The Woodland Trust objects to the proposed hydro scheme as it results in direct loss and damage to ancient and SSSI designated woodland.

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1 Snowdonia National Park Authority National Park Office Penrhyndeudraeth Gwynedd LL48 6LF 18 th June 2015 Dear Mr Thomas, Planning application: NP4/26/323 Proposal: Proposed hydro scheme up to 5MW comprising construction of intake weir, tunnel, buried pipeline, buried powerhouse building with outfall, switchgear room and transformer, and including biodiversity and recreational enhancement proposals, and alterations to existing vehicular access off the A470(T) near Fairy Glen Hotel Afon Conwy, Betws y Coed As the UK's leading woodland conservation charity, the Woodland Trust (Coed Cadw) aims to protect native woods, trees and their wildlife for the future. Through the restoration and improvement of woodland biodiversity and increased awareness and understanding of important woodland, these aims can be achieved. We own over 1,250 sites across the UK, covering around 23,000 hectares (57,000 acres) and we have over 500,000 members and supporters. Ancient Woodland (land that has been continually wooded since at least AD1600) is one of the UK s richest habitats, supporting at least 256 species. Ancient woods form a unique link to the primeval wildwood habitat that covered lowland Britain following the last ice age. Ancient woodland sites are irreplaceable the interactions between plants, animals, soils, climate and people are unique and have developed over hundreds of years. These ecosystems can not be re-created and we cannot afford to lose any more. The Woodland Trust objects to the proposed hydro scheme as it results in direct loss and damage to ancient and SSSI designated woodland. Policy The designation of National Park given to Snowdonia was for the special qualities highlighted on the website stating, Snowdonia is a delightfully varied landscape of steep river gorges, waterfalls and green valleys. The proposed development lies inside the National Park and must be taken in the context of the primary National Park purpose to conserve and enhance the natural beauty, wildlife and cultural heritage. The Welsh Assembly has recognised that areas of ancient woodland are declining and becoming increasingly fragmented and emphasises the importance of conserving ancient The Woodland Trust is a charity registered in England and Wales (No ) and in Scotland (No. SC038885). A non-profit making company limited by guarantee. Registered in England No The Woodland Trust logo is a registered trademark.

2 woodland and its value as a biodiversity resource through the publication of Planning Policy Wales (2014). The following paragraphs highlight ancient woodland s importance: Paragraph 5.2.9: Trees, woodlands and hedgerows are of great importance, both as wildlife habitats and in terms of their contribution to landscape character and beauty. They also play a role in tackling climate change by trapping carbon and can provide a sustainable energy source. Local planning authorities should seek to protect trees, groups of trees and areas of woodland where they have natural heritage value or contribute to the character or amenity of a particular locality. Ancient and semi-natural woodlands are irreplaceable habitats of high biodiversity value which should be protected from development that would result in significant damage. Paragraph : Local planning authorities should, as appropriate, make full use of their powers to protect and plant trees to maintain and improve the appearance of the countryside and built up areas. Paragraph : In the case of a site recorded on the inventory of ancient woodland (1) produced by the former Countryside Council for Wales, authorities should consult with the Natural Resources Wales before authorising potentially damaging operations. Paragraph of PPW highlights the national importance of protecting SSSIs, such as Fairy Glen Woods. It states: With regards to SSSIs, which are of national importance, the Wildlife and Countryside Act, as amended by the Countryside and Rights of Way Act 2000, places a duty on all public bodies (including local planning authorities) to take reasonable steps, consistent with the proper exercise of their functions, to further the conservation and enhancement of the features by reason of which a SSSI is of special interest. SSSIs can be damaged by developments within or adjacent to their boundaries, and in some cases, by development some distance away. There is a presumption against development likely to damage a SSSI. Natural Resources Wales gives the following description of the role of SSSIs in Wales: Sites of Special Scientific Interest are the most important sites for Wales natural heritage. They are highly protected to safeguard the range, quality and variety of habitats, species and geological features in all parts of Wales. They are the cornerstones of conservation work, protecting the core of our natural heritage. Section 28G of the Wildlife and Countryside Act 1981 places a duty on public authorities (including LPAs), in exercising their functions so far as this is likely to affect the flora, fauna or geological or physiographical features by reason of which a SSSI is of special interest, to take reasonable steps, consistent with the proper exercise of their functions, to further the conservation and enhancement of those features. Paragraph of the UK Biodiversity Action Plan (UKBAP) includes objectives to conserve, and, where practicable, enhance: the quality and range of wildlife habitats and ecosystems; the overall populations and natural ranges of native species; internationally important and threatened species, habitats and ecosystems;

3 species, habitats and natural and managed ecosystems characteristic of local areas; and biodiversity of natural and semi-natural habitats where this has been diminished over recent decades. Section 40 of the Natural Environment and Rural Communities Act 2006 requires all public authorities (including LPAs), in exercising their functions to have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity. Welsh Government TAN 5 Nature Conservation and Planning, paragraph 2.1, states the town and country planning system in Wales should both: ensure that the UK s international and national obligations for site, species and habitat protection are fully met in all planning decisions (PPW ); help to ensure that development does not damage, or restrict access to, or the study of, geological sites and features or impede the evolution of natural processes and systems especially on rivers and the coast (PPW , 2.2.1, and 5.6.3). Snowdonia National Park SPG 6 Nature Conservation and Biodiversity: 4.7 All public bodies in the UK have a statutory duty to further the conservation and enhancement of SSSIs and their special interest features. This duty applies to public bodies when they plan and undertake their own projects and also when authorising the plans and projects of others (e.g. through grant of planning consent). Welsh Government TAN 8 Renewable Energy, paragraph 3.13, states though generally supported, there could be occasions where some hydro schemes are unacceptable because of potential ecological damage. Snowdonia National Park SPG10 Renewable Energy: 2.8. PPW considers that in order to meet the Government s renewable energy target of 4TWH per annum, local planning authorities should support proposals for renewable energy projects provided environmental impacts are avoided or minimised, and the integrity of nationally and internationally designated areas are not compromised Notes that the total installed capacity of hydro power stations in the National Park exceeds local electricity demand by an estimated factor of 3 and results in the area being a net exporter of electricity. Development impacts on woodland Ancient woodland is an irreplaceable habitat and the communities of animals and plants that have developed there over centuries cannot be recreated instantly in new woods. The fundamentals of the proposed hydro scheme are flawed as it falls within a highly sensitive area subjected to a number of locally and nationally important designations.

4 The Woodland Trust is concerned about the following: Direct loss and damage to ancient woodland Prolonged and intense activity within the woodland as a result of the construction phases, with particular concerns regarding noise, light and vibration during these phases; Fragmentation as a result of the separation of adjacent semi-natural habitats, such as other small wooded areas, glades/clearings, individual trees and riparian habitats; Disturbance of soil conditions will occur as a result of the installation of the pipeline; There can be changes to the hydrology, altering ground water and surface water quantities resulting from the development being largely hard-standing. Areas of hard-standing in the woodland and adjacent to watercourses will result in changes to the characteristics and quality of the surface water as a result of pollution/contamination etc; There will inevitably be issues in respect of trees adjoining infrastructure, i.e. the powerhouse and intake structures, which will be threatening to the longer-term retention of such trees; Any effect of development can impact cumulatively on ancient woodland - this is much more damaging than individual effects. The proposal impacts upon a large length of river and the surrounding woodland, namely Fairy Glen; a site designated as a Site of Special Scientific Interest (SSSI) including two ancient woodland categories, Ancient Semi-Natural Woodland (ASNW) and Plantation on Ancient Woodland Sites (PAWS). Further to these classifications, the areas affected by much of the scheme, including the intakes, access tracks and powerhouse are covered by a Tree Preservation Order (TPO). Evidently any such development within this area would cause lasting, significant damage and impact heavily upon the integrity of the entire area. Any development that adversely impacts and results in the destruction of ancient woodland and SSSIs is highly inappropriate and in direct contravention of a number of local and national planning policies. The woodland encompassing the area in which the intake structure and associated works is proposed is described as being in good condition, with large mature trees, good regeneration and fallen and standing wood being present. The presence of large numbers of ancient woodland indicator species, such as oak, ash, hazel, holly and downy birch in the canopy and understory, coupled with the bluebells, dog s mercury and ramsons in the ground layer indicate the woodland is rich in flora synonymous with ancient woodland. Despite this there is little mention given to ancient woodland when referring to these areas of woodland. The Trust finds this to be very concerning and highlights the lack of consideration given to ancient woodland by the applicant, despite stating the woodland will be subject to negative impacts. Throughout the planning application s available documentation the applicant has largely failed to fully consider the irreversible damage and loss to ancient woodland that would occur as a result of this development.

5 Development in ancient woodland can lead to long-term changes in species composition, particularly ground flora and sensitive fauna, i.e. nesting birds, mammals and reptiles. Majorly adverse impacts would occur as a result of the removal of large areas of woodland, much of which contains high quality, valuable trees, to make way for works associated with the scheme; including the construction of the intake, installation of the track route, construction of the powerhouse and associated hard surfacing and tracks, installation of the pipeline and numerous access tracks throughout the development site. According to the Arboricultural Impact Assessment losses of numerous trees will be unavoidable and it is wrongly suggested that new planting could appropriately mitigate for any loss. New planting of trees cannot be considered as mitigation for the loss of irreplaceable ancient woodland, it can only be classed as compensation. Furthermore the planting of new trees would not replicate the ancient woodland habitat likely to be lost to the proposal. Natural regeneration will also not compensate and only likely result in the growth of unwanted invasive species, i.e. rhododendron. Furthermore the area s designation as a SSSI is largely attributed to the well-developed fern and lichen assemblage. Removal of trees and implementation of access tracks through SSSI designated woodland would inevitably impact negatively on the fern and lichen populations. The Trust is in favour of green, renewable energy and in principle isn t against hydroelectric power schemes. However, we believe that any green energy project that results in the destruction of such a precious and irreplaceable habitat as ancient woodland could never truly be considered as green. Impacts on ancient/veteran trees Ancient and veteran trees are a vital and treasured part of our natural and cultural landscape. Ancient and centuries old veteran trees in the UK represent a resource of great international significance. Veteran trees are the ancient trees of the future. It has been estimated that the UK may be home to around 80% of Europe's ancient trees. They harbour a unique array of wildlife and echo the lives of past generations of people in ways that no other part of our natural world is able. A 'veteran tree' is usually in the second or mature stage of its life and has important wildlife and habitat features including; hollowing or associated decay fungi, holes, wounds and large dead branches. It will generally include old trees but also younger, middle aged trees where premature aging characteristics are present. The Trust is concerned that a number of ancient/veteran trees could likely be removed as part of the proposed scheme. The Arboricultural Impact Assessment states that unless the pipeline can be realigned, this will result in the loss of one A grade tree (T10), three B grade trees (T11, T12, T13) and one C grade tree (T14). These trees are identified within the Tree Survey Schedule, which offers up an account of their size as well as a number of general observations. The stem size of oak trees T10, T11 and T13 would indicate that these trees are of a particularly large nature, which coupled with general observations detailing broken limbs, old cavities and deadwood within the canopy suggest that these trees could be identified as being ancient/veteran specimens. The willow tree,

6 T12, contains an unusually large number of stems, with this attributed to the likeliness of a number of trees becoming fused. It is likely that due to this characteristic tree T12 could also be considered to be an ancient/veteran specimen. Nearby there are a number of veteran trees within at least 250m of the proposed components of the scheme. These are identified on the Ancient Tree Inventory under the following: Sessile Oak: Ash: Sessile Oak: Sycamore: Sessile Oak: Oak: Due to the significant concentration of veteran trees in the area, the potential veteran trees likely to be lost are providing some of the closest potential replacement habitat for any rare species associated with decaying wood habitat, aging bark and old root systems. The larger the concentration of old trees in an area and the longer they have been present on site the richer the variety of species you will find among them. For this reason it is essential that no trees displaying ancient/veteran characteristics are lost as part of the development. Any loss of veteran trees would be highly deleterious to the wider environment of veteran trees within close proximity, which may harbour rare and important species. Trees are susceptible to change caused by construction/development activity. As outlined in Trees in relation to design, demolition and construction, BS 5837:2012, the British Standard for ensuring development works in harmony with trees, construction work often exerts pressures on existing trees, as do changes in their immediate environment following the construction of a building. Root systems, stems and canopies, all need allowance for future movement and growth, and should be taken into account in all proposed works on the scheme through the incorporation of the measures outlined in the British Standard. Development impacts on wildlife Fauna diversity is an important part of ancient woodland ecosystems. The presence of large numbers of fauna on site, including numerous bats, birds and otters, emphasises the importance of protecting this area from inappropriate development. Development such as this proposal will likely increase the fragmentation of the ancient woodland by creating or increasing barriers to movement, or impacting on existing movement corridors between ancient woodland fragments, and other nearby ancient woods and semi-natural habitats. Development may also cause disturbance by light, noise, pollution, compacting of soil and construction activity. In addition, the cumulative effect of development is more damaging to ancient woodland than individual effects which should not be considered in isolation.

7 Noise associated with construction arises from a range of sources, including heavy machinery and general construction activity. Noise levels in construction areas will be elevated over a prolonged period of time. They are likely to limit the distributions of animal species that are intolerant of noise and negatively affect their reproductive success. This may be beneficial at some sites if, as a result, deer pressure is reduced but bird diversity has been found to be lower in noisier sites. Surveys undertaken by the applicant indicate the presence of several species of bat on the development site, including soprano pipistrelle, lesser horseshoe, noctule, whiskered, Natterer s and brown long-eared. In the UK, bat populations have declined considerably over the last century, which has led to the protection of all UK species (17 species breed within the UK) at both national and European levels. Seven of the UK bat species are identified as priority species under the UK Post-2010 Biodiversity Framework; these are Bechstein s bat, barbastelle, noctule, soprano pipistrelle, brown long-eared bat and the two horseshoe bat species. At least four of these species is found in the vicinity of Fairy Glen. Bats are under threat from development work that negatively impacts bat roosting, commuting and foraging habitats through disturbance, bat fatalities, roost damage and destruction and habitat loss/severance. Almost all European bat species utilise woodland at some stages in their life cycle, however little research has been undertaken to show how disturbance of this habitat impacts upon bats. The applicant has also stated that various other protected species have been identified as regular users of the site. This includes signs of otter and many rare bird species found to be breeding throughout the site including wood warbler, spotted flycatcher, pied flycatcher (red-listed Birds of Conservation Concern), redstart and tree pipit (amberlisted). The removal and fragmentation of important habitat for the purposes of both temporary and permanent infrastructure would likely harm population numbers of these species within the area. Watercourses and soil profiles may also be affected or polluted by water run off as a result of new hard-standing areas associated with much of the infrastructure, i.e. the intake and powerhouse structures. This in turn will directly affect much of the woodland fauna that relies on the watercourse for both habitat and feeding, while the flora that relies on stable conditions will inevitably be adversely impacted by any changes to the woodland s soil conditions. Conclusion Many aspects of the proposal are likely to affect the highly valuable and important ancient woodland of Fairy Glen, including construction of the intake structure, construction of the powerhouse building and associated works, and installation of the pipeline. Furthermore there will be a significant amount of damage as a result of the implementation of access tracks, both permanent and temporary, for the purposes of construction. The Trust believes that there has been a lack of consideration to address the environmental/ecological issues facing the proposal. Ancient woodland is mentioned very sparsely throughout the application s documentation and been largely overlooked as part

8 of concerns within the Environmental Statement and Arboricultural Impact Assessment. Instead focus within these documents has been largely based on potential tree loss, rather than being focused on the entire habitat, i.e. ancient woodland soils, ground flora, etc. Ancient woodland is irreplaceable and cannot be recreated. The Trust believes that the planning application in its current form has fallen short of detailing the clear extent of loss to ancient woodland or ancient/veteran trees. The Woodland Trust strongly objects to the planning application. We believe this site to be of importance on both a county and national level. The direct loss and damage to ancient woodland and veteran trees in a SSSI designated area is highly inappropriate and entirely unacceptable. If you are concerned about any of the comments raised by the Woodland Trust then please do not hesitate to get in contact with us. Thank you for the opportunity to comment on this planning application. We hope you find these comments of use. Yours sincerely, Jack Taylor Campaigner Ancient Woodland