The Mid Wales (Powys) Conjoined Public Inquiry into 5 Windfarm Proposals and a 132kV overhead Electric Line Connection

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1 ALL-016 The Mid Wales (Powys) Conjoined Public Inquiry into 5 Windfarm Proposals and a 132kV overhead Electric Line Connection Session Two Hearing Session - Ecology and Wildlife Alliance Comments

2 The Alliance wishes to raise particular concerns regarding matters relating to the proposed Llanbrynmair windfarm application site, in addition to those matters of interest to PCC and NRW. The demonstrably high water quality of the Afon Gam indicates that the whole ecosystem of the upland hydrology that will be majorly affected by the Carnedd Wen and Llanbrynmair proposals is balanced and working effectively. The combination of the construction programme, deforestation and major road works along the entire course of the Afon Gam and most if its tributaries poses a serious threat to the delicately balanced ecosystem (as previously referred to in ALL-SSAB-POE-05). 1. The impact on water quality and riparian species during construction a. Bog and Mire i. Bog and mire forms 43% of the main application site 1, whilst grassland forms 37%. As the site (excluding the access route and the Llanerfyl Talerddig road) is 1,700 Ha a very conservative estimate would be that the area of peat and unimproved, species rich acid grassland comprises some 1,000 Ha. i Much of the blanket bog is National Vegetation Classification (NVC) M19, (Calluna vulgaris Eriophorum vaginatum, Heather Hare s-tail Cottongrass mire) 2 which is of international importance. We are concerned as to whether the species assumed and estimates taken for the parts of the moor not surveyed will have assumed a downgrading of the ecological quality of the area. b. Ponds and pools i. Great crested newt are likely to be present. 3 Although the limited surveys undertaken have not yet found them this does not mean they are not present. 1 From SEI August 2013, Vol I, page 166, Table ES 2008 page 160, para ES 2008 page 156, para

3 i iv. Llyn Gwyddior supports a diverse population of fish and as well as the fishing club based there, anglers catch a variety of species in the rivers and streams. There are good densities of juvenile salmonids in the Afon Gam and its tributaries. 4 The ES and SEI state, This area will therefore be very sensitive to changes in flow and/ or water quality, particularly the generation of excessive suspended solids. This paragraph also acknowledges the importance of the Afon Gam and its tributaries, which supports a significant (salmonid) spawning habitat with a 2005 survey indicating, good to excellent invertebrate numbers in the Afon Gam catchment. v. Otter and salmon are indicators of good water quality; they are present in numbers in these streams and rivers. Both require high quality habitat and a good food supply. Salmonids are highly sensitive to pollution e.g. leaks of hydrocarbons from construction machinery (such as hydraulic oil) 5. It was a notable achievement some 10 years ago when river and stream quality in Wales was restored to such a level that otters have been recorded in all its rivers. vi. The great success stories of Welsh conservation have been the reestablishment of strong populations of otter and red kite. 2. Impact of the windfarm and its construction on bats known to be present and using the site. a. In the 2008 survey the following bat species were present: common pipistrelle, soprano pipistrelle, long brown-eared bat, Natterer s bat, whiskered bat and noctule 6. There does not appear to be corresponding data for b. These species are still present and will undoubtedly be affected negatively by the proposed application, both during construction and throughout the lifetime of the development. Research in other countries has shown that impacts on 4 ES 2008 page 254, para (repeated in 2013 SEI page 311, para ) 5 Carnedd Wen ES Dec 2008 Vol I Chapter 13 page 48 para ES 2008 Vol II Appendix 6.1 2

4 bats can be significant. A study in North-Western Europe showed that the impact was: " highest (5 20 [bats killed per turbine]) at the coast and on forested hills and ridges." and "The species killed almost exclusively (98%) belonged to a group (Nyctalus, Pipistrellus, Vespertilio and Eptesicus spp.) adapted for open-air foraging.. Bat species other than the open-air suite referred to above are usually not at risk at wind turbines, because they fly below the rotors, but are still killed occasionally (2%)." 7 c. It is now thought that bats may be at greater risk of death from wind turbines than birds because they may be affected by barotrauma as well as injuries caused by direct collision as has been shown in Canada. 8 Barotrauma is described as tissue damage to air-containing structures caused by rapid or excessive pressure change; pulmonary barotrauma is lung damage due to expansion of air in the lungs that is not accommodated by exhalation. 9 The prevalence of barotrauma in bat fatalities but not bird fatalities from wind turbines could result as a consequence of differences in mammalian and avian biology as birds have a unique respiratory system. d. The relatively large numbers of bat fatalities at wind farms could also be related to differences in flight height of these groups during migration in relation to turbine height. In Canada, bat fatalities increased exponentially with turbine tower height; whereas bird fatalities were lower at taller turbine towers. 10 e. UK evidence of the impact of wind farms on bats, however, is still being gathered. The wind farm industry is currently involved with DEFRA on a study to determine the impact of turbines on bats in Britain; the research is due to be published in Impact on birds known to be present and using the site 7 Rydell et al Bat Mortality at Wind Turbines in Northwestern Europe. Acta Chiropterologica 12(2): Baerwald et al Baerwald et al Barclay et al

5 a. 79 species were recorded in the 2008 ES 11, of which a number of red and amber Databook 12 species are included. This again demonstrates the importance of this area despite the damage done through previous developments undertaken without a full understanding of the ecosystem and its services. b. The main ornithological interests comprised hen harrier, black grouse and curlew. 13 We are concerned that these three species represent a small sample of the bird population of ornithological interest on the site, and its value for these birds is also not given its true weight in light of the acknowledged reduction in habitat here and in the locality. c. For example, in the case of curlew: i. Montgomeryshire is of national importance for curlew; however they have shown a rapid and drastic decline in the last 5 years. Trannon Moor has seen a decline from 15 pairs to 3 pairs from i There is no evidence that curlew adapt to turbine presence after the windfarm development; turbines need to be at least 150m from breeding colonies once the windfarm is operational and curlew are frightened off site during the construction phase despite the restriction that no activity on a site may be within 600m. The fact that curlew exist and breed in other parts of the UK does not detract from the national and regional importance of the Montgomeryshire population, which is now hanging on tenuously in spite, and not because of national policies. Curlew are a key indicator of upland biodiversity and are on the Red list. 4. The importance of axiophytes in assessing habitat and its potential for restoration. a. The relevance of axiophytes in determining the existing quality and also the potential for habitat restoration has not been mentioned. From the evidence presented it appears unlikely that such evaluation has been undertaken, and 11 ES 2008 page 181, para SEI 2013 Vol IIB, page 434, Appendix 5.2, para

6 yet without this methodology, assertion of restorative management lacks substance. b. Weaknesses in NVC classification methodology have been identified by the ecologist: the vegetation has generally been modified by grazing and NVC categories were often not a good fit The long term impact of the proposed development on the ecosystem of Llanbrynmair moors and its wider effect. a. It is acknowledged in the State of Nature report 15 that there has been a rapid decline of species over the past 50 years. We are concerned that the remits and constraints under which many organisations and bodies work leaves nature to fend for itself. The 2013 SEI and previous iterations conclude that there will be negative impact on almost all species and habitats; these vary in extent. The Alliance has seen no evidence to support the case that the negative impacts that would be incurred are acceptable in terms of local, national or global benefit or that the particular habitats and species will suffer anything other than greater loss; mitigation may be a good idea, but evidence shows that it demonstrably fails. i. It has been the case of the developers that moderate (or even significant) loss in species and habitat would be worth it for the greater gain. The ability of the Llanbrynmair moors to function as an active ecosystem is crucial not only to wildlife but has wider impacts on private water supplies, flood risk, recreational activities and businesses. The UK is already seeing the consequences of the decline of the native honey bee, affecting crop fertilisation; the loss of a single species has knock-on effects, most of which we are unaware until after the event. The Alliance has found no evidence to support the assertion that the negative ecological impacts will in the long term be outweighed by environmental benefits and remains concerned that the importance and value in terms of ecosystem goods and services has been given less weight, in support of the application. 14 SEI 2013, page 165, paragraph