in order to inform the approach to the work, and the UK Government’s ‘Magic’

website was interrogated to obtain information on the locations of statutory designated sites in relation to

the proposed development.

9.1.12. Further desk based work involved approaching the following organisations for ecological data:

Cofnod (the North Wales Environmental Information Service)8.

NRW Energy Delivery Team and Forest Management officers with knowledge of the site.

Habitat Survey

9.1.13. A Phase 1 Habitat Survey of the site was completed in June 2018 in accordance with industry standard

(JNCC, 2010) survey guidance. This involved mapping all broad habitat types present within 250 m of

the indicative turbine array and 50 m of ancillary infrastructure, and surveying a further area that has the

potential to be restored to a mosaic of heath and bog habitats. As the design of the scheme progresses,

any further areas not covered during this initial work (resulting from changes in layout) will be identified

and surveyed.

7 CIEEM. (2016). Guidelines for ecological impact assessment in the UK and Ireland: terrestrial, freshwater

and coastal. Second edition. Chartered Institute of Ecology and Environmental Management, Winchester

8 The search area extended to 2 km beyond the perimeter of the site for all species except bats, for which it

extended to 10 km.


9.1.14. During the Phase 1 survey plant communities were assigned to National Vegetation Classification (NVC)

categories in the field (based on the experience of the surveyors) and checked against community types

identified by Rodwell (1998)9 on return to the office.

Protected Species Survey

9.1.15. The following survey work is proposed to inform the application:

Bat activity surveys. Ten static detectors have been deployed at the site in 2018, and data is being

and will be collected on a seasonal basis (for ten consecutive nights in each of spring, summer and

autumn). Habitats within the site include mature and thicket stage plantation forest, small areas of

beech and riparian woodland, and more open areas resulting from clearfell, tracks, firebreaks and

stream corridors. Detector locations have been selected to sample these representatively and to

build a picture of how bats use the site (access to most of the turbine locations is not possible due to

dense plantation cover). The positions of the detectors will be reviewed, with regard to collecting

relevant data for the emerging layout ahead of further work in 2019. A weather station has been

installed to collect site-specific data for the duration of the work. It is intended to collect ‘at height

data’ from a microphone attached to a meteorological mast on the site (it is anticipated the mast will

be erected in July 2018). This approach has been agreed with NRW.

Bat roost surveys. All buildings (including ruins) within Alwen Forest have been subject to

assessment for potential roost features in 2018. Emergence surveys of these buildings, led by a

licenced bat ecologist, will be completed in 2019 to gain an indication of the size and likely type of

any roosts present. The Phase 1 survey identified very little potential for tree roosting bats within

250 m of turbine locations10

; currently no roost surveys of trees is considered necessary, but this will

be kept under review as the development design progresses.

Dormouse (Muscardinus avellanarius) survey. This will be completed in areas of the plantation

likely to be impacted by the wind farm. Nest boxes (as opposed to mammal tubes) will be used, as

work at Clocaenog Forest has demonstrated that they are more capable of withstanding the local

climate (Matthew Ellis, pers comm). The density and overall number of nest boxes is currently under

discussion with Natural Resources Wales. Survey will be completed in September 2018, and during

the spring and summer of 2019.

Otter (Lutra lutra) survey. This will be completed once the design of the wind farm is close to being

fixed; there is a low risk of holts being located close to the wind farm and influencing site design.

Survey methods will be based on those recommended in Chanin (2003). Watercourses, including

channels and banks will be systematically surveyed for signs of otter such as droppings (‘spraints’),

runs and footprints. Particular attention will be given to suitable sprainting areas such as large, flat

rocks or areas where otters are likely to leave watercourses. Holts and resting places including

structures such as cavities in roots of bank-side trees, piles of logs or flood debris, drains and caves

will also be searched for as part of the work.

Badger (Meles meles) survey. The Phase 1 recorded no evidence of badger on site, indicating there

is a very low risk of badger setts influencing site design. A detailed badger survey will be conducted

at the pre-construction stage. This will involve systematically searching a limited area around the

proposed wind farm infrastructure and working areas to ensure legislative compliance.

9 Rodwell, J.S. (1998). British plant communities. Cambridge University Press, Cambridge.

10 A more detailed assessment will be needed of roost potential of an area of beech woodland approximately

125 m to the west of Turbine 6.


Question 6: Do consultees consider the baseline methodology appropriate?

Results

Consultation

9.1.16. As a result of consultation with NRW, the scope of ecological works for the proposed development has

changed to incorporate dormouse surveys. This reflects the fact that the species has been recorded

widely in nearby Clocaenog Forest (including in solely coniferous forest coupes), although its status in

Alwen Forest is unclear.

9.1.17. During the meeting with NRW it was agreed that the following were not considered necessary ahead of

a planning application and therefore have been scoped out of the assessment:

Walked transects for bats. These were considered unlikely to add useful data to that gained through

the use of static detectors.

Novel survey of red squirrel and pine marten. The distribution and abundance of both species are

well known as a result of feeding stations and camera trapping in the plantation. Approximately

twenty red squirrels and one pine marten (originating from the Welsh reintroduction scheme) are

considered to use the site.

Water vole (Arvicola terrestris) survey. An element of water vole survey (presence/absence) can be

incorporated with the otter survey. However, impacts on water vole are likely to be effectively

mitigated, as there is a stand off from watercourses incorporated within site design.

Macro invertebrates and fish. Development design is being led by the need to avoid impacts on

potable water supplies associated with the reservoirs into which on site watercourses discharge. As

these stand-offs around watercourses will effectively mitigate impacts on macro invertebrates and

fish, surveys for these groups are unnecessary.

Reptile or amphibian (herpetofauna) surveys. It is known that common species of herpetile are

present, but construction phase impacts on these species can be avoided via a working method

statement (a condition of consent).

9.1.18. Comments from CCBC have not resulted in changes to the scope of ecological survey work to date.

Much of the approach has been agreed in principle, but there is an ongoing consultation with CCBC to

clarify the detailed approach to some elements of it.

9.1.19. Baseline ecological reports will be issued to NRW and CCBC for comment to ensure ongoing

engagement.

Question 7: Do consultees consider the items scoped out appropriate?

Desk-based Review: Designated Sites

9.1.20. There are two Sites of Special Scientific Interest (SSSIs) within 2 km of the site boundary; Mynydd

Hiraethog, and Corsydd Nug a Merddwr (see Figure 9.1).

9.1.21. Mynydd Hiraethog SSSI abuts the site to the north and west. It was notified for its botanical and

ornithological interest. It represents one of the four remaining extensive tracts of sub-montane heather

(Calluna vulgaris) heath in the former county of Clwyd, and has been traditionally managed as a grouse

moor. The drier heath vegetation grades into wetter acidic blanket bog vegetation where the peat is

deeper. The SSSI also supports extensive areas of soligenous mires, and natural oligotrophic lakes, of

which Llyn Alwen is the largest and most notable.

9.1.22. Corsydd Nug a Merddwr SSSI is approximately 1.8 km south of the site, and was notified for its lowland

blanket mire, associated wetland/moorland habitats, and for individual notable plant species.


9.1.23. Migneint-Arenig-Dduallt Special Area of Conservation (SAC) and Special Protection Area (SPA) is

located in excess of 8 km to the south of the site. The SAC was designated for its wet and dry heath,

blanket bog, standing waters and sessile oak (Quercus petraea) woodland. Consideration is given to the

SPA in Section 10 of this document. The site is also an SSSI; additional features (to those listed on the

SAC and SPA Data Forms) are individual invertebrate species and the invertebrate assemblage.

9.1.24. There are twenty non-statutory sites of nature conservation interest within 2 km of the site (two of which

are within the site but outside the proposed development footprint). These sites are designated for their

habitats, which include acid and marshy grassland, broad-leaved woodland habitats, and areas of

freshwater.

Desk-based Review: Species Data

9.1.25. Cofnod data included the following:

Bats. Six records of noctule (Nyctalus noctula), none of which referred to roosts, within 10 km of the

site boundary. On-site roosts of brown long-eared bat (Plecotus auritus) and common pipistrelle

(Pipistrellus pipistrellus), with further roosts of these brown long-eared bat, common pipistrelle,

lesser horseshoe bat (Rhinolophus hipposideros), Natterer’s bat (Myotis nattereri) and soprano

pipistrelle (Pipistrellus pygmaeus) within 10 km of the site boundary.

Otter. Two records from the site.

Red squirrel. Fourteen records for the site between 2003 and 2015. A further five additional records

within 2 km of the site over the same period.

Water vole. Two records from the southern end of Alwen Reservoir in the late 2000s.

Reptiles. Numerous records of adder (Vipera berus) and common lizard (Zootoca vivipara).

Small pearl-bordered fritillary butterfly (Boloria selene). Fourteen records from the site, with further

records for the surrounding area.

9.1.26. Collated summary data from the Brenig, Pant y Maen and Clocaenog wind farms is as follows:

Bats. Noctule, common and soprano pipistrelles and Myotis species were noted at all three sites,

with brown long-eared bat noted at Pant y Maen and Clocaenog. Lesser horseshoe bat was

recorded at Pant y Maen only, where it occurred outside the breeding period (suggesting no local

maternity roost).

Otter was only conclusively recorded at Pant y Maen, with signs noted around a waterbody within

the survey area.

Red squirrel. Was noted in very low numbers within the site boundary at Clocaenog (and was

concluded as likely to be more common elsewhere in the forest). The species was not recorded at

Brenig, and grey squirrels were present (recorded using camera traps) at Pant y Maen.

Dormouse. Present in various parts of the Clocaenog site, with breeding noted in nest boxes.

Apparently absent from Pant y Maen, and no records from Brenig.

Water vole. Recorded at Pant y Maen and Clocaenog, but very localised within these sites.

Habitat Survey

9.1.27. The Phase 1 habitat survey, completed in early June 2018, found the survey area was dominated by

coniferous plantation, typically formed of dense, even-aged plantings of Sitka spruce (Picea sitchensis).

The plantation is managed in rotation, and all growth stages are represented, from recently felled or

replanted areas to stands of intermediate age and mature trees. Stands of intermediate age

predominate.

9.1.28. Ground flora is present in the younger stands (and, where tree density is low, also in some of the

intermediate-age stands). The nature of this ground flora reflects the soil conditions, with modified bog


(with some bog moss (Sphagnum species) and cotton grasses (Eriophorum species)) present in deeper

peat, and various mixtures of acid grassland/heath/scrub (typically with abundant heather (Calluna

vulgaris) or wavy hair-grass (Deschampsia flexuosa vulgaris)) present in better-drained areas or on

mineral soils. Ground flora is typically completely absent in the stands of intermediate-age trees, due to

the dense canopy and the deep layer of shed needles, but in the more mature stands, where thinning

may have taken place, there is typically some ground flora (e.g. bilberry (Vaccinium myrtillus), broad

buckler fern (Dryopteris dilatata) and various mosses). A small area of mature beech (Fagus sylvatica)

plantation is present towards the centre of the site, with little ground flora or shrub layer.

9.1.29. In the northern part of the site, within an area known as Bryn y Gors Goch there is blanket bog with

various bog mosses (including Sphagnum subnitens and S. magellanicum) and abundant heather,

hare’s-tail cotton-grass (Eriophorum vaginatum), bilberry, and red-stemmed feather-moss (Pleurozium

schreberi). Other habitats are limited to the narrow trackside verges (which support semi-improved acid

grassland, semi-improved neutral grassland, heath, scrub or tall ruderal vegetation), wet ditches, several

small quarries and derelict buildings, and very small areas within the forestry estate supporting marshy

grassland, flush, scrub, and semi-natural woodland dominated by downy birch (Betula pubescens).

9.1.30. Three non-native invasive plant species were noted on the site, Montbretia (Crocosmia x crocosmiiflora),

common rhododendron (Rhododendron ponticum) and piri-piri burr (Acaena novae-zelandiae). The

former two species are listed under Schedule 9 of the Wildlife and Countryside Act, 1981 (as amended).

Protected Species Survey

9.1.31. No signs of protected species were noted during the Phase 1 survey.

9.1.32. Spring bat survey data illustrate that the airspace above the site is used by pipistrelle species, noctule

and Myotis bats, albeit these data have yet to be fully analysed.

9.1.33. Dormouse survey is due to commence in September 2018. Otter and badger survey will be completed

when a design freeze is close to being achieved and prior to construction respectively.

Discussion

9.1.34. The ecological impact assessment (EcIA) will assess the likely effects of construction, operation and

decommissioning of a wind farm at Alwen Forest on ecological receptors.

9.1.35. It is unlikely that there will be significant impacts on the ecological interest of designated sites (alone or

cumulatively) as a result of the wind farm proposal. This conclusion is based on the lack of a clear effect

pathway with regard to the habitats/species for which sites have been designated.

9.1.36. The key considerations within the ecological assessment are likely to be disturbance impacts on red

squirrel and hazel dormouse (if present) during construction, and potential impacts on bats during the

operational phases of the wind farm. The likely scale of impact on these species will be informed by site

survey and existing data (for red squirrel); emerging results of post construction monitoring at wind farms

across Wales will help assess the likelihood/scale of bat mortality. Impacts on habitats, otter and pine

marten will also need to be considered, and measures included to ensure legislative compliance with

regard to reptiles and badger. Impacts on water vole, fish and invertebrates will be scoped out of the

assessment.


Table 9.1: Summary of EcIA considerations

Receptor Detailed Assessment Required?

Protected Sites No

Red squirrel Yes

Hazel dormouse Yes

Bats Yes

Otter No

Pine marten No

Reptiles Compliance only

Badger Compliance only

Water vole No

Fish No

Invertebrates No

Source: BSG Ecology

Question 8: Do consultees consider what is proposed in Table 9.1 acceptable?

Grid Overview

9.1.37. A high level overview of the proposed grid connection route will be undertaken as part of the

assessment. This will include a desk study review, and analysis of habitat and protected species survey

data in relation to the Alwen Forest and Clocaenog schemes. If there are information gaps or potential

issues with regard to the age of data, an extended Phase 1 survey will be completed in order to classify

habitats / identify whether changes have occurred. The results of the combined desk study and Phase 1

survey will be used to inform whether further information is necessary to inform the planning application

for the scheme.

Conclusions

9.1.38. Ecological work to inform the planning application for a wind farm at Alwen Forest remains at an early

stage.

9.1.39. Regular communication with Natural Resources Wales will be required with regard to emerging results,

and in order to use the findings of survey in 2018 to inform and fine-tune the approach to work in 2019.

9.1.40. While some localised ecological impacts are likely to occur as a result of the proposed development, it is

anticipated that land management facilitated by the proposed development will deliver conservation gain

in terms of restoration of important habitats and protected species.

Question 9: Do consultees consider the preliminary conclusions are appropriate?


10. Ornithology

Introduction

10.1.1. This section sets out the proposed approach to assessing potential ornithological effects of the Alwen

Forest Wind Farm.

Use of Existing Information to Inform the Interpretation of Impacts

10.1.2. Existing ornithological data for Alwen Forest is relatively limited. However, the ornithological interest of

the wider area is well known. In part this is due to long term monitoring of breeding moorland raptors and

grouse by local ornithologists and conservation organisations, and in part by the detailed survey to

inform the nearby consented Pant y Maen Wind Farm, and the in-construction Clocaenog and Brenig

schemes, which have required raptor (breeding and general flight line) and nightjar surveys.

Embedded Mitigation and Layout Iterations

10.1.3. The indicative positions of the turbines and other infrastructure are well within the commercial plantation,

away from peripheral areas of high quality moorland habitats known to support breeding raptors and

waders and managed for black grouse (Tetrao tetrix).

10.1.4. Ornithological work to inform the detailed design of the scheme is at an early stage. The presence of

ornithological receptors within the site that may influence the design of the scheme, the timing of works,

or require other specific mitigation are currently being established.


10.1.5. The approach to ornithological survey has been based on Scottish Natural Heritage (2014) guidance for

bird survey at onshore wind farms11

, which represents industry standard guidance for the UK.

10.1.6. Particular consideration has been given to those species listed under Annex 1 of the Birds Directive

(2009/47/EC), Schedule 1 of the Wildlife and Countryside Act 1981 (as amended) and Section 7 of the

Environment Wales Act (2016) in deriving the detailed approach to the work.

10.1.7. The approach to the ornithological impact assessment will be based on Chartered Institute for Ecology

and Environmental Management (CIEEM) guidance12

, and informed by Collision Risk Modelling using

the Band Model derived by Scottish Natural Heritage.

Methodology

Consultation

10.1.8. A meeting was held with Natural Resources Wales (NRW) in February 2018. This was attended by

members of the North Planning and Energy Delivery teams, and by Patrick Lindley, a specialist

ornithological advisor.

10.1.9. The aim of the meeting was to discuss and agree an approach to the bird survey work, obtain further

information to inform the scope of the desk study, and to establish clear lines of communication for

further consultation at key stages in the baseline data collection programme. The minutes of the meeting

were subsequently agreed with NRW (see Appendix B for minutes).

11 Scottish Natural Heritage. (2014). Recommended bird survey methods to inform impact assessment of

onshore wind farms. SNH, Inverness.

12 CIEEM. (2016). Guidelines for ecological impact assessment in the UK and Ireland: terrestrial, freshwater

and coastal. Second edition. Chartered Institute of Ecology and Environmental Management, Winchester


10.1.10. The local authority ecologist for Conwy County Borough Council (CCBC), Barbara Owsianka, was

informed of the proposed approach to ornithological and wider ecological work via an initial letter (issued

14 May 2018). A response was received on 18 June 2018 and discussions will continue throughout the

development process.

Desk-based Review

10.1.11. Desk study initially involved review of open source aerial photography and Ordnance Survey mapping,

together with review of (limited) species data, and figures indicating the years of felling and the species

composition of forest coupes (provided by NRW). Data collected to inform nearby wind farm applications

was also reviewed in order to inform the approach to the work, and the UK Government’s ‘Magic’

website was interrogated to obtain information on the locations of statutory designated sites in relation to


10.1.12. Further desk based work involved approaching the following organisations for ornithological data13

:

Cofnod (the North Wales Environmental Information Service)

RSPB Cymru

BTO Cymru (the Welsh branch of the British Trust for Ornithology)

NRW Energy Delivery Team and Forest Management officers with knowledge of the site

Local raptor surveyors

10.1.13. Additional information may be held in relation to water bird numbers on Alwen Reservoir by the Joint

Nature Conservation Committee (JNCC) (through the Seabird Monitoring Programme) and by BTO

(Thetford) as part of their Wetland Bird Survey database, and will be secured. However, there is no

indication at this stage that the reservoir supports important numbers of waterfowl (the BTO indicates

both Alwen Reservoir and Llyn Brenig are of low priority for survey).

Field Surveys

10.1.14. Two years of ornithological data will be collected to inform the ornithological impact assessment for the

proposed development (albeit some elements of breeding season work may be modified or omitted in

2019 based on the results for 2018). The proposed scope of work involves:

Vantage point (VP) surveys based on SNH (2014) guidance. Two locations were selected for use in

September 2017. Viewsheds were ground-truthed in the field during an accompanied visit with

Natural Resources Wales Energy Delivery Team and Forest Management staff. In combination, the

VP locations afford excellent views over the site and surrounding areas of land. It is proposed to

complete 36 hours of survey work per VP during the 2018 and 2019 breeding seasons; a minimum

of 36 hours of winter survey work per VP has already been achieved during winter 2017/18 and is

planned for winter 2018/19. VP locations and viewsheds are shown on Figure 10.1.

Black grouse survey. All areas of potential lekking habitat within 1.5 km of the site boundary have

been surveyed for black grouse in accordance with the method identified by Gilbert et al (1998).

Known lek sites, areas of open moorland and upland farmland adjacent to woodland or forestry,

woodland edges, tracks and clearings in plantations have been included in the survey area. The

work will be repeated in 2019.

Nightjar (Caprimulgus europaeus) survey. All areas of potential nightjar breeding habitat within the

site and additional suitable habitat within 500 metres of proposed turbine locations have been

identified from aerial photography and felling plans, and ground-truthed during site visits. Surveys to

locate ‘churring’ males (which indicate territories) are following the industry standard method

13 The search area extended to 2 km beyond the perimeter of the site for Cofnod data. RSPB Cymru provided

data on black grouse for a perimeter area of 5 km from the site.


described by Gilbert et al (1998). Two visits are being completed to record nightjars between late

May and mid-July in both 2018 and 2019.

Breeding raptor survey. Surveys for moorland and forest-nesting raptors following methods outlined

in Hardey et al (2013) will be completed in both 2018 and 2019. Additional VP survey was

completed in spring 2018 in order to detect displaying birds. A series of walkover surveys

(incorporating watches from additional ad hoc VPs) will be undertaken under licence during summer

2018 to confirm territory locations and to gain a clear indication of breeding success for raptors

encountered.

Breeding wader survey. Four walkover surveys of areas of suitable wader habitat (predominantly

open moorland) will be completed between April and July 2018 in accordance with the Brown &

Shepherd (1993) method; these surveys will cover an area extending to 800 m from indicative

turbine locations. All potentially suitable breeding habitat for waders is outside the site boundary.

Semi-improved fields around the fringes of the plantation will also be visited and scanned for waders

for completeness. The results of survey in 2018 will be used to inform the necessity for further

survey in 2019.

Waterfowl surveys. There is no indication that Alwen Reservoir (or Llyn Brenig to the east of the site)

is of importance for breeding or wintering waterfowl. As such, dedicated waterfowl surveys are not

being completed. However, a significant part of Alwen Reservoir is overlooked by one of the VPs. It

follows that any waterfowl present are recorded during each three hour VP watch.

Question 10: Do consultees consider the baseline methodology appropriate?

Results

Consultation

10.1.15. Subject to some points of clarification with regard to the detail of the approach to VP survey (principally

the production of a viewshed map), and concerning the black grouse, raptor and wader survey work,

NRW’s North Planning team (including their ornithologist Patrick Lindley) have confirmed in writing that

they are satisfied with the scope of ornithological work (following the meeting in February 2018).

10.1.16. During the meeting it was agreed that the following were not considered necessary ahead of a planning

application:

Radio tracking of nightjar to confirm territory / nesting locations. A standard two-visit survey was

considered proportionate.

Surveys for long-eared owl (Asio otus) and barn owl (Tyto alba). These species are not likely to be

significantly impacted by wind farms.

Surveys of Alwen and Brenig Reservoirs for breeding or wintering waterfowl (due to a shared

understanding that these waterbodies are unlikely to support large number or important populations

or waterfowl).

10.1.17. CCBC did not raise any concerns with regard to the scope of ornithological work (other than requesting

clarification that nightjar survey in 2018 would be repeated in 2019 to identify any changes in

distribution).

10.1.18. Baseline ornithological reports will be issued to Natural Resources Wales and CCBC for comment to

ensure ongoing engagement.

Desk-based Review: Protected Sites

10.1.19. There are two Sites of Special Scientific Interest (SSSIs) within 2 km of the site boundary; Mynydd

Hiraethog, and Corsydd Nug a Merddwr (see Figure 9.1 in the Ecology Section).


10.1.20. Mynydd Hiraethog abuts the site to the north and west. It was notified for its botanical and ornithological

interest. The SSSI citation states that it supports a diverse community of upland breeding bird species,

including hen harrier (Circus cyaneus), merlin (Falco columbarius), golden plover (Pluvialis apricaria),

dunlin (Calidris alpina), lapwing (Vanellus vanellus), curlew (Numenius arquata) and short-eared owl

(Asio flammea).

10.1.21. Corsydd Nug a Merddwr SSSI was notified for its blanket mire, and is not considered further here.

10.1.22. Migneint-Arenig-Dduallt Special Protection Area (SPA) and Special Area of Conservation (SAC) is

located in excess of 8 km to the south of the site. The SPA was classified for its breeding populations of

hen harrier, peregrine (Falco peregrinus) and merlin. Consideration is given to the SAC in Section 9 of

this document.

10.1.23. There are twenty non-statutory sites of nature conservation interest within 2 km of the site (two of which

are within the site but outside the proposed development footprint). None are designated for their

ornithological interest; therefore these sites are not given further consideration in this section.

Desk Based Review: Species Data

10.1.24. The desk based review has identified the following species information:

A number of current or former black grouse lek sites within 5 km of the site boundary.

Previous records of nightjar territories within the plantation.

Regular breeding by three species of highly protected raptor within 1.5 km of the site boundary.

That the wader species curlew and snipe (Gallinago gallinago) are likely to have recently bred on

areas of moorland close to the site.

10.1.25. Nightjar and black grouse have been the main ornithological considerations for the Clocaenog, Brenig

and Pant y Maen wind farms, albeit all have also considered potential impacts on protected raptors and

other species of conservation concern.

10.1.26. With particular reference to the site, it has been noted that osprey has begun to occur on the reservoirs

with increasing regularity (reflecting the recent range expansion of the species into North Wales), and

that crossbill, a specially protected passerine, is likely to use the plantation throughout the year.

Winter Survey Work

10.1.27. A total of 75.5 hours of survey was completed from the two VP locations between October 2017 and

March 2018 inclusive.

10.1.28. Target species noted were red kite (Milvus milvus), hen harrier, goshawk (Accipiter gentilis), kestrel

(Falco tinnunculus), peregrine (Falco peregrinus), merlin and golden plover (a flock of three birds). Other

than goshawk and kestrel, these species were recorded on a maximum of two occasions. Target

species activity was mainly noted over moorland habitats adjacent to the site; however, all goshawk

flights (five were recorded) were within the plantation.

10.1.29. Non-focal species included buzzard (Buteo buteo) and raven (Corvus corax), which were regularly

recorded. Common crossbill (Loxia curvirostra) and herring gull (Larus argentatus) were also recorded

frequently throughout the period. Waterfowl were noted more occasionally, and included mallard (Anas

platyrhynchos), great cormorant (Phalacrocorax carbo) and grey heron (Ardea cinerea).

Question 11: Based on these results we consider a second winter of survey to be unnecessary. Do consultees agree with this conclusion?

Breeding Season Survey Work

10.1.30. Breeding season survey work is ongoing. Emerging results are as follows:


Flight activity from VPs is higher than during the winter period, and additional species (including

osprey) have been noted. A combination of VP and walkover survey has resulted in the conclusion

that four species of highly protected raptor are currently holding territory within the raptor survey

area (one species within and three species outside the site boundary). Survey to determine flight

behaviour and breeding success continues.

Black grouse leks occur on the moorland to the north and west of the site.

Nightjar is present in suitable habitat within the site. It is likely that several territories are present, but

work is ongoing.

Curlew are holding territory within the wader survey area; no other wader species are present.

Discussion

10.1.31. The ornithological impact assessment (OIA) will assess the likely effects of construction, operation and

decommissioning of a wind farm at Alwen Forest on ornithological receptors. The OIA will be informed

by Collision Risk Modelling to determine indicative likelihood of collision of target species.

10.1.32. It is unlikely that there will be significant impacts on the ornithological interest of designated sites (alone

or cumulatively) as a result of the wind farm proposal. Survey to date does not indicate regular use of

the plantation or the airspace above it by species forming interest features of the Mynydd Hiraethog

SSSI. The site is also beyond the core ranging distance of raptors breeding in the Migneint-Arenig-

Dduallt SPA; it follows that impacts on SPA bird populations will not be subject to detailed assessment in

the OIA.

10.1.33. Other key considerations within the ornithological assessment are likely to be disturbance and collision

of forest-nesting raptors, black grouse and nightjar during the construction and operation of the wind

farm. Detailed assessment of the impacts of development on moorland-nesting raptors, all owl species

and passerines will not be completed within the OIA. Measures will be required to ensure there is

legislative compliance with regard to breeding birds (including crossbill) during construction.

Table 10.1: Summary of OIA considerations

Receptor Detailed Assessment Required?

Protected Sites No

Black grouse Yes

Nightjar Yes

Forest/tree-nesting raptors Yes

Moorland-nesting raptors No

Waders No

Breeding passerines Compliance only

Source: BSG Ecology

Question 12: Do consultees consider what is proposed in Table 10.1 acceptable?

Grid Overview

10.1.34. A high level overview of the proposed grid connection route will be undertaken as part of the

assessment. This will include a desk study review, and analysis of habitat and protected species survey

data in relation to the Alwen Forest and Clocaenog schemes. If there are information gaps or potential

issues with regard to the age of data, an extended Phase 1 survey will be completed in order to classify


habitats/identify whether changes have occurred. The results of the combined desk study and Phase 1

survey will be used to inform whether further information is necessary to inform the planning application

for the scheme.

Conclusions

10.1.35. Ornithological work to inform the planning application for a wind farm at Alwen Forest remains at an

early stage.

10.1.36. Regular communication with Natural Resources Wales will be required with regard to emerging results,

and in order to use the findings of survey in 2018 to inform and fine-tune the approach to work in 2019.

10.1.37. While some localised ornithological impacts are likely to occur as a result of the proposed development,

it is anticipated that habitat management within the site will deliver conservation gain for key bird

species, particularly black grouse and nightjar. The approach to habitat creation will be based on the

precedents established by other local wind farms, particularly Clocaenog, and can be further informed by

monitoring at these sites.

Question 13: Do consultees consider the preliminary conclusions are appropriate?

11. Landscape and Visual

Introduction

11.1.1. This section sets out the proposed approach to assessing the potential effects of the Alwen Forest Wind

Farm on landscape character and visual amenity. The primary guidance for Landscape and Visual

Impact Assessment (LVIA) is the Guidelines for Landscape and Visual Impact Assessment, 3rd Edition

(GLVIA3)14

. In addition, Scottish Natural Heritage (SNH) has published a number of documents that

have been adopted as industry standard good practice on landscape and visual assessments of wind

farm proposals. The LVIA will be completed by Chartered Landscape Architects, and in accordance with

relevant best practice documents.

11.1.2. In accordance with GLVIA3, landscape and visual effects will be considered separately. The landscape

assessment will consider the effects of the proposed wind farm development on the existing landscape

character, pattern of land, and the rural and urban elements within the Study Area. The visual

assessment will consider the visual impact of the development over the Study Area, including the

magnitude of visual effect from nearby settlements, roads and public places of interest. The LVIA will

focus on receptors that may experience potentially significant effects. The LVIA will take into account

the proposed level of micrositing which is expected to be 50 m.

11.1.3. It is considered likely that a residential visual amenity study will be required to examine effects on the

visual component of residential amenity at a number of nearby properties within 2 km of the nearest

proposed turbine.

11.1.4. An indicative Zone of Theoretical Visibility (ZTV) map has been generated for the Scoping Layout and is

shown on Figure 11.1, with a more detailed ZTV provided in Figure 11.2.

11.1.5. It is proposed that the Study Area for the LVIA will cover a radius of 35 km from the outermost turbines.

SNH guidance on the Visual Representation of Wind Farms15

states that an initial distance of 45 km

should be considered based on the size of the turbines proposed (up to 200 m to tip), however as shown

14 Landscape Institute and the Institute of Environmental Assessment (2013) Guidelines for Landscape and

Visual Impact Assessment. 3rd Edition

15 Scottish Natural Heritage (February 2017) Visual Representation of Wind Farms Guidance. Version 2.2


by the ZTV on Figure 11.1, there is limited theoretical visibility beyond 35 km, except from parts of the

Irish Sea in the far north of the Study Area.

Question 14: Do consultees consider the size of the 35 km radius Study Area to be appropriate?

Consultation

11.1.6. Conwy County Borough Council (CCBC), Denbighshire County Council (DCC) and Natural Resources

Wales (NRW) will be consulted on the approach to the assessment of effects on landscape character

and visual amenity, in particular the selection of viewpoints for the visual assessment.

Question 15: Are there any other relevant consultees who should be consulted about the LVIA?

Planning Policy

11.1.7. The following national and regional policy documents and supplementary guidance will be considered in

the assessment.

National Planning Policy

11.1.8. Planning Policy Wales (2016) sets out the land use planning polices for the Welsh Government. It is

supplemented by a series of Technical Advice Notes (TANs). National policy and guidance on onshore

renewable energy technologies is set out in TAN 8 Planning for Renewable Energy (2005).

11.1.9. The site is located within TAN 8 Strategic Search Area A (SSA A). TAN 8 Annex D Study of Strategic

Search Area A – Clocaenog16

seeks to identify a ‘preferred area or areas’ for siting wind farms within

SSA A, in the context of landscape and visual sensitivities. The site falls within Zone 4 (Alwen

Reservoir) which is considered to be of Medium-low sensitivity in terms of landscape character.

Local Development Plan

11.1.10. The site is mainly located within the CCBC local authority area, however section of the site lies within the

DCC local authority area. The Conwy Local Development Plan (LDP) 2007-2022 (Adopted October

2013) and Denbighshire LDP 2006-2021 (Adopted May 2013) are therefore the most relevant land use

planning documents for the area. The Conwy LDP is supported by Supplementary Planning Guidance

(SPG) LDP11: Landscape Sensitivity and Capacity for Onshore Wind Turbine Development (November

2014) and SPG LDP24: Renewable Energy (February 2017). The Denbighshire LDP is also supported

by an SPG on Renewable Energy (April 2016).

Question 16: Are consultees aware of any other supplementary guidance of relevance to landscape and visual issues?

The Site

11.1.11. The site is located on either side of Alwen Reservoir, a large man-made water body flanked by rolling,

forested hills, rising to moorland beyond its boundary. On the southern side of the reservoir there is a

small ridge running north-west to south east; the ridge is approximately 470 m Above Ordnance Datum

(AOD) at its highest point and blanketed with coniferous forestry. On the northern side of the reservoir

the land is undulating, reaching a high point of approximately 450 m in the east of the site. There are

several shared use trails for walkers, cyclists and horses around the reservoir, including the Two Lakes

Trail, Alwen Trail and Brenig Trail. The B4501 runs along the eastern boundary of the site, and forms

part of the Clwydian Way Regional Trail. The site borders the Hiraethog Special Landscape Area (SLA)

16 Ove Arup & Partners (December 2005) TAN 8 Annex D Study of Strategic Search Area A – Clocaenog Final

Issue Report


in the west and north. The northern part of the site at Cerrig Caws is within the Denbigh Moors / Mynydd

Hiraethog Landscape of Special Historic Interest (discussed further in Section 13 Cultural Heritage).

Assessment Methodology

Design Considerations

11.1.12. The design of the proposed wind farm development will aim to achieve a coherent and structured form,

in line with guidance provided by the Welsh Government17

and SNH18

. The ES will present the rationale

behind the final design strategy. The objective in designing the wind farm will be to develop a layout that

accords with its setting in terms of landform and pattern, and which presents a simple visual image,

avoiding the clustering of turbines and the isolation of outlying turbines in views from key locations,

whilst recognising that the final layout will need to balance a wide range of technical and environmental

considerations.

11.1.13. All elements of the proposed wind farm infrastructure will be considered in terms of locational and design

choice, and the LVIA will set out how the design of ancillary elements has evolved to minimise visual

impact, especially from nearby and sensitive visual receptors.

Landscape Character

11.1.14. Landscape receptors to be considered will include:

Landscape elements and features within the site;

Landscape character types and/or areas, as identified in published character assessments;

LANDMAP aspect areas; and

The implications of effects on landscape character for the special qualities of landscape-related

planning designations at the national, regional and local level.

11.1.15. Predicted changes in both the physical landscape and landscape character will be identified. Effects will

be considered in terms of the magnitude of change to the landscape, including its key characteristics as

set out in published landscape character assessments and LANDMAP data. The sensitivity of the

landscape will also be taken into account, acknowledging its underlying susceptibility, and the value

placed on the landscape by society, which may be indicated through designation or LANDMAP

evaluation.

11.1.16. NRW’s National Landscape Character Areas (NLCAs) form the broadest scale of landscape character

assessment in Wales. The site is within the Denbigh Moors/Mynydd Hiraethog NLCA.

11.1.17. The 35 km radius Study Area includes parts of the unitary authorities of Conwy, Denbighshire,

Gwynedd, Powys, Wrexham and Flintshire. At a regional scale, there are no current published

landscape character assessments for Conwy, Denbighshire, Powys or Wrexham. The landscape of

Snowdonia National Park is described in the Eryri Landscape Character Assessment, which forms part

of the Snowdonia National Park Authority’s SPG: Landscapes and Seascapes of Eryri (July 2014). The

Gwynedd Landscape Strategy (1999) describes Landscape Character Areas within Gwynedd (outside of

the National Park), and is based on the LANDMAP methodology. A Landscape Strategy for Flintshire

(April 1996) describes Landscape Character Areas within the authority.

11.1.18. Significant effects on landscape character are more likely to occur in areas which have a strong

landscape or visual relationship with the landscape of the site. Each character type/area within 35 km

will be considered in terms of its relationship to the site and the extent of theoretical visibility indicated by

the ZTV, to determine whether assessment of effects is required.

17 Design Commission for Wales (2014) Designing Wind Farms in Wales

18 Scottish Natural Heritage (August 2017) Siting and Designing Windfarms in the Landscape. Version 3a


LANDMAP

11.1.19. In accordance with LANDMAP Guidance Note 319

, all five aspect areas (Geological Landscape,

Landscape Habitats, Visual and Sensory, Historic Landscape and Cultural Landscape) will be

considered in the LVIA, with reference to published LANDMAP data. LANDMAP aspect areas within the

site are provided in Table 11.1.

Table 11.1: LANDMAP Aspect Areas within the Site

Aspect Area Aspect ID Area Name Overall Evaluation

Geological Landscape CNWGL097

DNBGHGL088

Mwdwl-eithin

Mynydd Hiraethog

Moderate

Moderate

Landscape Habitats CNWLH074

DNBGHLH059

Alwen forest

Hiraethog Conifer Forest

Moderate

Low

Visual and Sensory CNWVS007

DNBGHVS069

CNWVS005

Clocaenog Forest West

Llyn Brenig Moorland/Forest

Alwen Reservoir

Low

Moderate

High

Historic Landscape CNWHL042

CNWHL041

CNWHL078

DNBGHHL170

Alwen Plantation

Bryn Gors-goch

Alwen & Brenig

Unnamed

Moderate

Moderate

High

High

Cultural Landscape CNWCL018

DNBGHCL016

Conwy uplands

Denbigh Moors

High

High

Source: LANDMAP

11.1.20. In accordance with LANDMAP Guidance Note 3, for Geological Landscape and Landscape Habitats the

assessment will consider aspect areas within and adjacent to the site. For Visual and Sensory, Historic

Landscape and Cultural Landscape, the assessment will consider aspect areas within 15 km of the site

and which are intervisible with the proposed wind farm development. In accordance with LANDMAP

Guidance Note 3, the assessment will focus on aspect areas of ‘outstanding’ or ‘high’ overall evaluation.

Visual and Sensory aspect areas of ‘moderate’ overall evaluation will also be considered where scenic

quality and/or character criteria are ‘outstanding’ or ‘high’. The LANDMAP assessment will be included

as an appendix to the LVIA.

Question 17: Is the proposed approach and scope for the assessment of effects on landscape character and LANDMAP aspect areas considered to be appropriate?

Designated Landscapes

11.1.21. Designated landscapes are shown on Figures 11.1 and 11.2. The site does not fall within any nationally

designated landscapes but does border the Hiraethog SLA in the west and north. It is proposed that

effects on the integrity of nationally and locally designated landscapes within the 35 km radius Study

Area will be considered in the assessment. These include:

Snowdonia National Park, approximately 6.5 km to the west of the site at its closest point;

19 Natural Resources Wales (2013) LANDMAP Guidance Note 3: Guidance for Wales, Using LANDMAP for

Landscape and Visual Impact Assessment of Onshore Wind Turbines


Clwydian Range and Dee Valley Area of Outstanding Natural Beauty (AONB), approximately 15 km

to the south-east of the site at its closest point; and

Special Landscape Areas to the north, west and south of the site.

11.1.22. For each of the above designations, careful consideration will be given to the identified effects of the

proposed wind farm development on landscape character and visual amenity within the designated area.

Any resulting effects on the published special qualities of the designation will be identified, and an

assessment will be made of the implications for the integrity of the designated area. The key

characteristics of landscape character areas within Snowdonia National Park are set out in the National

Park Authority’s SPG: Landscapes and Seascapes of Eryri (July 2014). The special qualities of the

Clwydian Range and Dee Valley AONB are set out in the Management Plan Strategy (2014-2019) and

Supplementary Planning Guidance Note Consultation Draft (October 2017).

Question 18: Is the proposed approach and scope for the assessment of effects on designated landscapes considered to be appropriate?

Visual Receptors

11.1.23. Visual receptors to be considered will include:

People within settlements;

People travelling on major roads;

People using walking routes and cycle routes; and

People visiting areas of interest such as visitor attractions, viewpoints and hill summits.

11.1.24. The assessment will consider effects on villages and hamlets within approximately 5 km of the site,

including Cerrigydrudion and Cefn-brith to the south and Pentre-llyn-cymmer to the south-east. The

assessment will also consider effects on larger settlements beyond 5 km, where the ZTV indicates

theoretical visibility.

11.1.25. The assessment will consider effects on A roads within the Study Area, where theoretical visibility is

indicated by the ZTV. This will include the A543 to the north and the A5 to the south. Minor roads within

5 km of the site will also be considered, including the B4501 to the east.

11.1.26. The assessment will consider effects on popular walking and cycling routes within the Study Area, where

theoretical visibility is indicated. The Clwydian Way Regional Trail crosses the northern and eastern

parts of the Study Area, passing through the north of the site. Offa’s Dyke National Trail passes through

the Clwydian Range in the east of the Study Area. Local routes within approximately 5 km of the site will

also be considered, including the Alwen Trail, Brenig Trail and Two Lakes Trail.

11.1.27. Visual effects are experienced by people at different locations around the Study Area, at static locations

(for example settlements or viewpoints) and transitional locations (such as sequential views from

routes). Visual receptors are the people who will be affected by changes in views at these places, and

they are usually grouped by what they are doing at those places (for example residents, motorists and

recreational users).

11.1.28. GLVIA3 states that the nature of visual receptors, commonly referred to as their sensitivity, should be

assessed in terms of the susceptibility of the receptor to change in views/visual amenity and the value

attached to particular views. The nature of the effect should be assessed in terms of the size and scale,

geographical extent, duration and reversibility of the effect. These aspects will all be considered to form

a judgement regarding the overall significance of effect.

11.1.29. Viewpoint locations have been selected to provide a representative range of viewing distances and

viewing experiences, including views from settlements, points of interest and sequential views along

routes. The viewpoints used in the Environmental Statements for nearby Clocaenog, Brenig and Pant y

Maen wind farms were reviewed to inform the selection. A list of proposed viewpoints for the


assessment is set out in Table 11.2, and these are shown on Figure 11.1. Assessment of the visual

effects of the proposed wind farm development will be based on analysis of the ZTVs, field studies and

examination of visualisations. Visualisations for each of the assessment viewpoints will be prepared in

line with SNH guidance20

. It is proposed that for the more distant viewpoints, where significant effects

are considered to be unlikely, wireframes only would be produced (i.e. Viewpoints 13 to 15). Where

forestry is proposed for removal as part of the proposed wind farm development, this would be modelled

on the photomontages for the closest viewpoints, where changes would be most visible (e.g. Viewpoints

1 to 3).

11.1.30. The visual assessment will consider the effects of aviation lighting, with night-time visualisations

prepared for 2 no. of the closer viewpoints to illustrate the effects of the proposed wind farm

development on night-time views.

Table 11.2: Preliminary LVIA Viewpoints – to be refined through fieldwork and discussion

No. Name Easting Northing

Approx.

Distance to

Nearest

Turbine Reason for Selection

1 Alwen Dam 295552 352888 0.02 km Represents views of recreational receptors

on the Alwen circular walk, near the dam car

park and picnic area.

2 Llyn Brenig

Visitor Centre

296700

354728 0.2 km Represents views of recreational receptors

at the Visitor Centre. Clocaenog LVIA VP05.

Brenig Tip Height Extension LVIA VPE.

3 A543 near

Sportsman’s

Arms

295208

358971 1.4 km Represents views of road users on the A543.

Clocaenog LVIA VP07. Pant y Maen LVIA

VP16.

4 Alwen Circular

Walk

291498 354617 1.5 km Represents views of recreational receptors

in the hills above Alwen Reservoir. Located

within Hiraethog SLA. Clocaenog LVIA

VP11.

5 A543 near

Cottage Bridge

292650 356532 1.8 km Represents views of road users on the A543.

6 Brenig

Archaeological

Trail


on the trail on the eastern side of Llyn

Brenig. Pant y Maen LVIA VP15.

7 Swch y Llan,

Cerrigydrudion

294928 348452 3.6 km Represents views of residents in the small

settlement of Cerrigydrudion in the Merddwr

valley. Clocaenog LVIA VP09.

8 Rhydlydan 289279 350844 4.2 km Represents views of residents in the small

settlement of Rhydlydan in the Merddwr

valley.

9 Craig 301857 351970 5.5 km Represents views of recreational receptors

20 Scottish Natural Heritage (February 2017) Visual Representation of Wind Farms Guidance. Version 2.2


No. Name Easting Northing

Approx.

Distance to

Nearest

Turbine Reason for Selection

Bronbanog

at a summit on the Hiraethog Trail within the

Clocaenog Forest. Clocaenog LVIA VP01.

Brenig Tip Height Extension LVIA VPK.

10 Footpath above

Cadair Benllyn


in Snowdonia National Park. Clocaenog

LVIA VP13. Brenig Tip Height Extension

LVIA VPI.

11 Foel Goch

(Arenigs)

295357 342285 9.7 km Represents views from a hill summit above Y

Bala.

12 B4407 near

Ysbyty Ifan

282757 347295 11.5 km Represents views from a road within

Snowdonia National Park.

13 Moel Famau 316069 362683 20.8 km Represents views of recreational receptors

at a popular summit in the Clwydian Range

and Dee Valley AONB. Clocaenog LVIA

VP16. Brenig Tip Height Extension LVIA

VPQ. Pant y Maen LVIA VP5.

Wireframe only.

14 Carnedd Moel

Siabod


at a popular summit in Snowdonia National

Park. Clocaenog LVIA VP 24. Brenig Tip

Height Extension LVIA VPV. Pant y Maen

LVIA VP23.

Wireframe only.

15 Summit of

Snowdon


at a popular summit in Snowdonia National

Park.

Wireframe only.

Question 19: Do consultees consider that the proposed viewpoints set out above are appropriate to inform the visual assessment, and that the suggested presentation of visualisations is proportionate?

Cumulative Assessment

11.1.31. A cumulative LVIA (CLVIA) will be undertaken in accordance with GLVIA3 and SNH Guidance21

. Initial

consideration will be given to all wind farms within 35 km which have a valid application, are consented,

under construction or are operational. Single turbines, and turbines less than 50 m height to tip, will not

be considered within the CLVIA, unless they are within 5 km of the site. Turbines of less than 20 m

height to tip will not be considered. Schemes at scoping will not be considered.

21 Scottish Natural Heritage (March 2012) Assessing the Cumulative Impact of Onshore Wind Energy

Developments


11.1.32. The intervisibility of the proposed wind farm development with other wind farms in the surrounding area

will be illustrated using combined ZTV (CZTV) maps, using ZTVs of each wind farm overlain on a base

map. Pairs of ZTVs will be prepared, shown together on a series of figures, to illustrate the key

relationships between the proposed wind farm development and other existing or proposed wind farms

close to the site. Where groups of wind farms lie close together or in similar directions at greater

distances, they will be grouped in order to rationalise the number of figures which is required.

Cumulative visual effects will be assessed through analysis of CZTVs, views from individual viewpoints

and sequential views from key routes, based on computer-generated wireframes. The magnitude of

cumulative change to landscape character reflects the additional influence the proposed wind farm

development has on the characteristics and character of the landscape, assuming the other wind farm

schemes are already present. Various scenarios will be considered, reflecting the status and therefore

the level of certainty of other wind farms being present in the landscape (i.e. in planning, at appeal, or

consented).

11.1.33. Table 11.3 presents all known wind energy developments within 45 km that fit the cumulative criteria

discussed above, and this list will be used to select those that will be considered within the CLVIA.

Cumulative wind farms are shown on Figure 11.3. It is accepted that the cumulative picture will change

in time and this will be considered during consultation and updated within the assessment.

Table 11.3: Wind Farm Developments to be considered as part of the Cumulative Assessment

Wind Farm Easting Northing

Tip Height

(m) Status

Distance

(km)22

Brenig 299466 357617 100 Under Construction 3.4

Pant y Maen 296919 359030 102 Consented 3.4

Tir Mostyn and Foel Goch 300432 357515 74.5 Operational 4.0

Clocaenog 301203 354643 145 Under Construction 4.1

Hafoty Ucha 293743 345608 61-81 Operational 7.4

Hafoty Ucha Repowering 293408 345504 86.5 Submitted 8.1

Moel Maelogen (Phase 2) 284899 360331 81 Operational 10.4

Moel Maelogen (Phase 1) 284902 361172 76 Operational 11.2

Wern Ddu 305570 347880 90 Operational 11.4

Braich Ddu Farm 301185 340887 90 Operational 13.9

Rhyl Flats 290161 388328 134 Operational 31.9

North Hoyle 303838 392229 107 Operational 36.3

Gwynt y Môr 294643 397007 138 Under Construction 37.1

Question 20: Is the approach to inclusion of schemes within the cumulative assessment appropriate? Are there other wind farm proposals that should be considered in the assessment?

22 Distance between the outermost turbines of the proposed wind farm development and cumulative wind

farm.


Residential Visual Amenity

11.1.34. Effects upon residential visual amenity become a matter of public rather than private interest when

properties or groups of properties become widely regarded as unattractive places to live. There is no

published guidance on the approach, which instead draws upon that set out in numerous previous

planning decisions.

11.1.35. A Residential Visual Amenity Study (RVAS) will be undertaken for all properties / groups of properties

within around 2 km of the nearest proposed turbine. For each property or group of properties, the

assessment will be informed by detailed ZTVs, aerial photography, wireframes and field work

undertaken from publicly accessible areas to identify the scale and extent of visual effects. The level of

detail and illustrative material provided for each property will be proportionate to the likely effects.

11.1.36. For those properties likely to be most affected, information including wireframes and any available aerial

photography will be provided alongside a detailed description of the predicted view from the property

and its curtilage and access drive (where applicable). The focus of the RVAS will be on identifying

whether any visual effects are likely to be considered to affect living conditions such that a property

becomes widely regarded as an unattractive place in which to live.

Question 21: Is the approach to the assessment of effects on residential visual amenity appropriate?

Decommissioning

11.1.37. At the end of the operational phase, the wind farm will either be decommissioned, or an application

made for consent to extend its operational life. Decommissioning will involve the removal of all above

ground infrastructure, including the turbines. Access tracks will likely be left in-situ. The changes to the

landscape arising from the decommissioning of the wind farm will be very similar to those arising from

construction. Decommissioning will not therefore be considered in the LVIA.

Grid Assessment

11.1.38. The grid connection is likely to be subject to a separate planning application, which will be accompanied

by an Environmental Statement, including a Landscape and Visual Impact Assessment (LVIA). In the

Environmental Statement for the Alwen Forest Wind Farm application, a brief high level

appraisal/summary of the potential landscape and visual effects associated with the grid connection will

be provided. The level of detail provided will depend upon the nature of the grid connection (i.e.

underground cable or overhead line).

12. Hydrology, Geology and Hydrogeology

12.1.1. This section of the scoping report outlines the information which currently exists as well as presenting

the baseline conditions applicable to the hydrological, hydrogeological and geological environment in the

surrounding region of the proposed Alwen Forest development.

12.1.2. As noted in Section 1 and 8 of this report, the intention of this scoping report is to introduce the project

and provide the competent authority and its advisors with sufficient information (where it currently exists)

on the likely impacts of the proposed Alwen Forest development on individual receptors and important

features at this stage. The intended approach will allow for an Environmental Impact Assessment (EIA)

that focusses on only those aspects of the proposed wind farm development that are likely to have a

significant impact on known hydrological, hydrogeological and groundwater receptors, as well as those

receptors that are currently unknown.


12.1.3. A hydrological baseline desktop review was undertaken in June 2018. The information gained from

desktop review has been presented in the following sections.

12.1.4. Where the impacts on important hydrological, hydrogeological and geological features (whether it be

direct or indirect) from the proposed Alwen Forest development are not likely to cause a significant

impact these have been detailed below. For each of these features, due to the proposed wind farm

development being not likely to have any impact on them, it is proposed that these receptors are ‘scoped

out’ and thus not included within the EIA.

12.1.5. The potential impact on any identified hydrological or hydrogeological receptor arising from the

development of the proposed grid route, irrespective of method i.e. overhead or underground would be

considered in the ES as a high level overview. This would identify any potential impacts and

consideration of appropriate mitigation measures to minimise any impact.

12.1.6. The structure of this section notes the guidance and legislation, methodologies used and identifies the

results from the work. Table 12.5 summarises the results in relation to the proposed development and

highlights whether or not the receptor will be included within the EIA.

Good Practice Mitigation

12.1.7. Mitigation will follow the well-established principles of industry good practice so as to prevent or

minimise effects on the surface and groundwater environment. The following good practice principles

will be included as part of the embedded mitigation:

Drainage – all runoff derived from works associated with the proposed development will not be

allowed to directly enter the identified natural drainage network. All runoff will be adequately treated

via a suitably designed drainage scheme with appropriate sediment and pollution management

measures. The proposed development is situated in an area of commercial forestry and it is

imperative that the drainage infrastructure is designed to maintain the existing hydrological regime

and meet the required design standards.

Storage – all soil/peat stockpiles as well as equipment, materials and chemicals will be stored well

away from any watercourses. Chemical, fuel and oil stores will be sited on impervious bases with a

secured bund.

Vehicles and Refuelling – standing machinery will have drip trays placed underneath to prevent oil

and fuel leaks causing pollution. Where practicable, refuelling of vehicles and machinery will be

carried out in designated areas, on an impermeable surface, and well away from any watercourse.

Maintenance – only emergency maintenance to construction plant will be carried out in designated

areas, on an impermeable surface well away from any watercourse or drainage feature, unless

vehicles have broken down necessitating maintenance at the point of breakdown, where special

precautions will be taken.

Welfare Facilities – on-site welfare facilities will be adequately designed and maintained to ensure

all sewage is disposed of appropriately. This may take the form of a soakaway or tankering and off-

site disposal depending on the suitability of the site for a soakaway and only with prior agreement

with Natural Resource Wales (NRW) / Local Planning Authority.

Cement and Concrete – fresh concrete and cement are very alkaline and corrosive and can be

lethal to aquatic life. The use of wet concrete in and around watercourses will be preferentially

avoided however if necessary it will be carefully controlled.

Monitoring Plan – all activities undertaken as part of the proposed development will be monitored

throughout the construction phase. Such monitoring will be to ensure environmental compliance.


Contingency Plans – plans will ensure that emergency equipment is available on site i.e. spill kits

and absorbent materials, advice on action to be taken and who should be informed in the event of a

pollution incident.

Training – All relevant staff personnel will be trained in both normal operating and emergency

procedures, and be made aware of highly sensitive areas on site.

12.1.8. Further details on specific mitigation requirements will be provided as part of the ES. This is likely to

include the preparation of a site specific Construction Environmental Management Plan (CEMP) as well

as appropriate and applicable technical appendices. It should be acknowledged that this CEMP would

be an outline CEMP in certain elements of its detail, due to the requirement of detailed engineering

design which may not be available at the stage of the application, but nonetheless, will be guided by

good practice and legislation.

Legislation, Guidance and Consultation

International Legislation and Policy

12.1.9. The assessment takes into account the requirements of the Water Framework Directive (2000/60/EC)

(WFD). The WFD aims to protect and enhance the quality of surface freshwater (including lakes, rivers

and streams), groundwater, groundwater dependent ecosystems, estuaries and coastal waters. The key

objectives of the WFD relevant to this assessment are:

To prevent deterioration and enhance aquatic ecosystems; and

To establish a framework of protection of surface freshwater and groundwater.

National Legislation and Regulations

12.1.10. This assessment takes into account the following legislation and policy:

The Water Environment (Water Framework Directive) (England and Wales) Regulations 2017;

Land Drainage Act 1994;

Flood and Water Management Act 2010;

Water Act 2014;

The Pollution Prevention and Control (England and Wales) Regulations 2000;

The Water Supply (Water Quality) Regulations 2018;

The Private Water Supplies (Wales) Regulations 2017;

The Waste (England and Wales) (Amendment) Regulations 2012;

Part IIa of the Environment Protection Act 1990; and

The Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017.

Policy & Guidance

12.1.11. The following regional policies are also taken into account during the assessment:

Planning Policy Wales (Edition 9) – November 2016;

Technical Advice Note 8: Renewable Energy;

Technical Advice Note 15: Development and Flood Risk;

Conwy County Borough Council Local Development Plan; and

Denbighshire County Council Local Development Plan.

12.1.12. Table 12.1 lists other guidance and best practice documentation which has been considered as part of

this assessment.


Table 12.1: Guidance and Best Practice

Topic Source of Information

NRW Pollution Prevention Guidelines (PPG’s)* PPG 1 Understanding your environmental

responsibilities - good environmental practices

GPP 2: Above ground oil storage tanks

GPP 4: Treatment and disposal of wastewater where

there is no connection to the public foul sewer

GPP 5: Works and maintenance in or near water

PPG 6: Working at construction and demolition sites

GPP 8: Safe storage and disposal of used oil

GPP 13: Vehicle washing and cleaning

GPP 21: Polluting incident response planning

Construction Industry Research and Information

Association (CIRIA)

CIRIA C692 Environmental Good Practice on site

(third edition)

CIRIA C697 The SuDS Manual

CIRIA C532 Control of Water Pollution from

Construction sites

CIRIA C624 Development and Flood Risk – guidance

for the construction industry

CIRIA C648 Control of Water Pollution from Linear

Construction Projects

CIRIA C689 Culvert Design and Operation Guide

Other Guidelines Scottish Renewables Joint Publication, (2015) Good

Practice During Wind Farm Construction Version 3

FCE, SNH, (2010), Floating Roads on Peat

Scottish Renewables, Joint Publication (2012),

Development of Peatland: Guidance on the

Assessment of Peat Volumes, Reuse of Excavated

Peat and the Minimisation of Waste

*A review plan for the PPGs is currently underway. The review will result in a replacement guidance series,

Guidance for Pollution Prevention (GPPs). It is aimed that the new series will provide environmental good

practice guidance for the whole UK, and environmental regulatory guidance directly to Northern Ireland,

Scotland and Wales23

Consultation

12.1.13. Throughout the EIA stage, on-going consultation will be undertaken with relevant stakeholders, including

NRW and Dŵr Cymru to ensure the layout and the approach to EIA is considered acceptable. It is

acknowledged that Alwen Reservoir is a drinking water source, therefore protecting Dŵr Cymru’s

interests will be crucial for this project and consultation will be maintained with Dŵr Cymru at all stages

of the project.

23 Net Regs (2018). Guidance for Pollution Prevention (GPPs) - Full List. [Online]. Available from:

http://www.netregs.org.uk/environmental-topics/pollution-prevention-guidelines-ppgs-and-replacement-

series/guidance-for-pollution-prevention-gpps-full-list/ [Accessed: 20/06/2018]

http://www.netregs.org.uk/environmental-topics/pollution-prevention-guidelines-ppgs-and-replacement-series/guidance-for-pollution-prevention-gpps-full-list/

http://www.netregs.org.uk/environmental-topics/pollution-prevention-guidelines-ppgs-and-replacement-series/guidance-for-pollution-prevention-gpps-full-list/


Survey Work Undertaken

12.1.14. The following sections summarise the desktop survey work that has been undertaken to inform the

hydrological, hydrogeological and geological details which are subsequently presented in this scoping

report.

Desk Based Study

12.1.15. A desk based study has been undertaken in order to establish the hydrology, hydrogeological and

geological conditions underlying the area of the proposed development. A detailed review of

documentation and data sources has been undertaken, as detailed in Table 12.2.

Table Error! No text of specified style in document..2:Baseline Information Sources

Topic Sources of Information

Topography 1:25,000 Ordnance Survey Mapping

1:50,000 Ordnance Survey Mapping

Designated Nature and

Conservation sites

NRW Designated Sites (http://naturalresources.wales/guidance-and-

advice/environmental-topics/wildlife-and-biodiversity/find-protected-areas-of-

land-and-seas/designated-sites/?lang=en) [Accessed 04/07/2018]

Solid and Superficial Geology 1:50,000 Solid and Superficial Geology data provided by the British

Geological Survey (BGS)

Soils and Peat UK Soil Observatory Map Viewer (http://www.ukso.org/mapViewer.html)

[Accessed 04/07/2018]

Surface Water Hydrology 1:25,000 OS Raster Data

1:50,000 OS Raster Data

Flooding NRW Long Term Flood Risk Map (https://naturalresources.wales/evidence-

and-data/maps/long-term-flood-risk/?lang=en) [Accessed 04/07/2018]

Water Quality NRW Water Watch Wales Map Gallery

(http://waterwatchwales.naturalresourceswales.gov.uk/en/) [accessed

04/07/2018]

NRW River Basin Management Plans

(https://naturalresources.wales/evidence-and-data/research-and-

reports/water-reports/river-basin-management-plans-published/?lang=en)

[Accessed 04/07/2018]

Water Resources 1:50,000 OS Raster Data

Conwy and Denbighshire Council PWS Data Request

Hydrogeology 1:625,000 Hydrogeology data provided by the British Geological Survey

(http://mapapps2.bgs.ac.uk/geoindex/home.html) [Accessed 04/07/2018]

Baseline Results

12.1.16. Through the desk study the existing site conditions have been established and are outlined below.

Topography

12.1.17. The landscape of the proposed development is characterised by extensive coniferous forestry

plantation. The general topography slopes north west to south east, following the Alwen Reservoir, with

valley sides sloping north east or south west towards the reservoir. The maximum elevation change

across the proposed development is approximately 140 meters Above Ordnance Datum (AOD) from 470

http://naturalresources.wales/guidance-and-advice/environmental-topics/wildlife-and-biodiversity/find-protected-areas-of-land-and-seas/designated-sites/?lang=en



http://www.ukso.org/mapViewer.html

https://naturalresources.wales/evidence-and-data/maps/long-term-flood-risk/?lang=en


http://waterwatchwales.naturalresourceswales.gov.uk/en/

https://naturalresources.wales/evidence-and-data/research-and-reports/water-reports/river-basin-management-plans-published/?lang=en

https://naturalresources.wales/evidence-and-data/research-and-reports/water-reports/river-basin-management-plans-published/?lang=en

http://mapapps2.bgs.ac.uk/geoindex/home.html


m AOD to 330 m AOD. From a wider perspective the proposed development is situated downslope of

the Mwdwl–eithin topographic summit to the west and Gorsedd Bran topographic summit to the north.

Designated Sites

12.1.18. Within a 3 km radius of the proposed development boundary there is a site designated as a National

Nature Reserve (NNR) within a Site of Special Scientific Interest (SSSI) located adjacent to north-

western corner of site boundary (see Figure 3.2). Hafod Elwy Moor NNR is designated as part of the

Mynydd Hiraethog SSSI which is qualified for its areas of blanket bog, dry heath, and mixture of heath

and mire habitats.

12.1.19. The designated sites are upslope of the proposed development and it is unlikely that there will be any

direct impacts from a hydrological perspective as a result of construction or operation. Designated sites

are therefore proposed to be scoped out.

Site Hydrology

12.1.20. The main hydrology feature within the immediate vicinity of the proposed development is the Alwen

Reservoir within the Afon Alwen catchment. A number of mapped watercourses are identified within the

proposed development. These watercourses drain outside the proposed development to the Alwen

Reservoir with a couple of watercourses draining towards the north east out into Llyn Brenig. A review

of aerial photography shows extensive forestry works within the proposed development and some

evidence of the associated increased functional drainage of the land through the cutting of artificial

drainage ditches and furrows, which ultimately feed into the Alwen Reservoir and Llyn Brenig.

Appropriate consideration of these features would be outlined within the application, including buffer

distances.

12.1.21. Due to the proximity of proposed infrastructure to mapped watercourses further assessment will be

required to determine the level of impact from water quality, flooding and potential pollution.

Flood Risk

12.1.22. A qualitative flood risk assessment has been undertaken where the risks of flooding have considered all

sources and reference to NRW’s Flood Map24

. The assessment has considered the risk to the proposed

development as well as the increase in flooding downstream caused by the development.

Fluvial and Pluvial Flooding

12.1.23. A review of NRW’s Flood Map indicates that the Afon Alwen, in the immediate vicinity of the proposed

development, has a medium (between 1 in 100 year event to a 1 in 30 year event) to high risk (less than

a 1 in 30 year event) of flooding. This extends beyond the channel. Within the proposed development

boundary there is mainly a low (between 1 in a 1000 year event to 1 in a 100 year event) to medium risk

of flooding from surface waters.

Tidal Flood Sources

12.1.24. The proposed development is greater than 10 km away from the nearest coast. Given the distance to

the coast and the topographical position of the proposed development it will not be affected by tidal

flooding and therefore scoped out of the assessment.

Groundwater Flood Sources

12.1.25. Flooding can also result from high groundwater levels if the water table rises above the surface level.

Groundwater flooding happens in response to a combination of already high groundwater levels (usually

during mid- or late-winter) and intense or unusually lengthy storm events. Groundwater flooding is

24 NRW. (2018) Long term flood risk. [Online]. Available from https://naturalresources.wales/evidence-and-

data/maps/long-term-flood-risk/?lang=en [Accessed 20/06/2018].




difficult to predict as it rarely follows a consistent pattern. The response time between rainfall and

groundwater flooding is also relatively long.

12.1.26. Groundwater flooding is often associated with the shallow unconsolidated sedimentary aquifers that over

lie non-aquifers. Such aquifers are susceptible to flooding as the storage capacity within these deposits

is often limited and direct rainfall recharge can be relatively high, subsequently increasing the water

levels within the groundwater.

Flooding from Artificial Drainage

12.1.27. There is evidence of artificial drainage associated with forestry works within the Alwen Forest

Development Area. There is the potential that this could cause some localised flooding by increasing

runoff rates to the watercourse they drain to within the surrounding area.

12.1.28. Due to proximity of infrastructure to mapped watercourses which have been determined as being at risk

from fluvial flooding further assessment on the potential impacts will be required.

Soils

12.1.29. The distribution of soils across the proposed development is dependent upon land use, geology,

topography and hydrological regime of the area. Information on the site soils has been provided by the

UKSO25

and is presented below in Table 12.3.

Table 12.3: Summary of Soil Types

Generalised Soil Type Parent material

Blanket Bog Peat

Peat/Blanket Bog Mudstone and Sandstone

Wet acid upland soil, with peaty surface Mudstone and Sandstone

Very acid, upland loamy soil, with peaty surface. Glacial Till

12.1.30. The information indicates that peaty soils are the dominant type within the area of the proposed

development.

12.1.31. At the time of writing an initial peat survey has been scheduled to inform any potential site constraints.

This has been limited to reaches of new access track and the indicative turbine locations. Review of this

information will assist in the determination of further peat surveys required. This will also determine the

requirements for the production of a Peat Management Plan as well as a Peat Slide Risk Assessment

Additional investigation of the wider area within the proposed development should be considered

following review of initial peat survey data.

12.1.32. In terms of the delivery of the EIA, it is envisaged that further peat investigation/survey effort will be

undertaken. This shall consist of a 100 m gridded pass over all proposed infrastructure areas.

Following refinement/finalisation of the scheme layout, detailed probing will be proposed. Detailed

probing will consist of the following:

50 m gridded points for borrow pits and compounds/substations;

50 m spacing along centreline, with 10 m offsets along all new track sections;

Determination of specific widening sections of the existing access track, with the same method

applied; and

10 m spacing transects north-south and east-west out to 100 m for all turbine locations.

25 UKSO (2018). UK Soil Observatory map viewer. [Online].Available from

http://www.ukso.org/mapViewer.html [Accessed 20/06/2018]

http://www.ukso.org/mapViewer.html


Geology

12.1.33. According to the 1:50,000 scale British Geological Society (BGS) dataset, the proposed development is

underlain by the geological units presented in Table 12.4.

Table 12.4:Solid and Superficial Geology

Element Type Comments

Denbigh Grits Formation,

Mudstone, Siltstone, and

Sandstone

Sedimentary rock These sedimentary rocks are marine in origin. They are

detrital and comprise coarse- to fine-grained slurries of

debris from the continental shelf flowing into a deep-

sea environment, forming distinctively graded beds.

Denbigh Grits Formation:

Sandstone




sea environment, forming distinctively graded beds.

Nantglyn Flags Formation:

Mudstone and Siltstone




sea environment, forming distinctively graded beds

Till Superficial deposit These sedimentary deposits are glacigenic in origin.

They are detrital, created by the action of ice and

meltwater, they can form a wide range of deposits and

geomorphologies associated with glacial and inter-

glacial periods during the Quaternary.

Peat Superficial deposit These sedimentary deposits are lacustrine and

palustrine in origin. They comprise accumulated (and

detrital) organic material, forming beds and lenses

within lagoons, bogs and swamps.

12.1.34. The underlying solid geology comprises the Denbigh Grits Formation that covers the majority of the

proposed development, and the Nantglyn Flags Formation which underlays a small section in the north.

Superficial deposits of peat are well spread across the proposed development, however till can be found

on the edges of the Alwen Reservoir with larger deposits present further north and south.

12.1.35. It is noted that no specific geological feature of interest has been identified within the proposed

development (excluding peat and soils which are discussed separately), as such this can be scoped out

of the assessment. Although having an understanding of the underlying bedrock and superficial geology

is pivotal for the effectiveness of the construction design of the proposed development, specific

mitigation to protect the geodiversity during construction, operation and decommissioning is not

required. The information of the local geology will be utilised in the assessment of groundwater

dependent terrestrial ecosystems (GWDTEs).

Hydrogeology

12.1.36. Following review of the 1:625,000 scale BGS Hydrogeological Map26

the proposed development is

underlain by a low productivity aquifer associated with the Wenlock Rocks (undifferentiated). The

sedimentary interbedded sandstone conglomerate would give rise to limited groundwater. Flow is

virtually all through fractures and other discontinuities.

26 BGS (2018). BGS hydrogeology 625K. [Online]. Available from

http://www.bgs.ac.uk/products/hydrogeology/maps.html [Accessed: 20/06/2018]

http://www.bgs.ac.uk/products/hydrogeology/maps.html


12.1.37. At this stage, no assessment has been made on the groundwater dependency of the identified habitats

located within the proposed development area. A thorough review and inclusion of appropriate

assessment will be included in the ES to determine the characteristics of the hydrogeological

environment and its suitability to support GWTDEs. The ES will be prepared with cognisance of the

habitats and NVC assessment completed as part of the Ecology assessment.

Fisheries

12.1.38. Review of fisheries information to be undertaken from ecology to determine whether this is an identified

receptor which will require assessment.

Water Resources

12.1.39. A data request was issued to the local authorities to determine the presence of any water abstractions

for private water supply use using a 3 km buffer around the proposed development boundary. There are

a number of properties being supported by Private Water Supplies (PWS) therefore these will be further

assessed as part of the EIA.

Carbon Balance Assessment

12.1.40. A carbon balance assessment will be produced to give an indication of the proposed development’s

impact on the existing peat on site and to assess the potential effects in terms of carbon dioxide (CO2)

emissions against the total potential carbon savings attributed to the proposed development. The

assessment will quantify the gains over the life of the project against the release of CO2 during

construction, including loss of peat bog and construction of roads/tracks and other infrastructure. The

latest version of the Carbon Calculator that is available before the application is submitted will be used.

It is not expected for there to be any requirement for the Carbon Balance assessment to be amended

post submission should any further update of the Carbon Calculator occur.

Impact Assessment

12.1.41. Based on the findings of the baseline study and whether the significance of any impact on receptors can

be quantified Table 12.5 identifies what is proposed to be scoped in and out of the assessment.

Table 12.5: Proposed Scoping Topics

Baseline Scope in or

out

Reason

Designated Sites Scope Out The designated sites (SSSI/NNR) are located upslope of the proposed

development and it is unlikely that there will be any direct impacts from a

hydrological perspective as a result of construction or operation.

Site Hydrology Scope In The main water feature is the Alwen Reservoir within the Afon Alwen

catchment which is in close proximity to the proposed development. An

appropriate level of assessment will need to be considered to understand

the potential impacts of the development on water quality, flood risk and

potential pollution.

Flood Risk Scope In Whilst a desk based assessment has been provided above, further

assessment will be required due to the mapped water features in the

proximity to proposed infrastructure.

Peat and Soils Scope In The initial desktop study identifies extensive areas of peat soils which is to

be supported by an initial peat survey. Further assessment will likely be

required to inform a carbon balance assessment, peat management plan

and peat slide risk assessment. Information on peat and soils will also be

utilised for production of a GWDTE assessment.


Baseline Scope in or

out

Reason

Geology Scope Out No specific mitigations to protect geodiversity are required. Review of the

local geology information will be considered for the GWDTE assessment.

Hydrogeology Scope In Assessment will be required to confirm the presence of GWTDE on site

based habitat, soils and hydrogeological information.

Fisheries Scope In At this stage it is unclear whether fisheries is an identified receptor.

Water Resource Scope In PWS are identified within the surrounding area and further assessment

required in the EIA.

Carbon Balance Scope In Initial desk top study and site visits indicate the presence of peat on site,

and although careful siting of infrastructure will minimise the impact on

peat, the use of the carbon calculator tool will assess the carbon impact of


Question 22: Are consultees in agreement with the topics to be scoped out?

13. Cultural Heritage

13.1.1. This section presents the proposed scope of work for the Cultural Heritage Assessment for Alwen Forest

Wind Farm. The purpose of the assessment is to identify the potential effects of the proposed

development on the historic environment and cultural significance of the area in which the development

is located. The heritage impact assessment will follow policy and best practice guidance in order to

establish a robust and transparent analysis of the issues. The approach adopted will follow a standard

staged process consisting of baseline survey to identify known and potential historic assets, design

iteration to avoid constraints and minimise potential impacts on the historic environment, comparative

analysis to determine which historic assets might be affected by the proposed development, field survey

and analysis to establish the heritage significance of important affected assets, characterising the nature

and magnitude of impacts, design of mitigation measures, and an assessment of the residual effect on

the historic environment.

Environmental Baseline and Potential Sources of Impact

Baseline Conditions

13.1.2. No Designated Historic Assets (DHAs) of national importance lie within the Alwen Forest Development

Area (site boundary) (Figure 13.1a and 13.1b). Two listed buildings (LBs) and one scheduled monument

(SAM) are adjacent to the site boundary, located in the valley between the two parts of the Development

Area and at its south-eastern corner. Analysis of the distances from the nearest turbines to DHAs shows

that three LBs and on SAM are located within 2 km. Within the 2 – 5 km zone from the nearest turbines

there are 24 LBs and 11 SAMs (all LBs are Grade II). Within 5 – 10 km there are 129 LBs and 35 SAMs

(6 LBs are Grade II*).

13.1.3. Two versions of the Mynydd Hiraethog/Denbigh Moors Registered Landscape of Special Historic

Interest in Wales (Historic Landscape Wales No. 39) exist. Cadw’s advice in response to a query over

the exact boundaries of the HLW was “In some cases, Historic Character Area edges can fall outside the

extent of the landscape areas on the Register. In planning terms, the Register is non-statutory, and so is

the information from characterisation that is intended to support it. It will be a matter for the planning or

other competent authority undertaking an EIA, or the PI Inspector concerned, to determine where a

precise edge should be drawn.”


13.1.4. One of the HLWs is represented within the published register and is located almost entirely within the

Mynydd Hiraethog Site of Special Scientific Interest (SSSI). It includes only the very northern tip of the

site within its boundary. A more detailed map of this HLW designation divides it into 15 Character Areas

which have been created following the results of survey work by the Clwyd Powys Archaeological Trust

(CPAT) (Figure 13.2). From this more detailed and extended map of the HLW area, all of the northern

section of the site, as well as the Alwen Reservoir itself, have been included in the HLW. This includes

two Character Areas: 1111 Alwen Reservoir and 1110 Bryn y Gors-goch. The first is for the 20th century

reservoir superimposed on a medieval and later enclosed landscape, whilst the latter is summarised as

“Modern coniferous forest plantation overlying relict medieval and later enclosed landscape of scattered

farmsteads with associated field systems and stone quarrying”.

13.1.5. The HLW designation has been made to preserve an increasingly rare historic landscape of upland

heather moorland that was managed as a grouse moor and shooting estate in the early 20th century, but

had its origins in the Neolithic and Bronze Age (and possibly earlier). During medieval and post-medieval

times summer grazing and seasonal occupation was followed by some permanent settlement, for

farming and peat cutting.

13.1.6. There are 467 non-designated historic assets of local importance listed within a 2 km buffer from the site

boundary (as shown on Figure 13.3). This number includes approximately 50 within the site, and a

further 20 on the edge or adjacent. In addition there are 34 entries for archaeological investigations in

the Clwyd Powys Archaeological Trust’s (CPAT) Historic Environment Record (HER) within the same 2

km buffer.

Potential Sources of Impact

13.1.7. Potential effects on cultural heritage associated with the construction and/or operation of the proposed

development include:

Direct effects through partial or total removal during groundworks (including turbine bases, crane

pads, borrow pits, access road etc.) on known or currently undiscovered buried remains of

archaeological interest;

Indirect effects through development within the settings of designated historic assets including those

resulting from intervisibility between an asset and the proposed development; and

Cumulative effects on designated heritage assets with other proposed developments.

13.1.8. Decommissioning should not result in further damage as the ground disturbance would already have

occurred during the construction phase, and therefore is scoped out of the assessment.

Method of Assessment

Legislative, Policy and National Guidance Framework

13.1.9. The proposed Alwen Forest development is one which requires Environmental Impact Assessment

under the Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017.

The assessment will comply with Welsh legislative and planning policy frameworks, and apply Cadw’s

relevant guidance, to ensure the EIA is undertaken in a robust manner.

The Historic Environment (Wales) Act 2016 is the primary statutory tool for protecting historic assets

and sustainable management of the historic environment. It is designed to enable greater

transparency into decisions taken on the historic environment and to make it a statutory requirement

for information on the historic environment to be safe-guarded for the public good.

National policy within Wales is set out in Planning Policy Wales Edition 9, November 2016 (PPW), in

which Chapter 6 Conserving the Historic Environment explains the need for a reasonable and


proportionate impact assessment to ensure proposed development is sustainable and to prevent

unnecessary harm to historic assets.

PPW is supported by Technical Advice Note 24: The Historic Environment (May 2017) which is

designed to assist local authorities with developing their local plans and for determination of

planning applications or listed building consent in relation to historic assets. The Welsh Ministers

and Planning Inspectors will consider these guidance documents when considering the proposal.

The two principal guidance documents that will be followed in this assessment are those produced

by Cadw on behalf of the Welsh Government for managing historic assets: Heritage Impact

Assessment in Wales (May 2017) and the Setting of Historic Assets in Wales (2017).

Cadw’s Conservation Principles for the sustainable management of the historic environment in

Wales (March 2011) would also be used to establish objective assessment of the value and

significance of historic assets within and surrounding the proposed development site.

In relation to the Registered Landscape of Special Archaeological Interest in Wales, Natural

Resources Wales (NRW)’s Guide to Good Practice on Using the Register of Landscapes of Historic

Interest in the Planning and Development Process will be used.

The Chartered Institute for Archaeologists’ standard and guidance for Historic Environment Desk-

Based Assessment (January 2017) provides national quality standard for the baseline study.

Baseline Desk Study

13.1.10. It is proposed that the cultural heritage assessment will employ two study areas. The Inner Study Area

will comprise the proposed development and the area up to 2 km from the outermost proposed turbines.

This area will allow the development of the local historic environment to be understood in detail, and to

make an assessment of the significance of known assets, and the potential for currently unknown assets

to occur, within the boundary of the proposed development. Analysis of indirect effects will be carried out

on all DHAs within the Inner Study Area and within 2 – 5 km of the boundary of the proposed turbines

(‘the Outer Study Area’). DHAs between 5 – 10 km will be shown also, but if required at all, assessment

will be limited to specific assets whose heritage significance is related to long distance views that might

be changed by the proposed wind farm, such as Registered Parks and Gardens, or hillforts. Intangible

cultural heritage for the combined study areas would also be considered at this stage, to include for

example potential artistic or literary associations, sacred space, or local traditions and customs.

Baseline Field Study and Virtual Modelling

13.1.11. A site inspection will be carried out over the area of the proposed development to establish the condition

of historic assets and identify the potential for the existence of additional assets not currently identified. It

will also identify the contemporary existing environment (including historic and modern developments

and land-use including already constructed wind farms) to help understand the setting of DHAs and the

degree of change that the proposed development might introduce.

13.1.12. To assist with the impact assessment a staged approach will be undertaken. Field inspections will be

made after a filtering exercise to identify those DHAs that would not experience visual change, and can

be scoped out. This would be achieved by comparison of mapped DHAs to the Zone of Theoretical

Visibility (ZTV) data and aerial imagery. For those DHAs which show a potential change to their setting

by turbines or hubs being visible, further analysis would be undertaken to assess the level of impact.

The ZTV mapping uses a bare earth model and even when it suggests potential visibility of the proposed

turbines from DHAs, intervening vegetation and structures might screen views. It is envisaged that all

designated assets; either individually or in associated groups, will be inspected where there is reason to

predict significant intervisibility with the turbines.

13.1.13. It is not proposed that all DHAs within the Outer Study Area would need detailed assessment, but a

representative selection of these might require computer modelling (wirelines and/or photomontages) to

assist in compiling a robust evidence base for assessment. Some of these locations might coincide with


the Landscape and Visual Impact Assessment (LVIA) viewpoints, but the following list provides those

DHAs which on current information are likely to benefit from this approach due to proximity and within

the ZTV for all nine turbines being potentially visible:

Ffrid Brynhelen Enclosures and Field system (DE228)

Nant Heilyn Stone Setting (DE284)

Bwlch-Du Round Barrow (DE085)

Hen Ddinbych barrows and platforms (a group asset) (DE086, DE087)

Cae Ddunod Camp (DE076)

Question 23: Do consultees have any comments regarding the approach noted above?

Assessment of Heritage Significance

13.1.14. Analysis of the designated historic assets and historic mapping will allow synthesis and interpretation of

the historic development of the site, and enable the heritage significance to be established in

accordance with Cadw’s Heritage Impact Assessment in Wales (section 4.2) and Conservation

Principles for the sustainable management of the historic environment in Wales. This analysis will also

establish what comprises the setting for the DHAs, and what elements of that setting contribute to how

the asset is experienced, understood and appreciated. Assessment of the heritage significance

(sensitivity) of the asset would use the criteria in the following table (the HLW is not included as this has

a specific assessment methodology and scoring mechanism that needs to be applied, so is itemised

separately below).

Table 13.1: Levels of heritage significance

Heritage Significance Explanation

Highest World heritage sites

Scheduled monuments

Grade I and II* listed buildings

Grade I and II* registered parks and gardens

Designated battlefields

Protected wrecks

Non-designated assets of equivalent national significance

High Grade II listed buildings

Grade II registered parks and gardens

Conservation areas

Non-designated assets of equivalent significance

Archaeological sites which are of particular individual importance within the

regional archaeological resource

Medium Archaeological sites of local importance

Low Sites that are of minor importance or with little remaining to justify a higher

category

Negligible Negligible or no heritage significance

Unknown Further information is required to assess the potential of these sites

Source: SLR Consulting

Initial Input to Design Iteration and Mitigation

13.1.15. Analysis of Geographic Information System (GIS) layered data about the historic environment will be

provided to the design team to assist with avoiding or minimising both direct and indirect effects on


heritage assets. Where potential adverse impacts on cultural heritage are identified, measures to

prevent, reduce and/or where possible offset will be proposed.

Assessment of Potential Impacts

13.1.16. The proposed development would result in change to the existing baseline, and change might be

considered as impacts according to the degree of change in relation to heritage significance. In

accordance with EIA regulations, the assessment would identify impacts and effects as direct or indirect,

adverse or beneficial, and short-term, long-term or permanent. Direct impacts are those which physically

alter an asset and therefore its heritage significance; indirect impacts are those which affect the heritage

significance of an asset by causing change within its setting. Application of Cadw’s Managing: Setting of

Historic Assets in Wales will require a four stage process in assessment of impacts:

Stage 1: Identify the Historic Assets

Stage 2: Define and Analyse the Setting

Stage 3: Evaluate the Potential Impact of Change or Development

Stage 4: Consider Options to Mitigate the Impact of a Proposed Change or Development

13.1.17. Magnitude of impact will be assessed with reference to the criteria set out in Table 13.2.

Table 13.2: Magnitude of impact

Magnitude of impact Definition

High beneficial The development would considerably enhance the heritage significance of the

affected asset or the ability to appreciate it

Medium beneficial The development would enhance to a clearly discernible extent the heritage

significance of the affected asset or the ability to appreciate it

Low beneficial The development would enhance to a minor extent the heritage significance of the


Very low beneficial The development would enhance to a very minor extent the heritage significance of

the affected asset or the ability to appreciate it

Neutral/None The development would not affect, or would have harmful and enhancing effects of

equal magnitude, on the heritage significance of the affected asset or the ability to

appreciate it

Very low adverse The development would erode to a very minor extent the heritage significance of

the affected asset or the ability to appreciate it

Low adverse The development would erode to a minor extent the heritage significance of the


Medium adverse The development would erode to a clearly discernible extent the heritage

significance of the affected asset or the ability to appreciate it

High adverse The development would severely erode the heritage significance of the affected

asset or the ability to appreciate it


Assessment of Potential Effects

13.1.18. Following design freeze the EIA will assess the potential direct effects for heritage assets from

construction activities within the site and along the grid connection route. It would also assess the

potential indirect effects from the operational phase, principally noise, flicker and intervisibility, to

designated heritage assets within the Inner Study Area from significant change to their settings. Within

the Outer Study Area assessment would be focussed on DHAs of the highest heritage significance

(Table 13.1) that have not been filtered out due to the ZTV showing minimal or no visual change.


13.1.19. Analysis of data gathered during the desk study and site visit layered within a GIS, combined if

necessary with photographs and wireframe visualisations of the topography and proposed turbines from

the location of key heritage assets, will be used to facilitate assessment.

13.1.20. These assessments will be carried out using professional judgement, taking into account designations

and heritage significance as assessed against national standards. Significance of effect will be based on

a combination of heritage significance (in other disciplines sometimes referred to as sensitivity of the

receptor) and magnitude of impact. The significance of effect matrix is presented in the table below and

relates the heritage significance to the magnitude of impact (incorporating contribution from setting

where relevant) to establish the likely significance of effect.

Table 13.3: Significance of Effect

Magnitude of

Impact Heritage Significance

Highest High Medium Low

En

ha

nce

me

nt

High Beneficial Substantial Substantial Moderate Slight

Medium beneficial Substantial Moderate Slight Very slight

Low beneficial Moderate Slight Very slight Very slight

Very low beneficial Slight Very slight Negligible Negligible

Neutral/nil Neutral/nil Neutral/nil Neutral/nil Neutral/nil Neutral/nil

Very low adverse Slight Very slight Negligible Negligible

Harm

Low adverse Moderate Slight Very slight Very slight

Medium adverse Substantial Moderate Slight Very slight

High adverse Substantial Substantial Moderate Slight


ASIDOHL 2

13.1.21. This scoping report would indicate that the introduction of turbines into the HLW would have direct and

indirect impacts, on the historic landscape. Although this has not prevented permission for Clocaenog or

Brenig wind farms, NRW has raised concerns over wind farm applications and their potential impact on

HLWs in other parts of Wales. Development within an HLW is not forbidden, but the designation

presents a further level of potential harm to the historic environment that would need to be robustly

assessed. A full ASIDOHL2 would be required to complement any EIA and related planning submission,

and ultimately the public benefit that might derive from the scheme would be an essential element in

determining whether the development would receive permission.

Cumulative Effects

13.1.22. A cumulative effect is considered to occur when there is:

An effect on an asset or group of assets due to changes which would be caused by the main

development under assessment; and

An effect on the same asset or groups of assets which would be caused by another development or

developments.

13.1.23. Consideration of the other potential contributor developments is limited to those of the following kind:

Wind farm developments which have been applied for with decision pending; and

Wind farm developments which been granted permission but not yet implemented.

13.1.24. Effects from operational wind farms and those under construction would be included in the baseline

position. Consultation with Cadw and Conwy and Denbighshire County Councils would assist with


identifying developments to be considered within the cumulative assessment. Single turbine schemes

and all turbines below 50 m would be outside the scope, but otherwise the cumulative assessment

would review an area of 5 km in extent from the outlying turbines of the proposed Alwen Development.

Question 24: Are consultees in agreement with the proposed methodology for cumulative assessment?

Consultation

13.1.25. Consultation with respect to the method of assessment employed and the cultural heritage assets will be

undertaken with Cadw (SAMs, Grade I and II* LBs and Registered Parks and Gardens, and ASIDOHL2

(also with NRW)), and Conwy and Denbighshire Councils (Grade II LBs and RPGs, conservation areas),

and CPAT (non-designated heritage assets).

Matters Scoped Out

13.1.26. It is not proposed that cultural heritage issues in general would be scoped out. Where it is found that the

proposed change to the baseline setting cannot affect specific assets this will be noted in the ES and no

further assessment of such assets undertaken. For example there are no Grade I or Grade II* LBs in the

Inner or Outer Study Areas, and only three Grade II LBs lie within the Inner Study Area, so the likelihood

of significant effects is greatly reduced due to distance from the turbines. The provisional ZTV modelling

suggests four LBs within the Inner and Outer Study Areas might have potential visibility of blade-tips, but

vegetation screening and the degree of impact on the specific heritage significance of these Grade II

LBs, might allow them to be scoped out early in the assessment process.

13.1.27. It is possible that the grid connection route could be scoped out, dependent on the type designed and its

location. For example if designed as underground cabling, located to run alongside existing roads, then

the potential for these works to impact on buried archaeological remains in previously disturbed contexts

(due to their proximity to existing roads), and the lack of visual impact on the setting of DHAs, suggests

detailed assessment of the grid connection could be scoped out.

Question 25: Are consultees in agreement with the approach to scope out certain cultural heritage aspects?

14. Traffic and Transport

Introduction

14.1.1. As part of this scoping exercise an assessment of the traffic and transport associated with Alwen Forest

Wind Farm development has been undertaken.

Guidance

14.1.2. The ‘Guidelines for the Environmental Assessment of Road Traffic’ (EART), published by the Institute of

Environmental Assessment (IEA) is used to assess the environmental impact of traffic generated by a

proposed development. The EART suggests that two rules can be used as a screening process to

delimit the scale and extent of the assessment:

Rule 1 – Include highway links where traffic flows would increase by more than 30% (or the number

of Heavy Goods Vehicles (HGVs) would increase by more than 30%);

Rule 2 – Include any other specifically sensitive areas where traffic flows would increase by 10% or

more. (IEA Guidelines Paragraph 3.20 defines sensitive area as including “accident blackspots,

conservation areas, hospitals, links with pedestrian flows etc.”).


14.1.3. Where the predicted increase in traffic flow is lower than these thresholds, the significance of the effects

can be stated to be low or insignificant, and further detailed assessments are not warranted. Where the

predicted increase in traffic flow results in a high significance then further mitigation is required in order

to minimise the potential impact.

14.1.4. It should be noted that these guidelines are intended for the environmental impact assessment of long-

term impacts of road traffic associated with major new developments such as industrial estates and

supermarkets. In terms of a wind farm development, this would be equivalent to the operational phase

rather than the construction phase. The volume of traffic generated during the operational phase of a

wind farm is considered negligible as during normal operation the wind farm would generally be

unattended but with regular site visits to carry out routine inspections and preventative maintenance.

However, in the absence of other guidance, the EART guidelines are also used to assess the temporary

transport flow during construction.

Previous Wind Farm Assessments

14.1.5. There are two consented wind farms that are in close proximity to Alwen Forest that are considered

relevant, namely:

Clocaenog Forest Wind Farm (currently due to start construction);

Brenig Wind Farm (currently nearing construction completion).

14.1.6. As part of this scoping exercise Natural Power has reviewed the Environmental Statements and other

relevant documentation for both these wind farms.

Clocaenog Forest Wind Farm

14.1.7. Clocaenog Forest Wind Farm is located to the east of Llyn Brenig Reservoir which is to the north east of

the proposed Alwen Forest Wind Farm. Clocaenog Forest Wind Farm is accessed off of the B4501 spur

road. It is a 27 turbine site with a 92.5 m hub height and 51.2 m blade length.

14.1.8. The highway network providing access to the Clocaenog Forest site includes the A5, A543, A544, A548

and A55. The Clocaenog Forest site will be accessed from the A543 via the B4501 and then via

unclassified roads leading through to Clocaenog forest.

14.1.9. The B4501 is a local authority maintained road that runs north-south from Cerrigydrudion in the south to

the A543 to the north. There is an additional spur off of the main north-south running B4501 located to

the north of Llyn Brenig. This additional spur off of the B4501 runs east-west to Denbigh is also named

as the B4501. The B4501 spur is single carriageway, with the exception of a circa 4 km section that is

single track from its junction with the A543 running west towards the main B4501.

14.1.10. The traffic assessment for Clocaenog Forest Wind Farm assumed that there would be no stone sourced

from within the site and that all stone would need to be imported to the site, increasing the derived

number of HGV’s used in the traffic impact assessment. Subsequently, during the construction phase it

is understood the majority of stone has been sourced from onsite borrow pits.

14.1.11. For Clocaenog Forest Wind Farm the adopted Abnormal Indivisible Load (AILs) route adopts the Mid-

Wales Strategic Traffic Management Plan (MWSTMP) route from the port to the A5. The adopted AIL

route is as follows:

Liverpool docks onto the M53;

M53 and A55 to the south of Chester as far as its junction with A483;

A483 past Wrexham as far as its junction with the A5 at Halton Roundabout;

West along the A5 to the junction with A543 east of Pentrefoelas;

A543 to the junction of B4501 at Llyn Bran;


B4501, through Brenig Wind Farm to Clocaenog site.

14.1.12. As part of the Clocaenog Forest ES a dry run of the route was initially conducted by Collett Transport in

2012 to identify potential modification works required on the route. Subsequently, as part of the

construction phase Traffic Management Plan, another dry run took place in April 2017 to identify route

modification works required. The identified modification works are currently being installed that will

enable turbine component delivery for both Brenig Wind Farm and Clocaenog Forest Wind Farm.

14.1.13. The Clocaenog Forest Wind Farm Traffic and Transport section of the ES generally concluded that

percentage increases to traffic flows on the A543 (north and south of the B4501), A544 and B4501 are

all less than 30%. The maximum increase is 7.2% on the A543 north of the B4501.

14.1.14. The impacts identified and resultant mitigation measures adopted are as indicated in the table below.

Table 14.1: Clocaenog Forest Wind Farm Impacts and Mitigation

Impact Mitigation Notes

Accidents and Road

Safety

Temporary Highway Works, AIL

Escort Vehicles, Traffic

Management Plan

The single-track section of the B4501 was

highlighted as having an increased risk of traffic

accidents.

Driver Delay AIL Escort Vehicles, Traffic

Management Plan, Passing

Places

The implementation of temporary passing places

was identified along the single-track section of the

B4501

Source: Clocaenog Forest Wind Farm ES, Chapter 12: Traffic and Transport, RWE

14.1.15. With the implementation of the above mitigation measures the resultant residual impacts from the

Clocaenog Forest Wind Farm development were assessed as slight in a scale of Major, Moderate, Slight

and Insignificant, therefore not significant in EIA terms.

Brenig Wind Farm

14.1.16. Brenig Wind Farm is north of Clocaenog Forest Wind Farm, located to the north east of Llyn Brenig

Reservoir, also to the north east of the proposed Alwen Forest Wind Farm. Brenig Wind Farm is

accessed off of the B4501 spur road. It is a 16 turbine site with a 58.9 m hub height and 41 m blade

length.

14.1.17. The highway network providing access to the site includes:

The A5 from the A483 to Pentrefoelas;

The A543 from Pentrefoelas to Denbigh;

The B4501 from the A543 to the site.

14.1.18. As discussed above, the B4501 includes a spur to the north of Llyn Brenig that runs east-west to

Denbigh and is also named as the B4501. The access to Brenig Wind Farm site is off the section of the

B4501 spur that is single carriageway (not single track).

14.1.19. The traffic assessment for Brenig Wind Farm assumed that the majority of stone would be sourced from

on-site borrow pits. However, an allowance was included for importing stone associated with the final

surfacing layers.

14.1.20. For Brenig Wind Farm the adopted AILs route is the same as for Clocaenog Forest Wind Farm as

follows:

Liverpool docks on the M53;

M53 and A55 to the south of Chester as far as its junction with A483;

A483 past Wrexham as far as its junction with the A5 at Halton Roundabout;


West along the A5 to the junction with A543 east of Pentrefoelas;

A543 to the junction of B4501 at Llyn Bran;

B4501 to the site entrance.

14.1.21. The impacts identified and resultant mitigation measures adopted are as indicated in the table below.

Table 14.2: Brenig Wind Farm Impacts and Mitigation

Impact Mitigation

Traffic Effect at

Llangollen

Consultation with the relevant Roads Authority, and inclusion in a Traffic Management

Plan. Escorting and appropriate traffic management for AILs. Informing local residents

when such movements are occurring. Road condition survey prior to and after

construction.

Traffic Effect at

Corwen

As for Llangollen. A Route Access Study may also be required to check if any works are

needed in Corwen to allow blade vehicle access.

Traffic Effect at

Pentrefoelas

As for Llangollen.

Traffic Effect at A5

Rural Section

As for Llangollen. The TMP should include reference to signage on the approaches to

Pentrefoelas for the increased traffic at the A543 junction.

Traffic Effect at

A543

As for Llangollen. TMP to include signage for junctions at A5 and B4501.

Traffic Effect at

B4501

As for Llangollen. TMP to include signage for junctions at B4501 and site entrance.

Source: Brenig Wind Farm Tip Height Extension ES, Chapter 11: Traffic and Transport, Natural Power

14.1.22. With the implementation of the above mitigation measures the resultant residual impacts from the Brenig

Wind Farm development were assessed as negligible in a scale of Major, Moderate, Minor and

Negligible and therefore not-significant in EIA terms.

Alwen Forest Wind Farm Traffic and Transport Assessment

14.1.23. The proposed access to Alwen Forest Wind Farm will be off the main B4501 running north-south from

Cerrigydrudion in the south to the A543 to the north, thus avoiding the north-east running B4501 spur

road. As such the Alwen Forest Wind Farm will utilise essentially the same traffic routes as both the

Clocaenog Forest Wind Farm and Brenig Wind Farm.

14.1.24. With reference to Figure 14.1 below, the proposed AIL delivery route for the Alwen Forest Wind Farm

turbines is the same as Clocaenog Forest Wind Farm and Brenig Wind Farm, except in avoiding the

B4501 spur road.


Source: SLR, Alwen Forest, Figure 2

Figure 14.1: Alwen Forest Wind Farm Proposed AIL Delivery Route

14.1.25.

14.1.26. Access to the northern section of the site is currently proposed entering from the B4501 onto an existing

forestry tack in the northern section of the site, along with another entry point for the substation further

south along this road, as shown on Figure 2.2. Access to the southern section of the site is also via the

B4501 onto an existing forestry track. Other options for entering the northern section of the site are

currently being investigated, close to the location of Turbine 4, and will be further discussed in the ES.

Traffic and Transport Conclusions

14.1.27. For the following reasons it is suggested that there will be no significant impacts associated with the

traffic and transport for Alwen Forest and therefore a full EIA is not proposed to accompany the

application:

Both Clocaenog Forest Wind Farm and Brenig Wind Farm TIA’s did not have significant impacts;

Both Clocaenog Forest Wind Farm and Brenig Wind Farm are larger developments (27 turbines and

16 turbines respectively) than Alwen Forest Wind Farm (9 turbines) and would have higher traffic

flows than Alwen Forest Wind Farm will;

The proposed Alwen Forest Wind Farm development will aim to source the bulk of the stone

material from borrow pits located within the site boundary;

B4501 Spur used for Brenig and Clocaenog.

Not required for Alwen Forest Wind Farm.

Alwen Forest Development Area

Proposed AIL Delivery Route

Indicative Access Points


The proposed turbine component dimensions for Alwen Forest are similar in size to Clocaenog

Forest Wind Farm, although with a greater number of tower sections. The proposed AIL delivery

route for Alwen Forest Wind Farm follows the route for Clocaenog Forest Wind Farm. Any route

modifications will have been undertaken prior to Alwen Forest Wind Farm construction. The

applicant for both Clocaenog Forest Wind Farm and Alwen Forest Wind Farm is the same so any

route modifications implemented for Clocaenog Forest Wind Farm can be utilised for Alwen Forest

Wind Farm.

14.1.28. In recognition of the mitigation measures incorporated for Clocaenog Forest Wind Farm and Brenig

Wind Farm the following requirements will be included within the Alwen Forest Wind Farm ES:

A draft Traffic Management Plan (TMP), incorporating the measures adopted for both Clocaenog

Forest Wind Farm and Brenig Wind Farm. As the applicant for Alwen Forest Wind Farm and

Clocaenog Wind Farm is the same, any issues or opportunities from the construction phase of

Clocaenog Forest Wind Farm can be incorporated into the TMP for Alwen Forest Wind Farm.

A requirement to undertake Route Access Study as part of the discharge of any planning conditions

to verify that the AIL route is still sufficient at that time and no additional developments causing

obstruction or temporary measures have been reinstated that would preclude delivery of AIL

vehicles.

A requirement that all AILs be escorted and appropriate traffic management be put in place.

Question 26: Do consultees have any comments in relation to scoping out a full EIA on traffic and transport relating to the proposed Alwen Forest development considering the likely non-significant effects that will occur?

15. Noise

15.1.1. This section of the scoping report summarises the proposed scope for the noise assessment for Alwen

Forest Wind Farm.

15.1.2. Wind farms are often situated in rural environments where there are few other sources of noise. A

normal conversation can be held at the base of a turbine. At residential distances wind turbine sound

can be audible and noise limits are recommended to protect amenity and prevent sleep disturbance.

15.1.3. Operational noise from wind turbines includes aerodynamic noise from the movement of the blades and

mechanical noise from the turbine components, such as the generator and the gearbox. Turbine

manufacturers have been able to control most of the mechanical sources. Wind turbine aerodynamic

noise is restricted by control systems which regulate the pitch and rotational speed of the blades.

15.1.4. The sound from wind turbines rises quickly from the cut-in wind speeds and then remains at the same

level from close to the rated power to the cut out speed. The background noise, such as that from wind

blowing through trees and vegetation, is low at low wind speeds and increases steadily with wind speed.

Background noise at high wind speeds can mask the sound from wind turbines. Appropriate noise limits

can be derived using ETSU-R-97 and the Institute of Acoustics: A Good Practice Guide to the

Application of ETSU-R-97 for the Assessment and Rating of Wind Turbine Noise. These limits are based

on a fixed value and a set margin above the background noise level for day-time and night-time periods.

15.1.5. There will be a short-term noise from the construction of the wind turbines and associated infrastructure

and from traffic movements associated with the delivery of construction materials and turbine

components. However, construction works will generally be carried out during daytime hours only for a

short period.


Operational Noise

TAN 8 2005

15.1.6. Technical Advice Note (TAN) 827

provides Welsh Government information and advice on technologies

for renewable energy. The proposed development lies within TAN 8 Strategic Search Area (SSA) A and

therefore is in an area deemed suitable for large-scale wind turbine development. Noise from wind

turbines is specifically covered in Paragraphs 2.14 to 2.18 of the Note. Selected guidance from TAN 8 is

given below:

15.1.7. “Wind-generated background noise increases with wind speed, and at a faster rate than the turbine

noise increases. The noise of the wind farm is therefore more likely to be noticeable at low wind speeds.

Varying the speed of the turbines in such conditions can, if necessary, reduce the sound output from

modern turbines.”

15.1.8. “The report, ‘The Assessment and Rating of Noise from Wind Farms’ (ETSU-R-97), describes a

framework for the measurement of wind farm noise and gives indicative noise levels, calculated to offer

a reasonable degree of protection to wind farm neighbours without placing unreasonable restrictions on

wind farm development or adding unduly to the costs and administrative burdens on wind farm

developers or planning authorities. The report presents the findings of a cross-interest Noise Working

Group and makes a series of recommendations that can be regarded as relevant guidance on good

practice.”

15.1.9. Accordingly, ETSU-R-97 will be used in this assessment to determine appropriate noise limits.

15.1.10. In terms of layouts and separating distances, TAN 8 advises:

“500m is currently considered a typical separation distance between a wind turbine and residential

property to avoid unacceptable noise impacts, however when applied in a rigid manner it can lead to

conservative results and so some flexibility is again advised”.

15.1.11. The assessment methodology for operational noise is described in ETSU-R-97 ‘The Assessment and

Rating of Noise from Windfarms’28

. The basic aim of ETSU-R-97 is to provide:

“Indicative noise levels thought to offer a reasonable degree of protection to wind farm neighbours,

without placing unreasonable restrictions on wind farm development or adding unduly to the costs and

administrative burdens on wind farm developers or local authorities”.

15.1.12. The specific methodology for applying ETSU-R-97 to a proposed new development will be detailed in full

in the ES but, in summary, the guidance will be used to derive fixed noise limits or limits relating to the

existing levels of background noise.

Institute of Acoustics Good Practice Guide

15.1.13. In May 2013, the Institute of Acoustics (IoA) published the ‘Good Practice Guide to the Application of

ETSU-R-97 for the Assessment and Rating of Wind Turbine Noise'29

. The document was prepared with

the purpose of agreeing current good practice in the application of the ETSU-R-97 methodology to wind

turbine schemes. The document was prepared by a working group and peer reviewed.

27 Welsh Government (2005) TAN 8 Renewable Energy. Available from:

https://gov.wales/topics/planning/policy/tans/tan8/?lang=en [Accessed 05/07/2018]

28https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/49869/ET

SU_Full_copy__Searchable_.pdf [Accessed 05/07/2018]

29 http://ioa.org.uk/publications/wind-turbine-noise [Accessed 05/07/2018]

https://gov.wales/topics/planning/policy/tans/tan8/?lang=en

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/49869/ETSU_Full_copy__Searchable_.pdf

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/49869/ETSU_Full_copy__Searchable_.pdf

http://ioa.org.uk/publications/wind-turbine-noise


15.1.14. The Welsh Government has formally endorsed the IoA Good Practice Guide (GPG) and the planning

advice recommends that it be used for wind turbine noise assessments. Since May 2013, a number of

supplementary guidance notes have also been published providing further detail. The IoA GPG and the

supplementary guidance notes should be regarded as a refinement of the ETSU-R-97 guidance to

ensure consistency and the noise assessment will follow the guidelines stated therein.

15.1.15. The GPG provides general advice on noise monitoring and data processing for noise surveys. It also

clarifies a number of issues including the following:

The background noise survey should be of sufficient duration that no fewer than 200 valid data

points are obtained for each of the amenity hours and night-time periods with no fewer than five

valid points in any 1 m/s wind speed bin.

The background noise measurements (and thereby noise limits) should preferably be corrected for

wind shear by correlating the background noise measurements with the standardised wind speed at

10 m height. The standardised wind speed is defined as the wind speed at 10 m height which is

derived from the hub height wind speed using a logarithmic profile, with a roughness length of 0.05

m.

That ISO 9613-2 is to be used for wind turbine noise predictions, with defined parameters that reflect

noise propagation from wind turbines:

Consideration of cumulative noise issues including:

– How noise impacts from existing and consented wind farm schemes must be assessed.

– The use of directivity corrections for specific situations so that the effect of wind direction on

noise propagation can be accounted for. This is important in respect of cumulative noise level

as there are some receptor locations which cannot be downwind of all turbines at the same time.

Methodology

15.1.16. To carry out a noise assessment in accordance with ETSU-R-97 and the IoA Good Practice Guide, the

following steps are required:

Specify the number and locations of the wind turbines;

Identify the locations of the nearest, or most noise sensitive, receptors;

Determine the background noise levels from measurements as a function of site wind speed at the

nearest properties, or at least at a representative sample of the nearest properties; It is possible that

background noise data from previous measurement exercises will be used;

Determine the quiet day time and night-time noise limits from the background noise levels identified

at the nearest properties in consultation with the local authority and following ETSU-R-97 guidance;

Calculate the noise levels owing to the operation of the wind turbines as a function of site wind

speed at the nearest properties;

Compare the calculated noise immission levels with the derived ETSU-R-97 noise limits and assess

in the light of relevant planning requirements;

Identify potential mitigation measures including changes to layout, turbine type and the use of low

noise modes as required;

Identify any cumulative noise issues associated with other existing, consented and schemes in the

planning system and if necessary reconsider mitigation.

Cumulative Assessment

15.1.17. ETSU-R-97 states that the noise limits that it recommends apply to the cumulative effect of noise from

all wind turbines that may affect a location. Therefore, any wind energy developments, either

operational, consented or in planning, which may require consideration in the assessment process will


be identified. At present the following operational, consented or proposed schemes have been

identified:

Tir Mostyn/Foel Goch (Operational)

Brenig (Under Construction)

Pant y Maen (Consented)

Clocaenog Forest (Under Construction)

Wern Uchaf (Single Turbine – Operational)

Hafodty Ddu (Single Turbine – Under Construction)

15.1.18. Information on these schemes will be taken from various sources including any submitted environmental

reports and the consented noise limits. Additional baseline noise data may also be available.

Low Frequency Noise, Infrasound & Vibration

15.1.19. A Government-funded study published in 2006, by Hayes McKenzie investigated low frequency noise

from wind turbines30

. This study concluded that there is no evidence of health effects arising from

infrasound or low frequency noise generated by wind turbines. Further international studies include a

large study from Health Canada31

that concluded that there were no health effects from low frequency

noise or infrasound.

15.1.20. Vibration from wind turbines is low, nevertheless it has been measured in the past, but only by extremely

sensitive equipment, for example that at the Eskdalemuir monitoring station for detecting nuclear tests in

remote parts of the world, to enforce the nuclear test ban treaty. Measured vibration levels are far below

the thresholds for human perception even on the wind farm sites.

15.1.21. These issues were also considered in an article in Acoustics Bulletin32

which concludes:

“...there is no robust evidence that low frequency noise (including ‘infrasound’) or ground-borne vibration

from wind farms, generally has adverse effects on neighbours”.

15.1.22. It is therefore not considered necessary to carry out specific assessments of low frequency noise,

infrasound or perceptible vibration. However, further supporting information on these subjects including

summaries of more recent international studies will be provided in the ES.

Amplitude Modulation

15.1.23. Amplitude Modulation is defined as periodic fluctuations in the level of audible noise from a wind turbine

(or wind turbines), the frequency of the fluctuations being related to the blade passing frequency of the

turbine rotor(s). For a three-bladed turbine rotating at 20 revolutions per minute (rpm), this equates to a

fluctuation in noise once per second. ETSU-R-97 noted that the levels of AM from a turbine are of the

order 2-3 dB(A) for typical wind turbine configurations. The Hayes McKenzie low frequency noise report

from 2006 also reported AM and described it as typically a low frequency effect.

15.1.24. The wind industry trade body, Renewable UK, in December 2013 published research into Amplitude

Modulation33

. This included theoretical research on mechanisms causing the problem and subjective

30 See The Measurement of Low Frequency Noise at Three UK Wind Farms. Available from:

http://webarchive.nationalarchives.gov.uk/+/http://www.berr.gov.uk/whatwedo/energy/sources/renewables/expl

ained/wind/onshore-offshore/page31267.html [Accessed 04/07/2018]

31 https://www.canada.ca/en/health-canada/services/environmental-workplace-health/noise/wind-turbine-

noise/wind-turbine-noise-health-study-summary-results.html [Accessed 04/07/2018]

32 Bowdler et al Prediction and assessment of wind turbine noise – agreement about relevant factors for noise

assessment from wind energy projects. Acoustics Bulletin Vol 34 No. 2 March / April 2009

33 Amplitude Modulation Research to Improve Understanding as to its Cause and Effect. Available from:

https://www.renewableuk.com/general/custom.asp?page=IndustryStatementOAM [Accessed 04/07/2018]

http://webarchive.nationalarchives.gov.uk/+/http:/www.berr.gov.uk/whatwedo/energy/sources/renewables/explained/wind/onshore-offshore/page31267.html

http://webarchive.nationalarchives.gov.uk/+/http:/www.berr.gov.uk/whatwedo/energy/sources/renewables/explained/wind/onshore-offshore/page31267.html

https://www.canada.ca/en/health-canada/services/environmental-workplace-health/noise/wind-turbine-noise/wind-turbine-noise-health-study-summary-results.html

https://www.canada.ca/en/health-canada/services/environmental-workplace-health/noise/wind-turbine-noise/wind-turbine-noise-health-study-summary-results.html

https://www.renewableuk.com/general/custom.asp?page=IndustryStatementOAM


tests to determine the relationship between the subjective effect and the objective rating method. More

recently, the Institute of Acoustics has published an agreed numerical rating method34

and further

Government-commissioned reports35

have considered how the issue might be addressed in respect of

planning.

15.1.25. At present it is not possible to assess the likelihood of AM occurring at the planning stage. The ES noise

chapter will summarise the current situation in terms of AM analysis and possible ratings.

Construction Noise

15.1.26. The following legislation and standards are of particular relevance to construction noise:

The Control of Pollution Act 1974 (CoPA 1974);

BS 5228: 2009 Code of Practice for Noise and Vibration Control on Construction and Open Sites.

15.1.27. CoPA 1974 provides local authorities in England and Wales with powers to control noise and vibration

from construction sites. Section 60 of the Act enables a Local Authority to serve a notice to a contractor

of its requirements for the control of site noise. Section 61 of the Act allows for those carrying out

construction work to apply to the Local Authority in advance for consent to carry out the works.

15.1.28. Construction noise can be assessed using British Standard BS 5228 which provides a calculation

method and general guidance on controlling noise and vibration from construction sites. This standard:

Refers to the need for the protection against noise and vibration of persons living and working in the

vicinity of and those working on construction sites;

Recommends procedures for noise and vibration control in respect of construction operations; and

Stresses the importance of community relations, stating that early establishment and maintenance

of these relations throughout the site operations will go some way towards allaying people’s fears.

15.1.29. There are no noise limits within the main text of BS 5228 and in fact, the preferred approach is to use

best practicable means to reduce noise rather than setting limits. This means that everything practicable

should be done to reduce noise. This strategy will be adopted here.

15.1.30. However, Annex E of the BS 5228-1 gives "example criteria for the assessment of the significance of

noise effects" e.g. for use in Environmental Statements. For quiet areas, where the existing ambient

noise levels are low, a significant noise effect is deemed to occur if the construction noise (plus the

ambient noise) exceeds the following threshold values:

65 dB LAeq Daytime (07.00-19.00) and Saturdays (07.00-13.00)

55 dB LAeq Evenings and Weekends (19.00-23.00 Weekdays, 13.00-23.00 Saturdays and 07.00-

23.00 Sundays

45 dB LAeq Night-time (23.00-07.00)

15.1.31. These values will be used in a preliminary assessment to assess the significance of any construction

works.

15.1.32. Noise can also occur during construction from traffic on local roads include the transportation of

construction materials and turbine components. Where traffic data is available the increase in noise due

to construction traffic can be calculated according the Government guidance “The calculation of road

traffic noise” (CRTN).

34 Institute of Acoustics (IOA) Amplitude Modulation Working Group, Final Report, A Method for Rating

Amplitude Modulation in Wind Turbine Noise. Available from: http://ioa.org.uk/publications/wind-turbine-noise

[Accessed 04/07/2018]

35 https://www.gov.uk/government/publications/review-of-the-evidence-on-the-response-to-amplitude-

modulation-from-wind-turbines [Accessed 04/07/2018]

http://ioa.org.uk/publications/wind-turbine-noise

https://www.gov.uk/government/publications/review-of-the-evidence-on-the-response-to-amplitude-modulation-from-wind-turbines

https://www.gov.uk/government/publications/review-of-the-evidence-on-the-response-to-amplitude-modulation-from-wind-turbines


15.1.33. The acceptability of construction noise is likely to be affected by the location of the site relative to the

noise sensitive premises; existing ambient noise levels; the duration and working hours of site

operations; the characteristics of the noise produced and the attitude of local residents to the site

operator. Given that construction noise is generally not substantial and that it is a short-term effect,

typically occurring in the daytime, it is not always necessary to consider construction noise within the

scope of an Environmental Assessment and it is proposed that a construction noise assessment is

excluded from the ES.

Impact Assessment

15.1.34. Table 15.1 summarises the topics to be scoped in and scoped out of the noise assessment.

Table 15.1: Noise Impact AssessmnentTopics

Assessment Scoped in or out?

Operational Noise Scope in

Construction Noise Scope out

Low frequency noise, infrasound and vibration Scope out

Source: Ion Acoustics

Question 27: Are the consultees happy with the suggested approach for the noise assessment?

Question 28: Do the Council agree with the topics propose to be scoped out of the EIA?

16. Forestry

Introduction

16.1.1. This section sets out the approach which would be used to integrate the proposed Alwen Forest Wind

Farm into the existing woodland structure. A wind farm felling plan would be prepared setting out the

forestry felling and management requirements, including replanting, associated with the construction and

operation of the proposed development.

16.1.2. The site is located in an area of extensive commercial forestry, on land owned by Dŵr Cymru and the

forest is managed by Natural Resources Wales (NRW) on behalf of the Welsh Ministers. The forest

consists primarily of commercial conifers and all growth stages are present, from recently felled or

replanted areas, to stands of intermediate age and mature trees, although coupes of intermediate age

predominate.

16.1.3. In the UK there is a strong presumption against permanent deforestation unless it addresses other

environmental concerns. The integration of the proposed development into the Forest Design Plan will

be a key part of the development process.

Consultation

16.1.4. The main forestry consultee is NRW. They would be consulted throughout the development of the

proposals to ensure that the proposed changes to the forestry are appropriate and address the

requirements of any policy and guidance.



16.1.5. The forestry proposals will be prepared in accordance with the current industry best practice and

guidance including, but not limited to:

Forestry Commission (2011). The UK Forestry Standard: The Government's Approach to

Sustainable Forestry, Forestry Commission, Edinburgh.

Forestry Commission (2011): The UK Forestry Standard Guidelines. Edinburgh.

SEPA (2013): SEPA Guidance Notes WST-G-027 "Management of Forestry Waste".

SEPA (2014): LUPS-GU27 "Use of Trees Cleared to Facilitate Development of Afforested Land.

UKWAS (2012). The UK Woodland Assurance Standard Third Edition, UKWAS, Edinburgh.

Woodlands for Wales – The strategy for Woodlands and Trees. Welsh Government (2009). Welsh

Woodland Strategy

Woodlands for Wales Action Plan. Welsh Government

Question 29: Do consultees have other best practice guidance we should be considering?

Methodology

16.1.6. Commercial forests are sustainably managed and constantly changing through landowner activities,

market forces and natural events such as windblow or pest and diseases. Commercial forestry is

therefore not being regarded as a receptor for a formal impact assessment. Instead it would be a factual

assessment describing the changes to the forest structure resulting from the incorporation of the wind

farm into the forest. This would include the changes to, for example, the woodland composition and

felling programmes. The effects of forest felling and restocking would be assessed in the relevant

chapters of the ES including Ornithology; Landscape and Visual; Hydrology, Geology and Hydrogeology;

Ecology; and Traffic and Transport.

16.1.7. The forestry baseline will describe the crops existing at the time of preparation of the ES. This would

include current species; the planting year; felling and restocking plans; and other relevant woodland

information. It would be prepared from existing forest records; desk based assessments; site visits; and

aerial photographs.

16.1.8. There is potential for changes to the forest structure resulting from the proposed development, with

consequential implications for the wider felling and restocking plans across the forest area. Areas of

woodland will need to be felled for the construction and operation of the proposed development

including access tracks, turbine locations and other infrastructure. A key holing approach is planned for

the proposed wind farm development, albeit it is proposed that felling (and adaptive forest management

post-felling) will seek to strike a balance between maximising the ongoing energy capture capabilities of

the wind farm and minimising the loss of woodland. An assessment will be made on a turbine by turbine

basis considering coupe age and felling timetable and wind firm edges to assess whether a larger area

of felling is potentially required rather than the immediate infrastructure area alone. Some of the areas

felled for construction purposes will be restocked within the life of the wind farm; in other areas the forest

may be managed via adaptive forest management in a way that benefits both commercial forestry or

environmental objectives and wind farm energy capture.

16.1.9. The Welsh Governments’ “Woodlands for Wales” strategy (July 2009) sets out a number of outcomes

sought from existing and new woodlands in Wales. This includes the following statement- ‘there is a

strong presumption against the permanent removal of woodland…’. Whilst the removal of woodland for

wind farm infrastructure (turbines, crane hardstandings and substation) is for the life of the wind farm

only, the Applicant would consult with NRW Energy Delivery Programme team on the mitigation options

in possibly locating and planting equivalent areas of woodland. The resulting changes to the woodland


structure and any requirement for compensation planting to mitigate against any woodland loss would be

considered in the context of the any published guidance and policy with regards to forestry.

16.1.10. The changes to the forests for a particular development are regarded as site specific and it is considered

that there are no cumulative forestry issues to be addressed.

Question 30: Are consultees in agreement with the proposed methodology for forestry?

17. Socio-Economics

Introduction

17.1.1. The demonstration of socio-economic and community impacts has become a more prominent issue for

the onshore wind sector in recent years. We therefore consider it an essential that this ES includes a

socio-economic assessment to determine the benefits for the Welsh economy and benefits for local

communities.

17.1.2. In terms of tourism effects, the review of literature evidence suggests that overall the research tends to

support the premise that wind farm development has not resulted in a serious negative economic impact

on tourism and could even have wider positive impacts. The most relevant and recent research on the

economic impact of wind farms on tourism was published by the Welsh Government in February 201436

.

The research outlines a number of key findings which suggests that there is little evidence to suggest

wind farms have had/or as having, a detrimental impacts on tourism across Wales. Furthermore, a more

recent national tracker survey37

outlined that support for renewable energy has been consistently high

during the tracker at around 75-80%, with 77% expressing support for the use of renewables, whilst

opposition to renewables was very low at 4%, with only 1% strongly opposed. It is intended therefore to

scope out assessment of tourism from the EIA.

Methodology

17.1.3. We propose that the socio-economic assessment would be based upon 3 economic boundaries (local,

regional and national economy) will include the following:

assess the existing economic environment (baseline) using official data on population, industrial

structure, unemployment and economic activity levels, income and earnings;

assess the potential economic effects during the development and construction phase of the project

including direct employment, supplier effects and income effects;

assess the potential economic effects during the operation of the wind farm including direct

employment, supplier effects and income effects;

assess the economic affects arising from infrastructure improvements and potential community

benefits and shared ownership; and

consider and report on mitigation and management measures which could be employed to minimise

any negative impacts and maximise potential positive impacts.

36 Welsh Government (2014) Study into the Potential Economic Impact of Wind Farms and Associated Grid

Infrastructure on the Welsh Tourism Sector, https://gov.wales/docs/desh/publications/140404economic-

impacts-of-wind-farms-on-tourism-en.pdf [Accessed 26/06/2018]

37 Energy and Climate Change Public Attitude Tracker, Wave 22, August 2017:

https://www.gov.uk/government/statistics/energy-and-climate-change-public-attitudes-tracker-wave-22

[Accessed 26/06/2018]

https://gov.wales/docs/desh/publications/140404economic-impacts-of-wind-farms-on-tourism-en.pdf

https://gov.wales/docs/desh/publications/140404economic-impacts-of-wind-farms-on-tourism-en.pdf

https://www.gov.uk/government/statistics/energy-and-climate-change-public-attitudes-tracker-wave-22


Impact Assessment

17.1.4. Table 17.1 summarises the topics to be scoped in and scoped out of the assessment.

Table 17.1: Impact Assessment Topics

Assessment Scope in or out?

Socio-economics Scope in

Tourism Scope out


Question 31: Are consultees in agreement with the proposed methodology for socio-economic and that tourism is scoped out?

18. Health and Public Safety

Shadow Flicker

18.1.1. Standard guidance states that shadow flicker occurs within ten rotor diameters of the turbine, and that

effects only occur within 130 degrees either side of north relative to the turbines. Beyond these limits it

is considered that potential impacts associated with shadow flicker will not be significant.

18.1.2. As there are currently no residential properties identified within the 10 rotor diameters (based on a

candidate turbine of 105 m rotor) of the nearest proposed turbines, we propose to scope out the need for

a shadow flicker assessment from the ES. However, should the proposed rotor diameter increase on

any of the turbines positioned closer to residential properties during the design evolution of the wind

farm, then another assessment will be made to ensure that we are still outside the criteria set above.

18.1.3. In the case that properties lie within ten times rotor diameter of the turbine and within 130 degrees either

side of north relative to the turbine, then further shadow flicker assessment will be undertaken to analyse

the potential impact and assess its significance. This would consist of determining the maximum number

of shadow flicker hours per year at any receptor within the vicinity of the wind farm that theoretically has

the potential to experience some form of shadow flicker effects, using software such as WindFarmer

(which would show ‘worst case scenario’). There is limited guidance on a defined number of hours of

shadow flicker that is considered acceptable and considered insignificant. Predac, which are a European

Union sponsored organisation that promotes best practice in energy use and supply, recommends that

shadow flicker does not exceed 30 hours per year or 30 minutes per day (Predac, 2003)38

. Less than 30

hours per year of theoretical shadow flicker is the most commonly quoted figure within the industry as an

acceptable limit in the UK.

Ice Throw

18.1.4. Blade icing is a rare occurrence that will only happen when the blades of the turbine are stationary and

under near freezing temperatures and relatively high humidity, with either freezing rain or sleet. If these

certain climatic conditions cause icing to occur, once operation recommences, the operational motion of

the turbine blades and the forces of gravity can cause the ice to break off and fall vertically to the

ground.

38 Predac (2003) Spatial Planning of Wind Turbines Report.


18.1.5. The risk of ice throw39

is dependent on the local climate and weather conditions in which the wind

turbines are situated. Increases in temperature, wind speed and solar radiation can cause the ice to

loosen and fall. This makes the area under the turbine the area of the greatest risk. Dependent on the

conditions, there is the potential for the blades to propel the ice up to several hundred meters when they

commence operation. This can cause damage to people, structures and vehicles.

18.1.6. Siting the turbines away from occupied buildings, roads and public areas can mitigate the risk. This is

the case at the proposed Alwen Forest Wind Farm development. There are specific sensors that can

identify the likeliness of the climatic conditions that cause icing, so if ice accumulation is expected or

occurs the turbines can be shut down. This works when icing on the blades results in reduced

performance, unusual loads, and/or vibrations. These are then detected by a control system and trigger

an automatic shutdown of the turbine. Project operators use these detection systems to halt operation

of certain turbines during icing events to prevent ice throws and equipment damage and, in these cases,

the turbine remains off-line until an operator visually inspects and manually restarts the turbine when the

blades are clear of ice.

18.1.7. The overall view is that modern turbines which are fitted with climatic detection systems like the ones

being considered for Alwen Forest Wind Farm, together with good practice site management procedures

including the use of visual warnings signs and restricted access to turbines where ice is present on

blades, will mitigate and manage this potential hazard.

18.1.8. TAN 8 notes that the ‘build up of ice on turbine blades is unlikely to present problems’ and has not been

reported as a significant issue at operational sites in Wales. Ice throw will not be assessed in the ES.

Lightning

18.1.9. The danger to human or animal life from lightning strike via a turbine is rare since lightning is directed

down the turbine to the earth. Maintenance of the turbines would not be undertaken during high

lightning risk weather conditions. Lightning will not be assessed in the ES.

Health & Safety

18.1.10. The assessment of the safety aspects of the construction, operation and decommissioning of the wind

farm will consider the health and safety of construction workers and risks to safety of members of the

general public. Conwy County Borough Council (CBCC) will be consulted with regard to the location of

any hazardous sites within the vicinity of the proposed development.

Impact Assessment

18.1.11. Table 18.1 summarises the topics to be scoped in and scoped out of the health and public safety

assessment.



Shadow Flicker Scope out

Ice Throw Scope out

Lightning Scope out


39 Evaluating risk caused by ice throw from wind turbines (2017) Available from: http://www.lr.org/en/news-

and-insight/articles/evaluating-risk-caused-by-ice-throw-from-wind-turbines.aspx [Accessed 24/01/2018]

http://www.lr.org/en/news-and-insight/articles/evaluating-risk-caused-by-ice-throw-from-wind-turbines.aspx

http://www.lr.org/en/news-and-insight/articles/evaluating-risk-caused-by-ice-throw-from-wind-turbines.aspx


Question 32: Do consultees have any comments regarding scoping out shadow flicker, Ice throw and lightning from the ES?

19. Aviation and Existing Infrastructure

Introduction

19.1.1. This section assesses the potential impact of the proposed Alwen Forest development on aviation and

existing infrastructure and sets out the proposed methods for assessing aviation and existing

infrastructure in the ES.

19.1.2. In terms of aviation, an initial feasibility assessment has been carried out by Coleman Aviation Ltd.

Consideration has been given to the potential impact on civil and military aviation interests and the

relevant aviation stakeholders have been identified. This assessment was undertaken by means of

desktop study methods, including review of the relevant aviation policy and legislation documents, and

consultation with statutory aviation bodies as well as identifying whether potential mitigation measures

may need to be employed.

19.1.3. The assessment on existing infrastructure has been carried out by Natural Power and summarises the

existing public right of way network and any other public trails in the vicinity of the proposed

development. In addition, TV and radio reception, and telecommunications is discussed in this section,

along with any existing water, gas and power infrastructure.

Aviation

Baseline Conditions

19.1.4. The development of wind turbine sites has the potential to cause a variety of negative effects on

aviation. These effects are widely publicised and the primary concern is one of safety. A full

explanation of the impact of wind turbines on aviation is contained in Civil Aviation Publication 764

(Policy and Guidelines on Wind Turbines)40

however, in general terms turbines can affect aviation in the

following ways:

Physical: Turbines can present a physical obstruction at or close to an aerodrome, or to aircraft

flying at low level.

ATC and AD radar systems: Turbines can generate unwanted returns on radar displays and in some

cases, affect the performance of the radar system itself.

Communication, Navigation and Surveillance (CNS) equipment. A wide range of systems, together

with air-ground communications facilities, can potentially be affected by wind turbine developments.

References and Standard Guidance

19.1.5. The following guidance and industry standards on the potential effects of wind turbines on aviation will

be used in undertaking the aviation assessment:

Civil Aviation Publication (CAP) 168 Licensing of Aerodromes.

CAP 493 Manual of Air Traffic Services Part 1.

CAP 738 Safeguarding of Aerodromes.

CAP 764 Policy and Guidelines on Wind Turbines.

40 CAP 764. Available from:

https://publicapps.caa.co.uk/modalapplication.aspx?catid=1&pagetype=65&appid=11&mode=detail&id=5609

[Accessed 04/07/2018]

https://publicapps.caa.co.uk/modalapplication.aspx?catid=1&pagetype=65&appid=11&mode=detail&id=5609


CAP 774 UK Flight Information Services.

CAP 793 Safe Operating Procedures at Unlicensed Aerodromes.

Military Aviation Authority (MAA) Air Traffic Management (3000 series) Regulatory Instructions.

MAA Low Flying Manual.

UK Military Aeronautical Information Publication (AIP).

UK AIPs.

Civil Aviation Authority (CAA) 1:250,000 and 1:500,000 Visual Flight Rules (VFR) Charts.

Joint MoD/CAA Wind Energy and Aviation Interests Interim Guidelines.

Potential Sources of Impact

19.1.6. Desktop studies have identified the civil and military aviation receptors that will potentially be affected by

the proposed Alwen Forest development. These receptors are as follows:

RAF Valley ATC Radar;

MoD Low Flying Operations;

National Air Traffic Services En-Route PLC (NERL) Radar Systems;

Hawarden (Chester) Airport ATC Radar; and

CAA Aviation Lighting.

RAF Valley ATC Radar

19.1.7. The proposed Alwen Forest development’s location is close to the maximum operating range of the ATC

radar at RAF Valley which is located on the island of Anglesey, North Wales. This means that the Alwen

Forest turbines are potentially in radar-line-of sight (RLOS) of the radar at RAF Valley, and if this is the

case, the MoD are likely to lodge an objection due to adverse impact on ATC operations. A pre-

application request was submitted to the MoD on 29 May 2018 in order for the MoD to carry out a RLOS

assessment. At the time of writing, the MoD are yet to respond; however, given the location of the

turbines close to the limit of the Valley radar’s operating range, it is unlikely that the turbines will be

visible to the radar. If this is the case, there will be no impact on the Valley radar and the MoD will not

object. This will be confirmed in the MoD’s response to the pre-application request which is expected by

the end of July 2018.

MoD Low Flying Operations

19.1.8. The proposed wind farm development is situated within Low Flying Area 7 (LFA 7) which is a

strategically important LFA within the UK Low Flying System (LFS). It is possible that the MoD may

have concerns over the layout of the wind farm and this will depend on the cumulative impact of other

sites in the vicinity. By way of consultation, a pre-application request was submitted to the MoD on 29

May 2018 and the MoD are yet to respond. However, the MoD response will not include an assessment

by operational experts and will be based on the wind farm’s location within the UK LFS. It is highly likely

that the MoD will respond stating that there may be concerns but that a detailed operational assessment

will only be carried out once a formal planning application is submitted. However, it is highly unlikely that

the MoD will make a formal objection, although this cannot be confirmed until a formal planning

application is submitted.

NERL Radar Systems

19.1.9. The proposed Alwen Forest development is technically within range of some NERL radar systems (such

as the Clee Hill and St Anne’s radars) however, given the range and intervening terrain between the

turbines and the radars, it is highly unlikely that the turbines will be in RLOS of any NERL radars. This

will be confirmed by means of a formal pre-planning request to NERL to carry out a Technical and

Operational Assessment (TOPA) which will be submitted during the Scoping consultation period.


Hawarden Airport ATC Radar

19.1.10. The proposed Alwen Forest development is technically outside the statutory 30 km consultation zone for

Hawarden Airport which is located on the western outskirts of Chester in Cheshire; however, it is within

the operating range of the Airport’s ATC radar. Given Alwen Forest’s location and range from Hawarden

(43 km), it was unlikely that the turbines would affect the Airport’s ATC operations but, in order to

confirm this, a request was made to the Airport to carry out a preliminary aviation assessment. At the

time of writing, Hawarden Airport had recently responded to this request confirming that the Alwen

Forest turbines would have no impact on the Airport’s operations. As a result, it is possible to scope out

any potential impact on Hawarden Airport operations.

CAA Aviation Lighting

19.1.11. Given that the proposed Alwen Forest turbines are taller than 150 m (proposed at 200 m maximum

turbine tip height), there is a legal requirement for developers to install aviation lighting in accordance

with the UK Air Navigation Order (ANO) 2016. The ANO dictates installation of 2000 candela aviation

lighting which the CAA are expected to confirm in their response to this Scoping Report. This is further

described in section 11: Landscape and Visual of this report and if deemed a requirement, mitigation

options discussed in the ES.

EIA Methodology

19.1.12. Given that there is no published legislation or guidance to define how the significance of impacts on

aviation receptors should be determined, the criteria to be used in the EIA have been devised using

professional judgement and developed in consultation with relevant aviation stakeholders.

19.1.13. In line with other EIA topics, the assessment of effect significance will be derived from combining the

sensitivity (defined as low, moderate or high) of the receptor with the magnitude (defined as negligible,

low, medium or high) of the effect to produce an overall significance rating. However, with respect to

impacts on civil and military aviation, given the safety critical function of aviation receptors, any predicted

effect upon aviation stakeholders which results in restricted activities or has the potential to affect

aviation or navigation abilities is regarded as unacceptable and therefore significant. Consequently, the

threshold for distinguishing whether an effect is not significant is when the magnitude is assessed as

being negligible.

19.1.14. Table 19.1 outlines how the overall significance of an aviation receptor will be assessed in the EIA

Report.

Table 19.1: Aviation Significance Criteria

Sensitivity of

Receptor

Magnitude of Impact

Negligible Low Moderate Major

Negligible Not significant Significant Significant Significant

Low Not significant Significant Significant Significant

Medium Not significant Significant Significant Significant

High Not significant Significant Significant Significant

Aviation Impacts Scoped Out

19.1.15. Following Hawarden Airport’s recent pre-planning response, it is possible to scope out any potential

impact of the proposed Alwen Forest development on Hawarden Airport’s operations. It is hoped that

this will also be the case for the other potential aviation receptors (RAF Valley ATC radar, Low Flying


operations and NERL radar systems) and this will be confirmed following their consultation responses

prior to submission of the EIA Report.

Mitigation

19.1.16. Depending on the pre-planning and scoping responses from the various aviation stakeholders, the

applicant will commence detailed consultation on mitigation options such that any adverse impact on

aviation operations can be alleviated.

Other Existing Infrastructure

19.1.17. The EIA will consider the potential impact on other existing infrastructure including:

Water, gas and power;

Existing paths including Public Rights of Way (PRoW);

Microwave fixed links; and

Telecoms.

19.1.18. No water, gas and power lines have been identified within the site boundary (see Figure 2.1 for the

closest identified lines) therefore further assessment is not proposed in the ES.

19.1.19. The location of all PRoW have been considered during the iterative design process. During construction

the PRoW will be appropriately managed for health and safety reasons. Figure 2.3 shows the bridleway

and public footpaths within the site and its vicinity, along with Long Distance Footpaths and NRW

recreational routes. The majority of the PRoW within the site are footpaths, with only a short section of

bridleway in the extreme north east of the site, in the area known as Cerrig Caws. The Clwydian Way, a

196 km long distance footpath, follows the eastern boundary of the site in places before turning north

and following the bridleway that crosses the site at Cerrig Caws. There are numerous NRW promoted

recreational routes within the site and its vicinity, as well as the Llyn Brenig Visitor Centre which will all

be considered as part of the design of the proposed development to minimise potential conflicts, and

take account of recreational users of the visitor centre and the activities it promotes. Detailed discussion

is required with NRW and Dŵr Cymru to ascertain their views on the proposed infrastructure layout with

regards to PRoW and recreational routes. A proposed Access Management Area (AMA) during

construction will be prepared to indicate the restrictions for users and any proposed mitigation (through

means of alternative routes and enhancement opportunities etc.).

19.1.20. In relation to microwave fixed links, consultation with Ofcom has revealed no links within the specified

search area and that Atkins Ltd and Joint Radio Company should be consulted with. Joint Radio

Company has confirmed that no links are affected by the propose development. No response has been

received to date by Atkins Ltd. Due to the wind farm experience in the area, having worked on Brenig,

Pant y Maen and Clocaenog, and also the responses received to date, no microwave fixed links are

expected to be impacted by the proposed Alwen Forest development and therefore it is proposed that

this is scoped out of the ES.

19.1.21. Terrestrial television reception in the UK is widely available either through the well-established network

of standard broadcast services and/or through digital satellite receivers. No interference is possible to

the reception of analogue television services, as these were switched off during the Digital Television

Switchover that took place throughout the region during 2009. Whereas an analogue signal can be of

reduced quality (i.e. grainy or ghosted) due to interference, provided the receiver can identify the

components of the signal, digital signals can overcome a certain amount of signal degradation and are

effective at eliminating ghosting due to an internal data correction process. Interference signals are

provided by reflections of the carrier signal by wind turbines. To achieve good quality reception, an aerial

must receive a strong carrier signal but weak interference signals.


19.1.22. A baseline survey would be undertaken prior to construction of the wind farm and the Applicant would

seek to agree a planning condition setting out the procedure for a claim for domestic television picture

loss or interference and the remedial action to be taken if needed. Mitigation against impacts to

television reception may include in some case upgrading to a modern professionally installed antenna

system, or the provision of digital satellite television receiving equipment, the operation of which cannot

be impacted in any way by the wind farm.

19.1.23. It is suggested that TV and radio reception will not be significantly impacted and does not need included

in the EIA.

Impact Assessment

19.1.24. Table 19.2 summarises the topics to be scoped in and scoped out of the existing infrastructure

assessment.



Aviation Scope in*

Public Right of Way and recreational routes Scope in

Gas, water and power line Scope out

TV and Microwave fixed links Scope out

*Although certain aspects would be scoped out as described in section above


Question 33: Do consultees have any comments in relation the potential impact on aviation interests and existing infrastructure and the proposal to scope out an assessment of the impact on TV and microwave fixed links, gas, water and power lines?

20. Summary, Residual and Synergistic Effects and Mitigation

20.1.1. This section of the ES will summarise the residual effects regarding all of the proposed work in relation

to the construction, operation and decommissioning of the proposed development. It will identify all

mitigation, including the mitigation by design that will be undertaken to reduce any such effects, should

the development be consented.

20.1.2. We will also give consideration here to any synergistic effects anticipated.

21. ES Accompanying documentation

Non-Technical Summary (NTS)

21.1.1. The NTS details the main components of the proposed development and summarises the main findings

of the environmental studies carried out to build and operate the proposed development. It is designed

to be an easily readable document that will communicate the main elements of the EIA to any interested

party without the need for the reader to have specialist background knowledge. It will also contain maps

that show the extent and geographical location of the development. This document will be bilingual.

Planning, Design & Access Statement (PDAS)

21.1.2. The PDAS seeks to highlight the design principles and concepts behind the proposed development. It

will detail how the applicant has applied these principles to the proposed development in tandem with


input from consultation activities and will review how successful the proposed development has been in

realising the design strategy.

21.1.3. The PDAS will also provide a commentary of the EIA findings and assess the proposed development

accounting for residual effects (both positive and negative) against national policy and legislation, the

Development Plan and other material planning considerations relevant to the proposed development.

Pre-Application Consultation (PAC) Report

21.1.4. Under article 11 of the Development of National Significance (Procedure) (Wales) Order 2016, a DNS

application must be accompanied by a pre-application consultation (PAC) report which provides:

An account of the statutory consultation, publicity, deadlines set, and activities required under

section 61Z of the Town and Country Planning Act 1990, including:

– Copies of all notices and publications used during the consultation;

– Declarations that the relevant notices and publication requirements comply with the Act and

Order;

– The addresses of those given notice of the proposed application;

a summary of all issues raised by any person consulted under section 61Z(3) of the Act and articles

8 and 9(2), including confirmation of whether the issues raised have been addressed and, if so, how:

and

the particulars of all responses received from persons consulted under section 61Z(3) or (4) of the

Act, including copies of responses from specialist consultees; and the account taken of these.

Question 34: Do the consultees have any comments regarding the proposed documentation that will accompany the application?

22. Responding to the Scoping Report

22.1.1. The Scoping Report has identified the baseline resource at the site for different topics, and presented

where any effects to these may be experienced from the development (either indirectly or directly).

22.1.2. The responses provided by consultees will ensure that they too are in agreement, with the baseline and

likely impact assessment so that the ES is focussed. Where features or receptors are deemed to have a

possible significant effect the methodologies to assess the impact have been provided for comment.

Responses on these would help ensure that the detailed methodology, survey and assessment are

carried out with consideration to all statutory consultees and key stakeholders. This approach is in line

with good practice in the planning system and an emphasis being communicated at a national level to

focus the content of the EIA and ES on key elements identified at the scoping stage.


Appendix A: Proposed Turbine co-ordinates

Table 22.1: Proposed Turbine Eastings and Northings

ID Easting Northing

1 294676 355408

2 295844 355388

3 294796 354912

4 296308 354972

5 295616 354708

6 294936 354416

7 293452 353732

8 293896 353356

9 294296 353020

Source: innogy


Appendix B: Consultation Meeting Notes






Documents

Report A4 TMPL NP - GOV.UK€¦ · ForeSite™, vuWind™, ... Summary, Residual and Synergistic Effects and Mitigation.....70 21. ES Accompanying documentation .....70 22. Responding