HEARING STATEMENT FOR HEARING SESSION 2 - Penderi Solar Farm, Land at Blaenhiraeth Farm, Llangennech, Llanelli, SA14 8PX
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Development of national significance in the renewable energy sector HEARING STATEMENT FOR HEARING SESSION 2 Penderi Solar Farm, Land at Blaenhiraeth Farm, Llangennech, Llanelli, SA14 8PX FEBRUARY 2021 | BRS.4254
Hearing Statement – Session 2
1 Introduction
This statement presents the applicant's position on the matters to be discussed at Hearing Session 2.
2 Impacts on Hydrology and Water Quality with Particular Reference to Potential Impacts
on Receiving Watercourses
Local impacts on watercourses was raised by NRW and the hydrological link to the Carmarthen Bay
and Estuaries SAC, Bury Inlet SPA, Burry Inlet Ramsar and Loughor Estuary and the Burry Inlet and
Loughor Estuary Site of Special Scientific Interest. The impacts identified relate to the degradation of
watercourses through silt and sediment run-off during construction as well as accidental pollution
events relating to machinery used during construction. There is evidence from other solar farms which
are constructed in wet conditions that the ground can become churned up during construction – this
is particularly applicable to Penderi where there are areas of damp grassland present.
Suitable mitigation has now been proposed which is set out within a draft Construction Environmental
Management Plan i which NRW have confirmed should be made a condition of the planning
permission. This includes:
• Timing of main construction period outside winter
• Pollution prevention measures
• Management of sediment and surface waters (through preventative measures including the use
of silt fencing or hay bales)
• Application of buffer zones adjacent to watercourses
• Regular monitoring (including daily site checks, visit by ecologist every 2 weeks, water sampling)
During operation of the array, the cessation of agricultural activities such as ploughing and spreading
of fertilizers/slurry is likely to have a beneficial impact on the local watercourses, although there are
no current studies looking at water quality impacts of solar farms. The Solar Park Impacts on Ecosystem
Services (SPIES) tool was used to assess the proposals for future management of the site and it shows
enhancements in terms of soil erosion regulation, water cycle support and water quality regulation ii.
This shows that there is evidence that application of these management activities can have a
beneficial impact on local watercourses.
3 IMPACT ON GRASSLAND
There is evidence from other solar farms that were constructed under wet conditions that the ground
can become churned up; this would lead to damage of the grassland and also of the soil, making it
harder for the grassland to re-establish. This will be managed through the CEMP with measures such
as timing of main construction period outside winter, restrictions in terms of working during wet
weather, reinstatement of topsoil etc. In addition, any bare areas created during construction will be
re-seeded to ensure that the grass sward is re-established as soon as possible.
1The grassland within the site is likely to be enhanced post construction. The seed mix used will contain
a variety of native flower and grass species. Also included within this seed mix will be plants to attract
specific moths which are of local conservation priority. Post construction, more than half the site will
be subject to conservation grazing (with livestock removed between March and August to allow
plants to flower and set seed). Our study iii has shown that solar farms can offer a more diverse
grassland when compared with similar agricultural land, particularly with wildlife-focussed
management.
4 IMPACTS ON HEDGEROWS/FIELD BOUNDARIES
Some hedgerow removal will be required (~70m to create accesses). 125m of hedgerow may need
to be translocated to create a site access. There also remains a risk of accidental damage of
hedgerows and disturbance/damage during installation of security at the edges of the fields.
The CEMP and Construction Ecological Management Plan (CEcMP) iv sets out measures to protect the
hedgerows and field boundaries during construction and this will be in line with British Standard "Trees
in Relation to Design, Demolition and Construction to Construction - Recommendations" (BS 5837)
(2012), a widely recognised guidance document. With the installation of the security fencing around
the site periphery, sheep-proof fencing and wide buffer zones at other field boundaries and Heras-
type fencing around trees, these boundary habitats can be appropriately protected.
A total of 1,309m of new hedgerow will be created. Hedgerows will be managed post construction to
enhance these features (by allowing them to grow over 3m and retaining dead wood).
5 CUMULATIVE EFFECTS
The assessment of cumulative impacts has focused on other large scale solar facilities given the
similarity in impacts between solar arrays. Other developments can lead to cumulative impacts but
an examination of planning portals identified no other large developments which would result in
modification of similar substantial areas of habitat. Furthermore no major developments have been
identified downstream of the site which might result in cumulative impacts upon water quality or
designated sites downstream.
Tycroes Solar Farm, a proposed 40MW site located over 4km to the north east of Penderi.
Penderi and Tycroes are not situated on the same watercourses; Penderi is adjacent to the Afon
Morlais and Dafen, whereas Tycroes is adjacent to the Afon Gwili, although all watercourses eventually
feed into the designated sites to the south. Consultation with NRW regarding the Tycroes scheme has
resulted in specific details being included within the CEMP to ensure watercourses are protected.
The ecological surveys at Tycroes have not identified any habitats and species which may be
negatively affected by the proposals (no residual effects were identified). A HRA screening was
carried out to assess if any impacts on the Caeau Mynydd Mawr SAC (designated for marsh fritillary)
would occur; likely significant effects were screened out. Otters and dormice are assumed to be
present and protective measures set out to ensure these species are not impacted.
26 MITIGATION
The proposed mitigation measures are detailed within the draft CEMP and the CEcMP. The CEMP
details environmental protection (which covers habitats, soil, water, dust, noise, traffic etc) as well as
a CEcMP, which sets out specific ecological protection measures (for retained habitats and protected
species). Both documents can be secured through planning conditions and the draft CEMP will be
finalised and approved by the LPA prior to the start of construction.
Protection of Watercourses
The CEMP sets out pollution prevention measures (from silt and accidental spills) which are standard
for construction sites and applied widely; these are also in line with relevant Welsh Guidance for
Pollution Prevention v. In addition, as requested by NRW, preventative measures are also set out to
manage sediment and surface waters. This will be in the form of silt fencing or straw/hay bales used
within high risk areas. The installation of silt fencing and other measures is in line the Welsh Pollution
Prevention Guidance.
Effective and extensive monitoring has been incorporated into the CEMP to ensure its consistent and
successful delivery and will ensure that any issues are picked up early and can be immediately
addressed.
Mitigation within the CEcMP
The protection of habitats at the field boundaries is set out within the CEcMP and includes a mixture
of security fencing, stock-proof fencing and Heras type fencing around trees (fencing according to
BS5837).
Mitigation for Birds
An area of land is designated within the red line boundary but outside the footprint of the array to be
managed for ground nesting birds. Through removing grazing and cutting, this allows birds such as
skylark to nest within the taller undisturbed grass. Skylarks have been recorded within this area,
therefore, it is considered highly likely that they will initiate nesting in fields which are managed
appropriately. The land set out for this mitigation and subsequent management of it is set out within
the Landscape and Ecological Management Plan, which, as agreed with NRW, can be secured via
condition. It has been ensured that the red line boundary is extended to cover these areas.
7 EXTENT AND SIGNIFICANCE OF REVERSIBILITY
We are not aware of any solar sites which have yet been decommissioned in the UK, therefore there
is limited evidence to fully explore this issue. It is likely that the site can easily be reverted to agricultural
land due to the limited amount of physical development which will take place, although some
improvement to the grassland will be required to ensure it is optimal for grazing.
In terms of impacts on species which may move into the site as habitats become more ecologically
valuable, this would have to be explored through further survey prior to removal of the panels. Solar
arrays are likely to become important for pollinating insects, birds (such as barn owls) and hares vi,
therefore, impacts upon these species may occur due to decommissioning of the site.
38 HABITATS REGULATIONS ASSESSMENT
NRW have raised concerns with regards to impacts on Carmarthen Bay and Estuaries SAC
(approximately 5.1km downstream), Bury Inlet SPA and Burry Inlet Ramsar (both approximately 10.4km
downstream), which are hydrologically linked to the site. Specific measures to mitigate for impacts
on these sites are set out within the CEMP; recent case law (People over Wind) has meant that in all
cases where mitigation is required to prevent impacts on an internationally designated site, a full HRA
must be carried out.
Information to support the HRA process vii has been provided and it has been concluded that impacts
can be avoided through the mitigation measures as set out within the draft CEMP. It concludes that
no significant effect is anticipated on the designated sites. Consultation with NRW has confirmed that
they are satisfied that the CEMP contains enough information to conduct the HRA.
9 COMPLIANCE WITH NATIONAL AND LOCAL PLANNING POLICY
Planning Policy Wales (Edition 11)
Given that this planning policy has only recently been published, reference to this document will be
covered in a separate submission.
Carmarthenshire Local Development Plan and Supplementary Planning Guidance
Key policies within Carmarthenshire Local Development Plan and Supplementary Planning Guidance:
Nature Conservation and Biodiversity and Wind and Solar Energy are set out below with a description
of how they relate to ecology. A discussion is provided on how this proposed development supports
these policies.
Carmarthenshire Local Development Plan
Policy EQ4 Biodiversity The mitigation hierarchy has been followed, with impacts
avoided where possible. Some (short-term) damage will occur
to the grassland, but this will be minimised and mitigated
through seeding of a diverse mix.
Compensation is required for ground nesting birds which is
secured within the redline.
Policy EQ5 Corridors, Networks and Features of All corridors, networks and features of ecological distinctiveness
Distinctiveness are to be retained and protected. Some damage to the
grassland may occur, however, the management of the
operational site aims to create a more diverse grassland sward.
Policy SP11 Renewable Energy & Energy No cumulative impacts have been identified and
Efficiency environmental impacts are covered within a CEMP, which will
be secured via planning condition.
Policy SP14 Protection and Enhancement of the The scheme has been designed to maximise its enhancement
Local Environment of the local environment, as set out within the LEMP.
Policy RE3 Non-wind Renewable Energy No cumulative effects have been identified.
installations
Supplementary Planning Guidance: Nature Conservation
The process which this application has followed is in line with this planning guidance. In summary:
• Ecology has been considered very early in the process, with ecological considerations leading to
modification of the design
• The mitigation hierarchy has been followed.
• The good practice and general guidelines have been followed.
• Buffers have been incorporated into the design to protect boundary habitats
• A management plan has been prepared
4Supplementary Planning Guidance: Wind and Solar Energy
The ecological considerations within this guidance have been followed, with the ecological potential of the site
being maximised (as set out within the LEMP). The mitigation hierarchy has been followed, with measures put in
place within the CEMP and CEcMP to ensure impacts are avoided as far as possible. All stages of the
development have been considered from construction through to operation and decommissioning.
National Development Framework (Future Wales)
As above, given that this document has been very recently published, reference to it will be covered
in a separate submission.
10 OTHER ISSUES RAISED DURING PUBLIC CONSULTATION
Although not specifically raised as matter to be discussed during the hearing, several consultation
comments have been submitted with concerns regarding particular species.
Birds – loss of habitat
The displacement of breeding/wintering birds from within the site through the construction of the
panels has been raised (particularly in relation to skylark, curlews waterfowl and woodcock). These
species require unbroken sightlines and so the installation of the panels would constitute a cluttered
environment that may deter these species.
Mitigation has been provided for the loss of habitat for those birds which require unbroken sightlines,
such as skylark. A total of 8 breeding pairs of skylark were identified within the site through breeding
bird surveys, mainly in the west of the site. Although it is likely that nesting habitat may be lost (as there
is no evidence that skylarks use areas within the footprint of solar farms for nesting), these birds will
continue to use the site as part of their territory. An area which is large enough to support 10 pairs of
skylarks (outside of the footprint of the array) has been marked for management for ground nesting
birds (as set out within the LEMP). In addition to this, there is growing evidence to show that skylarks
continue to use solar farms for singing and foraging; one study found there was no significant
difference between numbers of skylarks on solar farms and control sitesiv and a recent RSPB study
found that skylarks were in the “top 10” birds found on solar farms viii.
In terms of use of the site by curlew, this species was not recorded on any of the breeding bird surveys
in 2018, nor previously in 2015. It is therefore concluded that this species has not been using the site for
nesting in recent history.
Wintering woodcock have been identified within the site in small numbers (peak count of 5, although
actual numbers may be higher given the cryptic nature of this species). This species was mainly
associated with boundary habitats (woodland and ditches) and so will continue to use these habitats.
Scrapes have been proposed and, in addition, large buffers have been provided between the
woodland habitats and panels.
Birds – Collision with panels
Concerns have also been raised with regards to the potential collision of birds with the panels due to
them being mistaken for bodies of water (particularly by waterfowl and species which drink on the
wind such as swifts, swallows and housemartins.
5There is no evidence to show that birds may mistake solar panels for water. The Natural England
Report ix was cited within a public consultation response. This report concluded that there is no
evidence to suggest that birds would collide with solar panels although some evidence exists of birds
confusing polarised light for water sources, although within very different habitats to those on the
Penderi site. The most comprehensive review of the impacts of solar farms on wildlife has been
prepared by BSG x. They conclude “Very few relevant research papers were found during the data
search for this review that substantiated these contentions. Furthermore, no studies from the UK or
Europe were found”.
Bats
The lack of survey effort relating to bats as well as a concern that bats may collide with the panels has
been raised during the public consultation. The concern relating to collision stems from some research
carried out which showed that in a laboratory setting, bats would collide with smooth vertical plates xi.
This study was carried out in a laboratory setting using a metal plate and therefore is not comparable
to a solar farm setting. In a solar farm, panels are not vertical and the surface is also broken up by
panel frames and debris which settles on the panels. The BSG literature review also concludes that
“Given that solar panels were not used in this study, and most PV solar arrays in the UK are tilted, no
potential impacts to bats can be inferred from these results”.
Specific bat surveys were not carried out at Penderi as no impacts on bats were identified which may
warrant further survey. The grassland and field boundaries are to be retained and enhanced and so
bats will continue to utilise the site. A small amount of impact from the lighting columns required at the
substation is anticipated, however, these will only be utilised during emergency works so extremely
infrequently (an estimate of twice per year).
Further survey is required at Ciddewi Bridge in order to assess impacts on roosting bats caused by the
installation of the cable route, but these will be conducted at a later date once the methodology for
installing the cable has been finalised.
6Key Documents
i Draft Construction Environmental Management Plan – Penderi Solar Park. Pegasus Group. December
2020
ii SPIES Report – Penderi
iii H. Montag, G Parker & T. Clarkson. 2016. The Effects of Solar Farms on Local Biodiversity; A
Comparative Study. Clarkson and Woods and Wychwood Biodiversity
iv Appendix 7.5 of the ES - Construction Ecological Management Plan. Clarkson & Woods. December
2020
v Guidance for Pollution Prevention – Works and Maintenance In or Near Water: GPP 5. February 2018
https://www.netregs.org.uk/media/1418/gpp-5-works-and-maintenance-in-or-near-
water.pdf?utm_source=website&utm_medium=social&utm_campaign=GPP5%2027112017
vi Solar view 2018 & 2019 – Clarkson & Woods
vii Appendix 7.7 of the ES – Information to Support HRA. Clarkson & Woods. December 2020
viii RSPB Project – Birds on Solar Farms https://community.rspb.org.uk/ourwork/b/biodiversity/posts/bird-
use-of-solar-farms-interim-results
ix Natural England - Evidence review of the impact of solar farms on birds, bats and general ecology
2016 (NEER012) http://publications.naturalengland.org.uk/publication/6384664523046912
x Evidence review of the impact of solar farms on birds, bats and general ecology 2016 (NEER012). BSG
Ecology. 2019 https://www.bsg-ecology.com/wp-content/uploads/2019/04/Solar-Panels-and-Wildlife-
Review-2019.pdf
xi Greif S, Zsebok S, Schmieder D & Siemers BM. 2017. Acoustic mirrors as sensory traps for bats. Science,
357: 1045 - 1047
7www.voltalia.com/en COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Group. Crown copyright. All rights reserved, Licence number 100042093
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