LAMBY WAY, RUMNEY, CARDIFF · Lamby Way, Rumney, Cardiff 2 negative assessment of the implications...

LAMBY WAY, RUMNEY, CARDIFF Habitats Regulations Assessment Screening Report

JANUARY 2019

Lamby Way, Rumney, Cardiff

Arcadis Consulting (UK) Limited is a private limited company registered in England & Wales (registered number 02212959). Registered Office at Arcadis

House, 34 York Way, London, N1 9AB, UK. Part of the Arcadis Group of Companies along with other entities in the UK.

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CONTACTS

LIZ TURLEY

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Screening Report

Author Liz Turley

Checker Jo Weaver

Approver Sarah Simons

Report No 1002541718ECO02

Date JANUARY 2019

VERSION CONTROL

Version Date Author Changes

01 December 2018 LT First issue

This report dated 14 December 2018 has been prepared for Cardiff City Council (the “Client”) in accordance with the

terms and conditions of appointment dated 04 September 2018(the “Appointment”) between the Client and Arcadis

Consulting (UK) Limited (“Arcadis”) for the purposes specified in the Appointment. For avoidance of doubt, no other

person(s) may use or rely upon this report or its contents, and Arcadis accepts no responsibility for any such use or

reliance thereon by any other third party.


CONTENTS

1 INTRODUCTION AND PURPOSE OF THIS REPORT ............................................. 1

1.1 Introduction and Purpose .................................................................................................................... 1

1.2 Background to Habitats Regulations Assessment ........................................................................... 1

1.3 Legislation and Guidance .................................................................................................................... 2

2 THE SCHEME ........................................................................................................... 3

2.1 Location ................................................................................................................................................. 3

2.2 Timetable ............................................................................................................................................... 3

2.3 Scheme Description ............................................................................................................................. 3

3 THE HABITAT REGULATIONS ASSESSMENT PROCESS .................................... 5

3.1 Stages in HRA ....................................................................................................................................... 5

3.2 Approach to the HRA Report ............................................................................................................... 5

3.3 In combination Effects ......................................................................................................................... 6

3.4 Consideration of Effects ...................................................................................................................... 6

4 IDENTIFYING THE EUROPEAN SITES.................................................................... 8

4.1 Approach to Identifying Sites .............................................................................................................. 8

4.2 European Sites identified ..................................................................................................................... 8

4.3 Severn Estuary SPA ............................................................................................................................. 8

4.4 Severn Estuary Ramsar Site ................................................................................................................ 9

4.5 Severn Estuary SAC ........................................................................................................................... 10

4.6 Conservation Objectives of the European Sites ............................................................................. 11

5 BASELINE ENVIRONMENT ................................................................................... 12

5.1 Overview .............................................................................................................................................. 12

5.2 Ecological Information ....................................................................................................................... 12

6 ASSESSMENT OF LIKELY SIGNIFICANT EFFECTS............................................ 17

6.1 Overview .............................................................................................................................................. 17

6.2 Direct habitat and species loss associated with European sites .................................................. 18

6.3 Habitat degradation as a result of air pollution ............................................................................... 18

6.4 Changes in water quality within the European sites ...................................................................... 18

6.5 Loss of habitat functionally linked to a European site ................................................................... 19

6.6 Disturbance/displacement to species using the adjacent Rhymney River and Severn Estuary

20


7 IN COMBINATION EFFECTS ................................................................................. 21

8 CONCLUSION ......................................................................................................... 21

9 REFERENCES ........................................................................................................ 25

..................................................................................................................... 26

European sites pressures/ threats ................................................................................................................ 26

..................................................................................................................... 29

Figures ............................................................................................................................................................. 29


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1 INTRODUCTION AND PURPOSE OF THIS REPORT

1.1 Introduction and Purpose

1.1.1 This Habitats Regulations Assessment (HRA) Screening Report has been prepared by Arcadis

Consulting UK (Ltd) on behalf of Cardiff City Council as part of their application to develop land at

Lamby Way, Wentloog, near Cardiff. The site is currently a Cleansing Depot (comprising a generation

plant and a landfill site), with the southern portion of land intended for use as a ground-mounted solar

farm, to be connected to the national grid. This HRA is being prepared as part of the planning

application for the proposed solar farm.

1.1.2 The Screening Opinion (Natural Recourses Wales (NRW) and the Council’s Ecologist, 2015) for the

proposed development determined the need for HRA due to the close proximity of the Severn Estuary

Special Protection Area (SPA), Ramsar Site and Special Area of Conservation (SAC). The HRA will

establish whether the proposed development is likely to have significant effects on the qualifying

features of these designated sites.

1.1.3 This Report comprises Stage 1 (the initial screening and detailed screening of the project proposals)

of the HRA process. Further details of the HRA stages are provided in Section 3.

1.2 Background to Habitats Regulations Assessment

1.2.1 Under Article 6 of the Habitats Directive (and Regulation 102 of the Habitats Regulations), an

assessment is required where a land use plan may give rise to significant effects upon a Natura 2000

site (also known as a ‘European site’).

1.2.2 Although there are no European sites within the application site itself, three such sites (Severn Estuary

SPA, Ramsar site and SAC) are located within 100 m of its boundary, which could potentially be

affected by the proposals. These designated sites form part of the Natura 2000 network, which is a

network of areas designated to conserve natural habitats and species that are rare, endangered,

vulnerable or endemic within the European Community. This includes SACs, designated under the

Habitats Directive for their habitats and/or species of European importance, and SPAs, classified under

Directive 2009/147/EC on the Conservation of Wild Birds (the codified version of Directive 79/409/EEC

as amended) for rare, vulnerable and regularly occurring migratory bird species and internationally

important wetlands.

1.2.3 In addition, it is a matter of law that candidate SACs (cSACs) and Sites of Community Importance

(SCI) are considered in this process; furthermore, it is Government policy that sites designated under

the 1971 Ramsar Convention for their internationally important wetlands (Ramsar sites) and potential

SPAs (pSPAs) are also considered.

1.2.4 The requirements of the Habitats Directive are transposed into English and Welsh law by means of

the Conservation of Habitats and Species (Amendment) Regulations 20171.

1.2.5 Regulation 61, Part 6 of the Habitats Regulations states that:

‘A competent authority, before deciding to undertake, or give consent, permission or other

authorisation for, a plan or project which (a) is likely to have a significant effect on a European site or

a European offshore marine site (either alone or in combination with other plans or projects), and (b)

is not directly connected with or necessary to the management of the site, must make an appropriate

assessment of the implications for that site in view of that site’s conservation objectives.’.


‘If the competent authority are satisfied that, there being no alternative solutions, the plan or project

must be carried out for imperative reasons of overriding public interest (which, subject to paragraph

(2), may be of a social or economic nature), they may agree to the plan or project notwithstanding a

1 SI 2017/1012: Explanatory memorandum to the Conservation of Habitats and Species Regulations, 2017.


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negative assessment of the implications for the European site or the European offshore marine site

(as the case may be).’


‘Where, in accordance with regulation 62 (considerations of overriding public interest )— (a) a plan or

project is agreed to, notwithstanding a negative assessment of the implications for a European site or

a European offshore marine site, or (b) a decision, or a consent, permission or other authorisation, is

affirmed on review, notwithstanding such an assessment,— the appropriate authority must secure that

any necessary compensatory measures are taken to ensure that the overall coherence of Natura 2000

is protected.’

1.2.8 The overarching aim of HRA is to determine, in view of a site’s conservation objectives and qualifying

interests, whether a project, either in isolation and/or in combination with other projects, would have a

significant adverse effect on the European site. If the Screening (the first stage of the process, see

Section 3 for details) concludes that significant effects are likely, then Appropriate Assessment must

be undertaken to determine whether there will be adverse effects on the site’s integrity.

1.3 Legislation and Guidance

1.3.1 This HRA is being made in accordance with the requirements of the following legislation and guidance.

• The Conservation of Habitats and Species Regulations 2017. In 2012, these Regulations were

amended to transpose more clearly certain aspects of the Habitats Directive. In 2017, the

Conservation of Habitats and Species Regulations 2017 (the “Habitats Regulations 2017”)

consolidated and updated the Conservation of Habitats and Species Regulations 2010 (the

“Habitats Regulations 2010”).

• European Commission, Managing Natura 2000 sites: The provisions of Article 6 of the Habitats

Directive 92/43/EEC.

• European Commission, Guidance document on Article 6(4) of the Habitats Directive 92/43/EEC.

• Department for Communities and Local Government (2006) Planning for the Protection of

European Sites: Appropriate Assessment. Guidance for Regional Spatial Strategies and Local

Development Documents.

• Environment (Wales) Act (2016).

• DTA Publications Limited, The Habitats Regulations Assessment Handbook2.

2 DTA Publications Limited (June 2016) The Habitats Regulations Assessment Handbook.


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2 THE SCHEME

2.1 Location

2.1.1 The site is situated on the eastern edge of Cardiff. To the north there is a car park and recycling plant,

to the east a recently capped area of landfill (with landfill areas further beyond), to the southeast and

south there is the Severn Estuary/Bristol Channel and to the southwest and west there is the Rhymney

River.

2.1.2 The proposed solar project would be located on the capped and restored landfill site (approximately

19 Ha in size). The capping has been ongoing since the 1970s, with final capping completed in 1999.

The site has since been restored with new grassland, woodland and ponds being created. The

development focusses on the open areas of grassland and does not require the removal of the

woodland areas or ponds.

2.2 Timetable

2.2.1 The site clearance works will take place in April/ May 2019. The solar farm will be constructed following

completion of the clearance works between April/ May and September / October 2019.

2.3 Scheme Description

2.3.1 The proposed development comprises a new 8.7MW ground-mounted solar farm (refer to Figure 1,

Appendix B). The proposal includes provision for a galvanized steel mounting structure supported on

surface mounted concrete pads. The solar panels (each measuring 1m x 1.67m) are fixed directly to

the mounting structure and these are referred to as arrays. The arrays will not exceed 2.8m in height

and the lower edge will be around 750mm above ground level (the undulating nature of the ground

means this measure cannot be precise). The arrays will face due south and will be spaced between

1.6 and 6.5m apart (depending on the local topography of the site). The panels will be mounted at an

angle of between 15 and 25 degrees to the sun. The existing vegetation on the site will remain and be

allowed to recover post completion.

2.3.2 The proposed development also requires a number of containerised and similar structures to house

high voltage electrical equipment including inverters, transformers and switchgear. Each of these will

be set on a concrete raft foundation to spread the load across a wider area.

2.3.3 The panels would be set back from the boundary with the scrub adjacent to the River Rhymney, being

retained. There is an aspiration for the Wales Coastal Path to be rerouted to pass along the southern

and western boundaries of the site from its current alignment, which takes it inland to the east of the

landfill site. Whilst this aspiration has no material planning weight, insofar to safeguard the potential

route and provide areas of more open habitat, a 10 m buffer will be retained between the areas of

scrub around the site and the perimeter fence line. The site will be secured using a 2.2m high security

fence (agricultural timber and wire fence), with 3-4m high CCTV camera poles located at intervals

inside the site and close to the fence. Access would be provided via proposed tracks which will be

constructed with hardcore or via injecting cement powder into the top 300mm of the cap.

2.3.4 The installation has been designed to ensure that the existing constraints of the site are properly

considered. Nothing will penetrate through the landfill cap. The existing gas management system will

be retained and measures to ensure its maintenance have been included in the design including

offsets around well heads, maintenance tracks, and access to maintain gas pipework.

2.3.5 Most of the equipment will be brought in by HGV trucks, with around 50 vehicles expected during the

construction period. The haul route into the construction site will following the existing Lamby Way to

the north of the proposed development. Access into the construction site will also be located at the

northern end of the proposed development site (as shown on Figure 1, Appendix B). There will be 5

tracks (4 for transformer stations and 1 for customer substations) across the construction site in order

to install the solar farm, these are also shown on Figure 1, Appendix B.

2.3.6 The total construction period is expected to last 12 weeks. The deliveries will be spaced across the

construction period, with typically up to 10 a day throughout the construction phase.


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2.3.7 A Construction and Decommissioning Method Statement will be produced for the proposed

development.

2.3.8 During the construction period the following activities will be undertaken:

• site clearance, which will involve clearing vegetation (including a reptile translocation) and

marking out the site;

• erecting the security fence, creating internal access roads, compound and crane area;

• installing the concrete foundations and the frames and mounting frames [Note: piling methods

will be not be used for this activity];

• affixing the panels to the mounting frames and stringing (connecting the panels together);

• trenching for the cable (designed to protect the engineering cap), and laying cables;

• pouring the concrete base for the electrical housing / cabinets (Switchgear, Transformer,

Inverters etc.);

• installation of the housing / cabinets;

• erecting pole mounted CCTV cameras;

• connecting all the cables up and backfilling the cable trenches; and

• landscaping works.

2.3.9 The solar development would constitute a temporary development and would be decommissioned at

the end of its operational period (approximately 35 years). The decommissioning would typically last

a similar length of time and would have similar impacts as the construction phase.


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3 THE HABITAT REGULATIONS ASSESSMENT PROCESS

3.1.1 This section provides an outline of the stages involved in HRA and the specific methods that have

been used in preparing this Report.

3.1 Stages in HRA

3.1.1 The requirements of the Habitats Directive comprise four distinct stages:

1. Stage 1: Screening is the process which initially identifies the likely impacts upon a European

site of a project or plan, either alone or in combination with other projects or plans, and considers

whether these impacts may have a significant effect on the integrity of the site’s qualifying

habitats and/or species. It is important to note that the burden of evidence is to show, on the

basis of objective information, that there will be no significant effect; if the effect may be

significant, or is not known, that would trigger the need for an Appropriate Assessment. There is

European Court of Justice case law to the effect that unless the likelihood of a significant effect

can be ruled out on the basis of objective information, and adopting the precautionary principle,

then an Appropriate Assessment must be made. The April 2018 CJEU judgement determined

that mitigation to avoid or reduce harmful effects of the plan or project on a European site cannot

be taken into account at the screening stage (Stage 1). Where such measures are required, a

plan or project will require Appropriate Assessment to be undertaken (Stage 2).

2. Stage 2: Appropriate Assessment is the detailed consideration of the impact on the integrity of

the European site of the project or plan, either alone or in combination with other projects or

plans, with respect to the site’s conservation objectives and its structure and function. This is to

determine whether or not there will be adverse effects on the integrity of the site. This stage also

includes the development of mitigation measures to avoid or reduce any possible impacts.

3. Stage 3: Assessment of alternative solutions is the process which examines alternative ways

of achieving the objectives of the project or plan that would avoid adverse impacts on the integrity

of the European site, should avoidance or mitigation measures be unable to cancel out adverse

effects.

4. Stage 4: Assessment where no alternative solutions exist and where adverse impacts

remain. At Stage 4, an assessment is made with regard to whether or not the development is

necessary for imperative reasons of overriding public interest (IROPI). If it is, this stage also

involves detailed assessment of the compensatory measures needed to protect and maintain the

overall coherence of the Natura 2000 network.

3.2 Approach to the HRA Report

3.2.1 This HRA Report takes into account the requirements of the Habitats Regulations and relevant

guidance produced by David Tyldesley Associates (DTA Publications Limited, 2016).

3.2.2 The following stages have been completed.

• Identification of all European sites potentially affected (including those outside of the proposed

development boundary).

• A review of each European site, including the features for which the site is designated, the

Conservation Objectives, and an understanding of the current conservation status and the

vulnerability of the individual features to threats.

• A review of the proposals which have the potential to affect the European sites, and whether the

sites are vulnerable to these effects.

• A consideration of any potential impacts in combination with other projects (or plans).


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3.3 In combination Effects

3.3.1 As outlined in Section 3.1, it is necessary for HRA to consider in combination effects with other projects

or plans.

3.3.2 Where an aspect of a project could have some effect on the qualifying feature(s) of a European site,

but the effects of that aspect of the project alone would not be significant, the effects will need to be

checked in combination, firstly with other effects of the same project, and then with the effects of any

other plans and projects.

3.3.3 If the prospect of cumulative effects cannot be eliminated, it is necessary to consider how the addition

of effects from other projects or plans may produce a combined adverse effect on a European site that

would be significant. Taking the effects which would not be likely to be significant alone, it is necessary

to make a judgement as to whether these effects would be made more likely or more significant if the

effects of other projects or plans are added to them. Most cumulative effects can be identified by way

of the following characteristics. Could additional effects be cumulative because they would:

a. Increase the effects on the qualifying features in an additive, or synergistic way?

b. Increase the sensitivity or vulnerability of the qualifying features of the site affected by the project

proposals?

c. Be felt more intensely by the same qualifying features over the same area (a layering effect), or

by the same qualifying feature over a greater (larger) area (a spreading effect), or by affecting

new areas of the same qualifying feature (a scattering effect)?

3.3.4 In accordance with DTA Publications Limited, The Habitats Regulations Assessment Handbook (DTA

Publications Limited, 2016), it will be necessary to look for projects and plans at the following stages:

a. Applications lodged but not yet determined.

b. Projects subject to periodic review e.g. annual licences, during the time that their renewal is under

consideration.

c. Refusals subject to appeal procedures and not yet determined.

d. Projects authorised but not yet started.

e. Projects started but not yet completed.

f. Known projects that do not require external authorisation.

g. Proposals in adopted plans.

h. Proposals in finalised draft plans formally published or submitted for final consultation,

examination or adoption.

3.3.5 Plans under consideration may range from neighbouring authorities’ planning documents down to

sector-specific strategic plans on such topics as flood risk.

3.3.6 A review has been undertaken of projects and plans with the potential for an in combination effect with

the proposed development.

3.4 Consideration of Effects

Definition of Significant Effects

3.4.1 A critical part of the HRA screening process is determining whether or not the proposals are likely to

have a significant effect on European sites and, therefore, if they will require an Appropriate

Assessment. Judgements regarding significance should be made in relation to the qualifying interests

for which the site is of European importance and also its conservation objectives. A useful definition of

‘likely’ significant effects is as follows:

‘…likely means readily foreseeable not merely a fanciful possibility; significant means not trivial or

inconsequential but an effect that is potentially relevant to the site’s conservation objectives’ (Welsh

Assembly Government, 2006).


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3.4.2 In considering whether the project is likely to have a significant effect on a European site, a

precautionary approach must be adopted:

• The project should be considered ‘likely’ to have such an effect if the applicant is unable (on the

basis of objective information) to exclude the possibility that the project could have significant

effects on any European site, either alone or in combination with other plans or projects.

• An effect will be ‘significant’ in this context if it could undermine the site’s conservation objectives.

The assessment of that risk must be made in the light of factors such as the characteristics and

specific environmental conditions of the European site in question.


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4 IDENTIFYING THE EUROPEAN SITES

4.1 Approach to Identifying Sites

4.1.1 European sites which may be affected by the proposed development through an identifiable impact

pathway have been considered within a 20km distance from the proposed new solar farm.

4.2 European Sites identified

4.2.1 Three European sites have been screened in for assessment within the HRA Report. These are listed

in Table 1, and are shown on Figure 2, Appendix B.

Table 1: Summary of European Sites

Name of Site Identification Number Designation

Severn Estuary UK9015022 SPA

Severn Estuary UK11081 Ramsar Site

Severn Estuary UK0013030 SAC

4.3 Severn Estuary SPA

4.3.1 The site citation (JNCC, 2001) provides the species and numbers of birds which form qualifying

features of the SPA, these are provided in Table 2, below. The citation specifies these species in their

non-breeding, over-wintering state.

Table 2: Qualifying Features of the Severn Estuary SPA

Species Count (1991/2-1995/6 mean), individuals

This site qualifies under Article 4.1 of the Directive (79/409/EEC) by supporting populations of European

importance of the following species listed on Annex I of the Directive:

Over winter;

Bewick swan (Cygnus columbianus bewickii) 280

This site also qualifies under Article 4.2 of the Directive (79/409/EEC) by supporting populations of European

importance of the following migratory species:

On passage;

Ringed plover (Charadrius hiaticula) 655

Over winter;

Curlew (Numenius arquata) 3,903

Dunlin (Calidris alpina alpine) 44,624

Pintail (Anas acuta) 599

Redshank (Tringa totanus) 2,330

Shelduck (Tadorna tadorna) 3,330


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Species Count (1991/2-1995/6 mean), individuals

Assemblage qualification: A wetland of international importance.

The area qualifies under Article 4.2 of the Directive (79/409/EEC) by regularly supporting at least 20,000

waterfowl.

Over winter, the area regularly supports 93,986 individual waterfowl (5 year peak mean 1991/2 - 1995/6)

including: Gadwall (Anas strepera), Shelduck, Pintail, Dunlin, Curlew, Redshank, Bewick's Swan, Wigeon (Anas

Penelope), Lapwing (Vanellus vanellus), Teal (Anas crecca), Mallard (Anas platyrhynchos), Shoveler (Anas

clypeata), Pochard (Aythya farina), Tufted Duck (Aythya fuligula), Grey Plover (Pluvialis squatarola), White-

fronted Goose (Anser albifrons albifrons), Whimbrel (Numenius phaeopus).

4.4 Severn Estuary Ramsar Site

4.4.1 The site citation (JNCC, 2008) provides the habitats, species and numbers of birds which form

qualifying features of the Ramsar site, these are provided in Table 3.

Table 3: Qualifying Features of the Severn Estuary Ramsar site

Species Count (1998/9-2002/3) mean

Ramsar criterion 1:

Due to immense tidal range (second-largest in world), this affects both the physical environment and

biological communities.

Habitats Directive Annex I features present include:

H1110 Sandbanks which are slightly covered by sea water all the time.

H1130 Estuaries.

H1140 Mudflats and sandflats not covered by seawater at low tide.

H1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae).

Ramsar criterion 3:

Due to unusual estuarine communities, reduced diversity and high productivity.

Ramsar criterion 4:

This site is important for the run of migratory fish between sea and river via estuary. Species include Salmon Salmo (salar), sea trout (S. trutta), sea lamprey (Petromyzon marinus), river lamprey (Lampetra Fluviatilis), allis shad (Alosa alosa), twaite shad (A. fallax), and eel (Anguilla Anguilla). It is also of particular importance for migratory birds during spring and autumn.

Ramsar criterion 5:

Assemblages of international importance:

Species with peak counts in winter:

70,919 waterfowl (5-year peak mean 1998/99-2002/2003)

Ramsar criterion 6 – species/populations occurring at levels of international importance:

Qualifying species/populations (as identified at designation):


Tundra sawn (Bewick’s swan) 229 individuals, representing an average of 2.8% of the GB population.


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Species Count (1998/9-2002/3) mean

Greater white-fronted goose (Anser albifrons)

2,076 individuals, representing an average of 35.8% of the GB population

Shelduck 3,223 individuals, representing an average of 1% of the population.

Gadwall (Anas strepera Strepera) 241 individuals, representing an average of 1.4% of the GB population.

Dunlin 2,5082 individuals, representing an average of 1.8% of the population.

Redshank 2,616 individuals, representing an average of 1% of the population.

Species/populations identified subsequent to designation for possible future consideration

under criterion 6.

Species regularly supported during the breeding season:

Lesser black-backed gull (Larus fuscus

graellsii)

4,167 apparently occupied nests, representing an average of 2.8% of the breeding population (Seabird 2000 Census).

Species with peak counts in spring/autumn:

Ringed plover 740 individuals, representing an average of 1% of the population.


Eurasian teal (Anas crecca) 4,456 individuals, representing an average of 1.1% of the population.

Northern pintail (Anas acuta) 756 individuals, representing an average of 1.2% of the population.

Ramsar criterion 8:

The fish of the whole estuarine and river system is one of the most diverse in Britain, with over 110 species recorded. Salmon, sea trout, sea lamprey, river lamprey, shad, twaite shad and eel use the Severn Estuary as a key migration route to their spawning grounds in the many tributaries that flow into the estuary. The site is important as a feeding and nursery ground for many fish species particularly allis shad and twaite shad which feed on mysid shrimps in the salt wedge.

4.5 Severn Estuary SAC

4.5.1 The site citation (JNCC, 2015) provides the habitats and species which form qualifying features of the

SAC, these are provided in Table 4, below.


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Table 4: Qualifying Features of the Severn Estuary SAC

Qualifying habitats and species

Annex I habitats that are a primary reason for selection of this site:

1130 Estuaries

1140 Mudflats and sandflats not covered by seawater at low tide

1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae)

Annex I habitats present as a qualifying feature, but not a primary reason for selection of this site:

1110 Sandbanks which are slightly covered by sea water all the time

1170 Reefs

Annex II species that are a primary reason for selection of this site:

1095 Sea lamprey

1099 River lamprey

1103 Twaite shad

Annex II species present as a qualifying feature, but not a primary reason for site selection:

Not applicable.

4.6 Conservation Objectives of the European Sites

4.6.1 Under Regulation 35(3) of the Conservation of Habitats and Species Regulations 2010 (as amended)

the appropriate statutory nature conservation body (in this case NRW) has a duty to communicate the

conservation objectives for a European site to the relevant/competent authority responsible for that

site. The information provided under Regulation 35 must also include advice on any operations which

may cause deterioration of the features for which the site is designated.

4.6.2 The conservation objectives for a European site are intended to represent the aims of the Habitats and

Birds Directives in relation to that site. To this end, habitats and species of European Community

importance should be maintained or restored to ‘favourable conservation status’ (FCS), as defined in

Article 1 of the Habitats Directive below:

The conservation status of a natural habitat will be taken as ‘favourable’ when:

• Its natural range and the area it covers within that range are stable or increasing;

• The specific structure and functions which are necessary for its long-term maintenance exist and

are likely to continue to exist for the foreseeable future; and

• Conservation status of typical species is favourable as defined in Article 1(i).

The conservation status of a species will be taken as favourable when:

• Population dynamics data on the species concerned indicate that it is maintaining itself on a long-

term basis as a viable component of its natural habitats;

• The natural range of the species is neither being reduced nor is likely to be reduced for the

foreseeable future; and

• There is, and will probably continue to be, a sufficiently large habitat to maintain its populations

on a long-term basis.

http://jncc.defra.gov.uk/protectedsites/sacselection/habitat.asp?FeatureIntCode=H1130





http://jncc.defra.gov.uk/protectedsites/sacselection/species.asp?FeatureIntCode=S1095




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4.6.3 Guidance from the European Commission indicates that the Habitats Directive intends FCS to be

applied at the level of an individual site, as well as to habitats and species across their European

range. Therefore, in order to properly express the aims of the Habitats Directive for an individual site,

the conservation objectives for a site are essentially to maintain (or restore) the habitats and species

of the site at (or to) FCS. Current pressures/ threats to the European sites are provided in Appendix

A.

5 Baseline Environment

5.1 Overview

5.1.1 This section provides details of the ecological information gathered to inform the screening

assessment. Reference to site-specific surveys undertaken for the project have been included, where

relevant.

5.2 Ecological Information

5.2.1 The following sources of ecological information have been considered during the screening exercise:

• British Trust for Ornithology (BTO) Bird Track.

• Glamorgan Bird Club (East Glamorgan Bird Atlas).

• Natural England goose and swan functional land Impact Risk Zone (IRZ) buffer.

• BTO Wetland Bird Survey (WeBS) data.

• South East Wales Biodiversity Records Centre (SEWBReC) Records.

• Ecological Surveys of the site.

5.2.2 Each of these data sources, and the results of the data gathering exercise is described below.

BTO Bird Track records

5.2.3 Bird Track is an online recording portal available through the BTO that anyone can register to use, and

enables birdwatchers to upload their sightings. Whilst it cannot necessarily be relied upon to provide

accurate and detailed location information of bird sightings; it provides a useful guide as to the

presence of large flocks of SPA/ Ramsar site species and covers a much wider area than would be

covered by regular, standardised surveys, such as WeBS.

5.2.4 A search of the Bird Track records did not identify any records within the proposed development

boundary, the nearest records of SPA/ Ramsar site species were more than 2km to the east of the site

within the Gwent Levels – Rumney and Peterstone Site of Special Scientific Interest (SSSI).

Glamorgan Bird Club

Glamorgan Bird Club hold an online Bird Atlas with records from 421 tetrads within East Glamorgan.

The proposed solar farm development lies within tetrad ST27I (Lamby Way). The Atlas includes

breeding and wintering records covering a 50-year period. However, for the purposes of this Report,

the most recent wintering records, covering 2007 – 2011, were reviewed.

The tetrad data shows that there are records of six SPA/ Ramsar site qualifying species (including:

Bewick’s swan, shelduck, pintail, ringed plover, dunlin and redshank), plus a further 33 species which

could form part of the qualifying waterbird assemblage present within tetrad ST27I. However, as the

tetrad includes the edge of the Severn Estuary SPA/ Ramsar site, Lamby Salt Marsh Site of Importance

for Nature Conservation (SINC), and the River Rhymney SINC, it is likely that the records relate to

these other more suitable locations, rather than the proposed development site itself.


13

Natural England goose and swan functional land IRZ buffer (GIS Data)3

5.2.5 Natural England have produced a swan and goose functional land IRZ buffer, to provide an indication

as to the potential for areas to support wintering geese and swans associated with SPA/ Ramsar sites

across England and the borders of Wales around the Dee Estuary and the Severn Estuary. The IRZ

does not take account of the presence of existing development, as such, being within the buffer does

not necessarily mean an area supports suitable habitat but does provide an indication as to where

suitable habitat could be present.

5.2.6 Due to the close proximity of the proposed development site to the Severn Estuary, the site does lie

within the goose and swan functional land IRZ buffer.

BTO WeBS data

5.2.7 The BTO carry out the WeBS monitoring scheme for non-breeding waterbirds across the UK.

Synchronised monthly counts at wetlands of all habitat types, are carried out mainly during the winter

period. These WeBS Core Counts are supplemented by occasional WeBS Low Tide Counts

undertaken on estuaries, with the aim of identifying key feeding areas. There are four WeBS Core

Count sectors adjacent to the proposed development site, as shown below.

Image taken from BTO WeBS website (www.bto.org.uk)

5.2.8 Low tide Count data is available for the Severn Estuary; however, the most recent data is from 2008/09.

Given that this data is now ten years old, and more recent data is available from other sources, it was

not deemed necessary to obtain the Low tide Count data.

5.2.9 The Core Count sectors adjacent to the proposed development site comprise:

• Parc Tredelerch – Cardiff (Location Code: 60055)

• Cors Crychydd Reen (Location Code: 60011)

• Rhymney Estuary and Great Wharf (Location Code: 61405)

• Peterstone Wentlooge (Location Code: 60401)

3 SSSI IRZs Full Dataset – External, available through the Natural England Huddle Workspace Updated July 2018


14

5.2.10 All of these sectors have been counted in the last five years, and data has been obtained for the three

Core Count sectors (Parc Tredelerch – Cardiff, Cors Crychydd Reen, and Rhymney Estuary and Great

Wharf) closest to the proposed development.

Parc Tredelerch – Cardiff (Location Code: 60055)

5.2.11 This count sector is located to the northwest of the proposed development site. The WeBS data shows

that no SPA/ Ramsar site qualifying species have been recorded. However, 13 bird species which

would form part of the waterbird assemblage are present within the count sector in small numbers

(refer to Table 5).

Table 5: Birds recorded within the Parc Tredelerch - Cardiff count sector

Species 5 yr average (2012/13 – 2016/17)

Mute swan 9

Canada goose 12

Mallard 33

Tufted duck 12

Great crested grebe 6

Cormorant 2

Grey heron 1

Moorhen 8

Coot 16

Black-headed gull 155

Common gull 1

Lesser black-backed gull 38

Herring gull 91

The Cors Crychydd Reen (Location Code: 60011)

5.2.12 This Count sector is located to the northeast of the proposed development site. The WeBS data for

this Count sector also shows that no SPA/ Ramsar site qualifying species were recorded. However,

eight bird species which would form part of the waterbird assemblage are present within the count

sector in small numbers (refer to Table 6).

Table 6: Birds recorded within the Cors Crychydd Reen count sector


Mute swan 6

Canada goose 2

Mallard 16

Little grebe 4


15

Grey heron 1

Moorhen 18

Coot 5

Black-headed gull 1

Rhymney Estuary and Great Wharf (Location Code: 61405)

5.2.13 This Count sector is located to the south and east of the proposed development site. The WeBS data

for this Count sector shows that individual SPA/ Ramsar site qualifying species are present within the

count sector (refer to Table 7). Species which would form part of the waterbird assemblage are present

within the count sector.

Table 7: SPA/ Ramsar site individual qualifying species recorded within the Rhymney Estuary and Great Wharf count sector


Ringed plover (on passage) 9

Curlew 4

Dunlin 1,500

Pintail 155

Redshank 1,167

Shelduck 428

Gadwall 9

Lesser black-backed gull

(breeding only) 37

Teal 41

SEWBReC

5.2.14 As part of the desk study for the Preliminary Ecological Appraisal (PEA) of the proposed development

(see references below), SEWBReC were contacted for records of protected and/or notable species,

including records of SPA/ Ramsar site species. The records from 2008 to 2016, identified one

waterfowl species (gadwall), within the site itself, with the remainder of the records outside of the site.

Little ringed plover, lapwing, greenshank, kingfisher, and whimbrel were recorded approximately 100m

away (associated with the Rhymney River), with records of other waterfowl species being associated

with the Severn Estuary.

5.2.15 SEWBReC did not provide any records of qualifying fish species associated with the Severn Estuary

SAC/ Ramsar site.

5.2.16 Habitat information provided by SEWBReC identified that the adjacent River Rhymney and Estuary

supported the SAC and Ramsar site qualifying habitats Atlantic salt meadow (saltmarsh), Intertidal

mudflats and sandflats, and Estuaries.


16

Ecological Surveys of the Site

5.2.17 Ecological surveys have been carried out at the site during 2017 and 2018, including a Preliminary

Ecological Appraisal (PEA) (Udall-Martin Associates Ltd, December 2017), Ground-nesting Bird

Surveys (Udall-Martin Associates Ltd, September 2017) and an over-wintering bird habitat

assessment carried out by Arcadis in October 2018.

Preliminary Ecological Appraisal

5.2.18 The Extended Phase 1 habitat survey identified the site as ‘dominated by grassland, with scattered

and dense patches of scrub, pockets of woodland, a large pond, small pond and several scattered

areas of wet pools/marshy areas. The central area of the site comprised reasonably flat ground

(although with localised humps and hollows) with the site sloping downwards to the south and west

towards the Severn Estuary and Rhymney River respectively.’

5.2.19 The River Rhymney to the west of the proposed site is not within the Severn Estuary SPA/ Ramsar

site or SAC, however, the desk study undertaken as part of the PEA identified that it is a designated

as a SINC, along with Lamby Saltmarsh SINC to the south of the proposed solar development.

5.2.20 Lamby Saltmarsh SINC is described as ‘The remnant edges of the originally large Lamby Saltings

that were reclaimed by land fill.... located on the eastern banks of the River Rhymney, bounded by the

Severn Estuary to the south and Lamby tip to the north. The site is important for rare salt-marsh and

coastal plants...and as a rest place and breeding site for birds frequenting the Rhymney Estuary for

feeding.’

5.2.21 River Rhymney SINC is described as ‘One of the three main rivers within Cardiff…Rhymney River

Valley Complex SINC, Rhymney Grassland East SINC and Lamby North SINC and Lamby Salt Marsh

SINC all bound the River Rhymney SINC towards the south. The river is important for migratory fish,

otters, wildfowl and bankside vegetation and acts as a major wildlife corridor. Bats, dormice, grass

snakes, eel and trout have been recorded in and around the River Rhymney’.

5.2.22 The Gwent Levels – Rumney and Peterstone SSSI is also located to the east of the site and supports

tidal mudflats and saltmarsh, as well as a network of ditches and reens. The area is important during

the spring and autumn migration for waders along the west coast of Britain, and also supports large

numbers of birds in the winter including oystercatcher, curlew, dunlin, redshank, knot, turnstone, grey

plover, shelduck, teal, pintail, wigeon, shoveler, and avocet.

5.2.23 The PEA identified that the waterbodies and wet pool/marshy areas provide potential habitat for

waterfowl (species recorded during the protected species walkover survey included common snipe,

coot, moorhen, and grey heron), and the site was also identified as suitable for breeding birds. Further

bird surveys were carried out in 2017, as described below.

Ground-nesting Bird Surveys

5.2.24 The Ground-nesting Bird Surveys were carried out in June and July 2017 (Udall-Martin Associates

Ltd, September 2017). The surveys identified the presence of oystercatcher (up to two pairs on the

active landfill site) and lapwing (two nests identified but appeared to fail) on the adjacent landfill site.

Shelduck were also recorded as present to the south-west of the active landfill site, but no breeding

was noted. Little grebe, mute swan, grey heron, moorhen and coot were also recorded utilising the

waterbodies within the survey area, but again were not recorded breeding. Gulls were recorded during

the surveys, but none of the three gull species (black-headed gull, lesser black-backed gull and herring

gull) noted had nests on the site itself, with all records of birds flying over or loafing on the adjacent

roofs of industrial buildings.

5.2.25 The presence of these waterbird species suggest that the proposed development site could provide

some suitable habitat for over wintering birds - species such as lapwing will utilise the same areas for

wintering and breeding. However, the Ground-nesting Bird Survey Report concluded that predation

and disturbance on site are major constraints to successful breeding, and it is likely that these issues

would be prevalent during the winter, thereby reducing the sites’ potential suitability for over-wintering

birds.


17

Over-wintering Bird Habitat Assessment

5.2.26 In order to determine the potential use of the proposed development site for over-wintering birds, a

habitat assessment was carried out in October 2018. The assessment identified that the majority of

the site supported tall ruderal herbs and scrubby grassland, which were largely unsuitable for the

majority of SPA/ Ramsar site qualifying bird species. The pond at the northern end of the proposed

development site supported densely vegetated margins with no areas suitable for probing waders,

such as curlew. It was considered possible that species such as lapwing or shelduck could land within

the site and utilise the small number of areas with a shorter sward, however, the habitats would not be

likely to support such species in large numbers. Given the poor habitat suitability within the proposed

development site, further wintering bird surveys were not considered necessary to inform the

assessment.

5.2.27 The boundaries of the site comprised scrub and woodland and screened the proposed development

site from the adjacent Severn Estuary and Rhymney River.

6 Assessment of Likely Significant Effects

6.1 Overview

6.1.1 During the HRA screening stage, the likely nature, magnitude, frequency, timing, duration, location

and spatial extent of changes resulting from the proposed development will be assessed. As a part of

this, mechanisms through which the proposed solar farm could impact upon European sites will be

considered.

6.1.2 The Natural Resources Wales (NRW) pre-planning advice identified the following potential impacts to

be considered in any assessment of the proposed development:

• water pollution from site drainage and contamination release during construction;

• noise and visual disturbance to overwintering birds during construction;

• visual disturbance to overwintering birds during operation from glare; and

• obstruction to bird flight-lines from overhead cabling.

6.1.3 Natural England have recently produced a document which looks at the current evidence available of

the potential impacts associated with solar farms on birds, bats and general ecology (Natural England,

2017). The literature review of scientific documents and non-governmental and governmental

organisations concludes that:

‘there is little scientific evidence exists that demonstrates a direct impact of solar PV on birds. It is likely

that different avian species are likely to be affected differently by solar developments, dependant on

the habitat within and around a solar PV development, the spatial requirements of a given species

(e.g. flocking species such as pink-footed goose Anser brachyrhynchus that require large areas to

host the flock) and the foraging behaviour of a given species. Until further scientific evidence is accrued

to support any positive or negative impacts of solar farms on birds, we recommend that developments

should be considered on a site by site basis with consideration given to 1) the habitat available prior

to the development, 2) the habitat that will co-occur with the development and 3) the potential for

attraction to polarotactic insect species (i.e. is the development close to a water body).’

6.1.4 Taking into consideration the advice from NRW, and the Natural England publication, the following

impact pathways have been identified.

• Direct habitat and species loss associated with European sites.

• Habitat degradation as a result of increased air pollution.

• Changes in water quality within the European sites.

• Disturbance/displacement to species using the adjacent Rhymney River and Severn Estuary.

• Loss of habitat functionally linked to a European site (i.e. used by overwintering or passage birds

for foraging).

6.1.5 Each of these potential impacts are assessed in the following sections.


18

6.2 Direct habitat and species loss associated with European sites

6.2.1 The proposed solar farm is located outside the Severn Estuary SPA/ Ramsar site/ SAC boundary and

therefore, there would be no direct habitat or species loss within the Severn Estuary SPA/ Ramsar

site/ SAC as a result of the proposed development.

6.2.2 This potential impact pathway has been screened out of further assessment alone and/ or in

combination.

6.3 Habitat degradation as a result of air pollution

6.3.1 Changes in air quality from increased traffic and development could have impacts on European sites

through an increase in nitrogen deposition which could occur as a result of construction activities in

the vicinity of European sites. Given the proximity of the proposed development to the Severn Estuary,

there is the potential for air quality impacts.

6.3.2 The Site Improvement Plan for the Severn Estuary (Natural England, 2015) identified the risk of

atmospheric nitrogen deposition as a potential pressure/threat to the European sites. The plan states

that:

‘Activities around the Estuary include fertiliser application, potentially dairy and poultry production, road

traffic, industry (including power stations), and shipping which are all sources of nitrogen pollution.

Nitrogen deposition exceeds site relevant critical loads, with potential impacts on vegetation structure

and diversity.’

6.3.3 The Site Improvement Plan includes the following qualifying features of the Severn Estuary which are

sensitive to nitrogen deposition: gadwall, Estuaries, Atlantic salt meadows, sea lamprey, river lamprey,

Twaite shad, and the waterbird assemblage. The only potential impact pathway associated with air

pollution and the proposed development would be through increased traffic during the construction

phase. Given that the construction works (and any future decommissioning works) will take place

outside of the main winter period, there would be no direct impacts on gadwall or the waterbird

assemblage. The remaining features could be present within 200m during the construction phase.

6.3.4 Current air quality guidance suggests that any construction sites or routes used by construction

vehicles within 50 m of a designated site (IAQM, 2014); and the presence of any European site within

200 m of the main access roads used by HGVs accessing the site (DMRB, 2007) could lead to likely

significant effects on the European site during the construction phases of new development.

6.3.5 Based on the available construction information, the construction site for the proposed development

would be more than 50m from the edge of the European site; therefore, potential air quality impacts

associated with the construction site itself can be ruled out. The proposed haul routes would use

Lamby Way to the north of the proposed development and access the site at the northern end of the

construction area. Lamby Way is over 700m from the Severn Estuary, and the entrance to the

construction site would be more than 400m from the Severn Estuary. Potential impacts associated

with the construction can therefore also be ruled out. The decommissioning site and haul routes would

be expected to be the same as those used for the construction phase.

6.3.6 There would be no air quality impacts associated with the operational phase of the proposed solar

farm.

6.3.7 This potential impact pathway has been screened out of further assessment alone and/ or in

combination.

6.4 Changes in water quality within the European sites

6.4.1 Changes in water quality as a result of the proposed development could have impacts on European

sites. For example, damaging the engineering cap of the landfill site could release contaminants into

the Rhymney River/ Severn Estuary, there is an increased risk of potential pollution incidents, and

potential increases in suspended sediments resulting in ecological effects, such as the direct loss of

habitats caused by re-deposition of suspended sediment, and the consequential health or mortality

effects on prey species, particularly invertebrates associated with the intertidal mudflats.


19

6.4.2 The Site Improvement Plan for the Severn Estuary (Natural England, 2015) identified the risk of water

pollution as a potential pressure/threat to the European sites. The plan states that:

‘There is uncertainty over water quality in the Estuary due to diffuse (including agricultural) or direct

pollution (e.g. industrial, sewage treatment works, thermal, radioactive). There is a requirement for

better understanding of water and sediment quality issues. The Severn River Basin Management Plan

identifies that 17 % of the estuarine waterbodies in the river basin district currently achieve good

ecological status while the others are at moderate status. Macrophytobenthos (benthic macro algae)

have been identified in localised hotspots and may be having adverse impacts on the invertebrate

communities there. The extent of issues like this, the presence and mobilisation of a range of

contaminants and reasons behind the moderate statuses need to be understood. This includes

analysis of current data and consideration of potential issues with contaminants in sediment. ’

6.4.3 The Site Improvement Plan includes the following qualifying features of the Severn Estuary which are

sensitive to water pollution: gadwall, dunlin, common redshank, greater white-fronted goose, subtidal

sandbanks, Estuaries, intertidal mudflats and sandflats, reefs, Atlantic salt meadows, sea lamprey,

river lamprey, twaite shad and the waterbird assemblage.

6.4.4 Based on the available construction information, the solar farm will be fixed to the ground via structural

supporting units with concrete shoe foundations. The access routes will be laid over the existing

ground, and there will be no ground penetration below 1m (refer to Section 2 for further details). The

engineering cap on the landfill will not be affected by the works and as such, no release of

contaminants are predicted from the landfill during the construction, operational or decommissioning

phases of the development. This potential impact can be ruled out.

6.4.5 In order to protect water quality during the construction and decommissioning phases of the

development as a result of potential pollution incidents, or run off from the construction site, the

Construction and Decommissioning Method Statement will include water quality protection measures.

These will comprise best practices and measures set out within relevant CIRIA publications, such as:

undertaking regular checking of waterbodies located near areas of construction works for changes in

water quality; avoiding spillages by using bunds around storage tanks to prevent leakages, use of drip

trays around mobile plant, designating specific areas for re-fuelling to prevent run off; and use of grips,

sumps, straw bales and sediment traps may also be used to capture silt, if required. These standard

pollution prevention measures are considered sufficient to protect water quality within the Severn

Estuary SPA/ Ramsar site/ SAC during the construction and decommissioning phases of the proposed

development, and no likely significant effects on water quality of the adjacent European sites are

predicted.

6.4.6 Once constructed, there would be no operational phase impacts on water quality.

6.4.7 This potential impact pathway has been screened out of the further assessment alone and/ or in

combination.

6.5 Loss of habitat functionally linked to a European site

6.5.1 Functionally-linked land is considered to be any land outside of a European site, which is regularly

used by significant numbers of birds that are qualifying interest features of that European site. In

relation to this HRA Report, this includes the brown field site of the landfill within and adjacent to the

proposed solar farm that could be regularly used by qualifying bird species associated with the Severn

Estuary SPA/ Ramsar site during the winter and on passage for foraging or roosting. The Site

Improvement Plan for the Severn Estuary does not include loss of functionally-linked land as a

potential threat to the European sites.

6.5.2 The information presented in the baseline, including an over-wintering bird habitat assessment of the

proposed development site, indicates that the land within the proposed solar farm development is

largely unsuitable for SPA/ Ramsar site species. Although small numbers of SPA/ Ramsar site species

have been recorded within the proposed development site; the site is unlikely to support significant

numbers of birds on a regular basis (due to poor habitat suitability, predation and disturbance from the

active landfill site). The desk study data shows that surrounding habitats including the Severn Estuary

SPA/ Ramsar site itself, the River Rhymney SINC, Lamby Saltmarsh SINC and the Gwent Levels –


20

Peterstone SSSI provide more suitable foraging and roosting habitat, and support SPA/ Ramsar site

species during the over-winter period (as indicated by the WeBS data (refer to Section 5).

6.5.3 Given the poor suitability of the proposed development site for SPA/Ramsar site species it is not

considered to be functionally linked land to the Severn Estuary SPA/ Ramsar site, and there would be

no likely significant effect on the qualifying features of the Severn Estuary SPA/ Ramsar site as a result

of the loss of 19ha of sub-optimal overwintering habitat under the footprint of the proposed solar farm.

6.5.4 This potential impact has been screened out of further assessment alone and/ or in combination.

6.6 Disturbance/displacement to species using the adjacent Rhymney River and Severn Estuary

6.6.1 There is the potential to disturb qualifying species within European sites, in particular birds, during the

construction and operational phases of new developments. Disturbance/displacement could occur as

a result of the following:

• Noise and visual disturbance to overwintering birds during the construction and decommissioning

phases of the solar farm.

• Potential collision with the new solar panels and visual disturbance to overwintering birds during

operation, from glare.

• Obstruction to bird flight-lines from overhead cabling.

6.6.2 The Site Improvement Plan for the Severn Estuary does not include effects associated with

disturbance/ displacement (as a result of construction activities/ operational stage) as a potential threat

on the European site.

Noise and visual disturbance to overwintering birds during the construction and

decommissioning phases of the solar farm

6.6.3 The information presented in the baseline (Section 5) indicates that River Rhymney SINC, Lamby

Saltmarsh SINC and adjacent estuarine habitat of the Severn Estuary provide roosting and foraging

areas for SPA/ Ramsar site qualifying features. However, no construction or decommissioning works

will take place during the main overwintering period when over-wintering and passage qualifying

species associated with the Severn Estuary SPA/ Ramsar site would be present. All construction

works, including site clearance and construction of the solar arrays will be completed prior to the main

winter period 2020/ 2021, although works would continue into October, the majority of the works would

already be completed by this time. Decommissioning would be expected to take place during the

summer of 2054.

6.6.4 Given, the timings of the works, there would be no likely significant disturbance/displacement effects

on the over-wintering and passage SPA/Ramsar site qualifying bird species using the adjacent habitats

during the construction or decommissioning phases of the project. This potential impact has been

screened out of further assessment alone and/ or in combination.

6.6.5 The Severn Estuary Ramsar site includes lesser black-backed gull as a qualifying feature during the

breeding season. Although recorded in small numbers (less than 1% of the SPA/Ramsar site

population) during the Ground-nesting Bird Surveys (Udall-Martin Associates Ltd, September 2017),

no record of breeding was noted, and no likely significant effects on this species are anticipated as a

result of the construction/ decommissioning works. This potential impact has been screened out of

further assessment alone and/ or in combination.

Potential collision with the new solar panels and visual disturbance to overwintering birds

during operation, from glare

6.6.6 Given the proximity of the SPA/ Ramsar site to the proposed development site, there is the potential

for visual disturbance to overwintering birds during the operational phase, from glare, and the potential

for collision with the new solar panels or overhead cabling.

6.6.7 Although there is the potential for birds to collide with the solar panels, there is little scientific evidence

that this is actually the case. A study by DeVault et al. (2014) conducted 515 bird surveys at solar PV


21

sites, but found no obvious evidence for bird casualty caused by solar panels. The literature review

carried out by Natural England (Natural England, 2017) concluded that current evidence suggests that

bird collision risk from solar panels is very low and that there is likely to be more of a collision risk to

birds presented by infrastructure associated with solar PV developments, such as overhead power

lines. Consequently, given the small-scale of the proposed solar farm and the positioning of the arrays

to allow gaps in between the banks of panels to break up the surface, potential impacts associated

with collision with the panels are considered unlikely, and this potential impact has been screened

out of further assessment alone and/ or in combination.

6.6.8 Although there is the potential for glare from the new solar arrays, the solar farm will be screened from

the adjacent River Rhymney and Severn Estuary from existing woodland and scrub at the edge of the

site. The proposed development will focus on the open areas of grassland within the site and would

not require the removal of this screening vegetation. In addition, as described in the previous

paragraph, gaps will be left between the banks of panels to break up the surface, further reducing the

likelihood of solar glare. Given the retention of screening around the edge of the proposed new solar

farm, and the positioning of the arrays, potential impacts associated with glare are considered unlikely,

and this potential impact has been screened out of further assessment alone and/ or in combination.

Obstruction to bird flight-lines from overhead cabling

6.6.9 In relation to cabling for the proposed development, there will be no additional overhead wiring

requirements. All cabling connections associated with the current solar farm planning application (on

which this HRA Report is based) will be underground; hence, there would be no impacts associated

with collision with over-head wires associated with the current solar farm planning application, and this

potential impact has been screened out of further assessment alone and/ or in combination.

6.6.10 [Note: that connection to the grid will be covered by a separate planning application, and therefore is

not included within this HRA Screening Report].

7 In combination effects

7.1.1 The screening assessment within Section 6 has identified that there would be likely significant effects

on European sites as a result of development of the proposed solar farm. No residual effects have

been identified and therefore no in combination effects are anticipated.

8 Conclusion

8.1.1 This HRA Screening has considered the potential for the proposed solar farm development at Lamby

Way, Cardiff to have a likely significantly effect on the Severn Estuary SPA/ Ramsar site/ SAC and/or

its qualifying habitats and species. The Screening exercise looked at each of the potential impacts

(comprising direct habitat and species loss associated with European sites; habitat degradation as a

result of increased air pollution; changes in water quality within the European sites;

disturbance/displacement to species using the adjacent Rhymney River and Severn Estuary; and loss

of habitat functionally linked to a European site (i.e. used by overwintering or passage birds for

foraging)) and concluded that the proposed development will not have any likely significant effects on

the European sites identified within this HRA Report, either alone or in combination with other plans

or projects. Tables 8 to 10 provide a screening summary for Severn Estuary SPA, Ramsar site and

SAC.

8.1.2 No further Appropriate Assessment is required.


22

Table 8: Screening summary table: Severn Estuary SPA

Qualifying

feature (refer to

Section 4.3)

Pressure/

Threats

Direct Habitat loss Air quality Water quality Disturbance/ displacement Loss of functionally

linked habitat

Co Op De Co Op De Co Op De Co Op De Co Op De

Over-wintering

birds:

Bewick’s swan, Curlew, Dunlin, Pintail, Redshank, Shelduck, Waterfowl assemblage

Passage:

Ringed plover

Refer to

Appendix A

No direct loss of habitat

within the European site as

a result of the proposed

solar farm development

Construction

site and haul

routes of

sufficient

distance to

avoid

impacts on

air quality

No effect

Decommissioning

site and haul

routes of sufficient

distance to avoid

impacts on air

quality

Standard pollution

prevention measures

adequate to protect

water quality during

construction phase. No

additional measures

required to protect

water quality of the

European site

No effect

Standard pollution

prevention measures

adequate to protect


decommissioning

phase. No additional

measures required to

protect water quality

of the European site

Construction works

will take place

outside of the main

winter period. No

impacts on over-

wintering/ passage

qualifying species.

Sufficient

screening

and

positioning

of solar

arrays to

avoid glare.

No

overhead

cabling

Decommissioning

works will take

place outside of

the main winter

period. No

impacts on over-

wintering/

passage

qualifying species.

No loss of habitat

functionally linked to the

European site as a result of

the proposed solar farm

development

Conclusion No Likely Significant Effect No Likely Significant Effect No Likely Significant Effect No Likely Significant Effect No Likely Significant Effect


23

Table 9: Screening summary table: Severn Estuary Ramsar site

Qualifying

feature (refer to

Section 4.4)

Pressure/

Threats


linked habitat


Qualifying habitats:

Sandbanks Estuaries Mudflats and sandflats Atlantic salt meadows

Refer to

Appendix A

No direct loss of habitat




Construction

site and haul

routes of

sufficient

distance to

avoid

impacts on

air quality

No effect

Decommissioning

site and haul


distance to avoid

impacts on air

quality

Standard pollution

prevention measures

adequate to protect



additional measures

required to protect


European site

No effect

Standard pollution

prevention measures

adequate to protect


decommissioning





N/A N/A N/A N/A

Qualifying

migratory fish

species:

Salmon, sea trout,

sea lamprey, river

lamprey, allis shad,

twaite shad and

European eel.

Refer to

Appendix A No effect No effect No effect N/A

Over-wintering birds: Bewick’s swan, White-fronted goose, Shelduck, Gadwall, Dunlin, Redshank, Teal, Pintail, Waterfowl assemblage On passage: Ringed plover

Refer to

Appendix A

Construction works

will take place

outside of the main

winter period. No

impacts on over-

wintering/ passage

qualifying species.

Sufficient

screening and

positioning of

solar arrays to

avoid glare. No

overhead cabling

Decommissioning

works will take

place outside of

the main winter

period. No

impacts on over-

wintering/

passage

qualifying species.

No loss of habitat




development

Breeding:

Lesser black-

backed gull

Refer to

Appendix A

No lesser black-

backed gull

recorded breeding

within or adjacent to

the proposed solar

farm development

site. No impacts on

breeding population

of lesser black-

backed gull

Sufficient

screening and

positioning of

solar arrays to

avoid glare. No

overhead cabling

No lesser black-

backed gull

recorded breeding

within or adjacent

to the proposed

solar farm

development site.

No impacts on

breeding

population of

lesser black-

backed gull

No loss of habitat




development

Conclusion No Likely Significant Effect No Likely Significant Effect No Likely Significant Effect No Likely Significant Effect No Likely Significant Effect


24

Table 10: Screening summary table: Severn Estuary SAC

Qualifying

feature (refer to

Section 4.5)

Pressure/

Threats


linked habitat


Qualifying habitats:

Estuaries Mudflats and sandflats Atlantic saltmarsh Sandbanks Reefs

Refer to

Appendix A No direct loss of habitat




Construction

site and haul

routes of

sufficient

distance to

avoid

impacts on

air quality

No effect

Decommissioning

site and haul


distance to avoid

impacts on air

quality

Standard pollution

prevention measures

adequate to protect



additional measures

required to protect


European site

No effect

Standard pollution

prevention measures

adequate to protect


decommissioning





N/A N/A N/A

N/A

Qualifying species:

Sea lamprey River lamprey Twaite shad

Refer to

Appendix A No effect No effect No effect

Conclusion No Likely Significant Effect No Likely Significant Effect No Likely Significant Effect No Likely Significant Effect N/A


25

9 References

Design Manual for Roads and Bridges (DRMB) (2007), Volume 11, Section 3, Part 1, HA 207/07 – Air

Quality, Highways Agency.

European Commission (2000) Managing Natura 2000 sites: the provisions of Article 6 of the Habitats

Directive 92/43/EEC.

Institute of Air Quality Management (IAQM) (2014) Guidance on the assessment of dust from demolition and

construction.

JNCC (2001) Severn Estuary SPA Description and Citation. http://jncc.defra.gov.uk/default.aspx?page=2066

JNCC (2008) Severn Estuary Ramsar Site Information Sheet and Citation.

http://jncc.defra.gov.uk/pdf/RIS/UK11081.pdf

JNCC (2015) Severn Estuary Citation.

http://jncc.defra.gov.uk/protectedsites/sacselection/sac.asp?EUCode=UK0013030 and Natura 2000 standard

data form for the site: http://jncc.defra.gov.uk/protectedsites/sacselection/n2kforms/UK0013030.pdf

Natural England (2015) Site Improvement Plan Severn Estuary

Natural England (9 March 2017) Evidence review of the impact of solar farms on birds, bats and general

ecology (NEER012) 1st edition.

Natural Recourses Wales (accessed 2016)

http://publications.naturalengland.org.uk/category/4582026845880320 accessed 04/08/16.

SI 2017/1012 (2017): Explanatory memorandum to the Conservation of Habitats and Species Regulations.

Udall-Martin Associates Ltd (September 2017) Ground-nesting Bird Surveys

Udall-Martin Associates Ltd (December 2017) Preliminary Ecological Appraisal

Welsh Assembly Government (October 2006) Annex to Technical Advice Note 5: Nature conservation and

planning. The Assessment of Development Plans in Wales Under the Provision of The Habitats Regulations’.


26

European sites pressures/ threats


27

Site Name Qualifying Features Pressures/Threats

Severn

Estuary SPA

This site qualifies under Article 4.1 of the Directive (79/409/EEC) by supporting populations of European

importance of the following species listed on Annex I of the Directive:

Over winter: Bewick’s swan (Cygnus columbianus bewickii)

This site also qualifies under Article 4.2 of the Directive (79/409/EEC) by supporting populations of European

importance of the following migratory species:

On passage: Ringed Plover (Charadrius hiaticula)

Over winter:

Curlew (Numenius arquata)

Dunlin (Calidris alpina alpine)

Pintail (Anas acuta)

Redshank (Tringa totanus)

Shelduck (Tadorna tadorna)

Assemblage qualification: A wetland of international importance.

The area qualifies under Article 4.2 of the Directive (79/409/EEC) by regularly supporting at least 20,000

waterfowl.

Over winter, the area regularly supports 93,986 individual waterfowl (5 year peak mean 1991/2 - 1995/6)

including: Gadwall (Anas strepera), Shelduck, Pintail, Dunlin, Curlew, Redshank, Bewick's Swan, Wigeon (Anas

penelope), Lapwing (Vanellus vanellus), Teal (Anas crecca), Mallard (Anas platyrhynchos), Shoveler (Anas

clypeata), Pochard (Aythya farina), Tufted Duck (Aythya fuligula), Grey Plover (Pluvialis squatarola), White-

fronted Goose (Anser albifrons albifrons), Whimbrel (Numenius phaeopus).

1. Public Access/Disturbance - Public access and recreation (including third party activities) may have an impact on bird species

sensitive to disturbance, causing displacement from feeding, roosting and moulting areas, and if severe could affect long term

survival and population numbers and distributions within the Estuary. There are a wide range of recreational activities within the

site (walking, dog walking, horse riding, biking, beach activities, angling, wildfowling, other shooting (e.g. clay pigeon)) that may

cause damage to habitats where pressure is high.

Features affected: Bewick's swan, Common shelduck, Gadwall, Dunlin, Common redshank, Greater white-fronted goose,

Estuaries, Reefs, Atlantic salt meadows, Waterbird assemblage

2. Physical Modification - Modification to water courses and barriers to Annex II migratory fish (and those included in the fish

assemblage) in the tributary rivers* are preventing completion of the life cycle and potentially altering the hydrodynamics of the site.

This includes existing structures and operations (bridges, power station lagoons, jetties, dredging, flood alleviation) influencing the

flow of water, sediments and therefore migration.

*Actions for tributary rivers which are designated as SACs will be detailed in Site Improvement Plans (England/cross-border) or

Prioritised Improvement Plans (Wales).

Features affected: Sea lamprey, River lamprey, Twaite shad

3. Impacts of Development - Strategic planning issue. More rigorous assessment of cumulative, in-combination and offsite impacts

(drainage, disturbance, runoff, impacts on managed realignment etc) on sensitive bird species and other habitats and species may

be required, given the range of planned development within and adjacent to the Estuary (including residential, transport, energy

and other industrial developments).


Estuaries, Intertidal mudflats and sandflats, Reefs, Atlantic salt meadows, Sea lamprey, River lamprey, Twaite shad, Waterbird

assemblage

4. Coastal Squeeze - As sea levels rise, man-made defences are constraining the natural roll back of estuarine habitats, causing

squeeze and loss of habitat and having impacts on species dependent upon those habitats (birds: feeding/ roosting, and fish:

feeding/ nursery and shelter areas).


Estuaries, Intertidal mudflats and sandflats, Reefs, Atlantic salt meadows, Waterbird assemblage

5. Change in Land Management - Changes in management and use of grassland and saltmarsh habitat within and bordering the

estuary. Changes in ownership and other land practices can result in changes in management and use of land (e.g. changes in

grazing practice) which affects species composition, habitat availability, and quality of saltmarsh habitats and use of land for other

activities that may cause damage or disturbance.


Estuaries, Atlantic salt meadows, Waterbird assemblage

6. Changes in Species Distributions - There is a risk of significant changes in estuarine populations (including declines in some

SPA bird populations) in parts of the Estuary resulting from climate change and other man-made and natural modifications to on-

and offsite environments. In many cases the causes of the changes to species distribution are unknown.

Features affected: Bewick's swan, Common shelduck, Gadwall, Dunlin, Common redshank, Greater white-fronted goose, Reefs,

Sea lamprey, River lamprey, Twaite shad, Waterbird assemblage

7. Water Pollution - There is uncertainty over water quality in the Estuary due to diffuse (including agricultural) or direct pollution (e.g.

industrial, sewage treatment works, thermal, radioactive). There is a requirement for better understanding of water and sediment

quality issues. The Severn River Basin Management Plan identifies that 17 % of the estuarine water bodies in the river basin district

currently achieve good ecological status while the others are at moderate status. Macrophytobenthos (benthic macro algae) have

been identified in localised hotspots and may be having adverse impacts on the invertebrate communities there. The extent of

issues like this, the presence and mobilisation of a range of contaminants and reasons behind the moderate statuses need to be

understood. This includes analysis of current data and consideration of potential issues with contaminants in sediment.

Severn

Estuary

Ramsar Site

Ramsar criterion 1:

Due to immense tidal range (second-largest in world), this affects both the physical environment and biological

communities.

Habitats Directive Annex I features present include:

H1110 Sandbanks which are slightly covered by sea water all the time.

H1130 Estuaries.

H1140 Mudflats and sandflats not covered by seawater at low tide.

H1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae).

Ramsar criterion 3:

Due to unusual estuarine communities, reduced diversity and high productivity

Ramsar criterion 4:

This site is important for the run of migratory fish between sea and river via estuary. Species include Salmon

(Salmo salar), sea trout (S. trutta), sea lamprey (Petromyzon marinus), river lamprey (Lampetra Fluviatilis), allis

shad (Alosa alosa), twaite shad (A. fallax), and eel (Anguilla Anguilla). It is also of particular importance for

migratory birds during spring and autumn.

Ramsar criterion 5:

Assemblages of international importance:


70,919 waterfowl (5-year peak mean 1998/99-2002/2003)

Ramsar criterion 6 – species/populations occurring at levels of international importance:

Qualifying Species/populations (as identified at designation):



28

Site Name Qualifying Features Pressures/Threats

Tundra sawn (Bewick’s swan)

Greater white-fronted goose (Anser albifrons)

Shelduck

Gadwall (Anas strepera Strepera)

Dunlin

Redshank

Species/populations identified subsequent to designation for possible future consideration under criterion 6.

Species regularly supported during the breeding season:

Lesser black-backed gull (Larus fuscus graellsii)

Species with peak counts in spring/autumn:

Ringed plover


Eurasian teal (Anas crecca)

Northern pintail (Anas acuta)

Ramsar criterion 8:

The fish of the whole estuarine and river system is one of the most diverse in Britain, with over 110 species

recorded. Salmon, sea trout, sea lamprey, river lamprey, shad, twaite shad and eel use the Severn Estuary as

a key migration route to their spawning grounds in the many tributaries that flow into the estuary. The site is

important as a feeding and nursery ground for many fish species particularly allis shad and twaite shad which

feed on mysid shrimps in the salt wedge

Features affected: Bewick's swan, Common shelduck, Gadwall, Dunlin, Common redshank, Greater white-fronted goose, Subtidal

sandbanks, Estuaries, Intertidal mudflats and sandflats, Reefs, Atlantic salt meadows, Sea lamprey, River lamprey, Twaite shad,

Waterbird assemblage

8. Air Pollution: Impacts of Atmospheric Nitrogen Deposition - Activities around the Estuary include fertiliser application,

potentially dairy and poultry production, road traffic, industry (including power stations), and shipping which are all sources of

nitrogen pollution. Nitrogen deposition exceeds site relevant critical loads, with potential impacts on vegetation structure and

diversity.

Features affected: Gadwall, Estuaries, Atlantic salt meadows, Sea lamprey, River lamprey, Twaite shad, Waterbird assemblage

9. Marine Consents and Permits: Minerals and Waste - The cumulative impacts of aggregate extraction, maintenance dredging

and disposal can have adverse impacts on features. While most activity is regulated under marine licences, cumulative effects are

not always fully considered.

Features affected: Subtidal sandbanks, Intertidal mudflats and sandflats, Reefs, Atlantic salt meadows, Sea lamprey, River

lamprey, Twaite shad

10. Fisheries: Recreational Marine and Estuarine - ACTION FOR ENGLISH PART OF SITE ONLY: Further information is required

on the levels and location of activity and potential impact of recreational bait digging and recreational fishing/angling. There are

unknown impacts in the vicinity of potentially sensitive roosting and feeding areas, and on intertidal reef habitats. This issue will be

reviewed in consultation with the Devon & Severn IFCA in the future.

Features affected: Bewick's swan, Common shelduck, Gadwall, Dunlin, Common redshank, Greater white-fronted goose, Intertidal

mudflats and sandflats, Reefs, Atlantic salt meadows, Sea lamprey, River lamprey, Twaite shad, Waterbird assemblage

11. Fisheries: Commercial Marine and Estuarine - ACTIONS FOR ENGLISH PART OF SITE ONLY: Dredges (inc. hydraulic), benthic

trawls and seines are categorised as ’red’ for the reef features (specifically the sub-feature Sabellaria spp. reef) as part of Defra’s

revised approach to commercial fisheries management in European Marine Sites (EMS). A bye-law is now in place to address this

and is being implemented by Devon & Severn IFCA (D&S IFCA).

Commercial fishing activities categorised as ‘amber or green’ under Defra’s revised approach to commercial fisheries in EMSs

require assessment and (where appropriate) management. This assessment will be undertaken by D&S IFCA. For activities

categorised as ‘green’, these assessments should take account of any in combination effects of amber activities, and/or appropriate

plans or projects, in the site

Features affected: Bewick's swan, Common shelduck, Gadwall, Dunlin, Common redshank, Greater white-fronted goose, Intertidal

mudflats and sandflats, Reefs, Atlantic salt meadows, Sea lamprey, River lamprey, Twaite shad, Waterbird assemblage

12. Invasive Species - There are recent reports of marine invasive non-native species (the Australian barnacle Austrominius modestus,

Mitten crab Eriocheir sinensis, and the Pacific Oyster Crassostrea gigas) in the Estuary (or the Bristol Channel). These could have

an impact on native species and habitats but the abundance and impact in the Severn Estuary of these species is unclear

Features affected: Estuaries, Intertidal mudflats and sandflats, Reefs, Atlantic salt meadows

13. Marine Litter – The marine environment is a sink for man-made litter which often originates from rivers. Impacts are not fully

understood.


Estuaries, Intertidal mudflats and sandflats, Reefs, Atlantic salt meadows, Sea lamprey, River lamprey, Twaite shad, Waterbird

assemblage

14. Marine Pollution Incidents - Marine pollution incidents and responses to such incidents have the potential for significant negative

impacts on the site and its features. Emergency planning and implementation (ensuring an estuary-wide plan is in place, with all

necessary partners signed up) are key to avoiding/reducing such impacts.

Features affected: Bewick's swan, Common shelduck, Gadwall, Dunlin, Common redshank, Greater white-fronted goose, Subtidal

sandbanks, Estuaries, Intertidal mudflats and sandflats, Reefs, Atlantic salt meadows, Sea lamprey, River lamprey, Twaite shad,

Waterbird assemblage

Severn

Estuary SAC

Annex I habitats that are a primary reason for selection of this site:

1130 Estuaries

1140 Mudflats and sandflats not covered by seawater at low tide

1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae)

Annex I habitats present as a qualifying feature, but not a primary reason for selection of this site:

1110 Sandbanks which are slightly covered by sea water all the time

1170 Reefs

Annex II species that are a primary reason for selection of this site:

1095 Sea lamprey

1099 River lamprey

1103 Twaite shad

Annex II species present as a qualifying feature, but not a primary reason for site selection:

Not applicable.










29

Figures

Figure 1: Site layout

Total Power = 8983.2 kWZone 1 = 200.64 kWZone 2 = 839.04 kW

Zone 3+4 = 72.96 kW

Mud

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Compound

48 Charlotte StreetLondon, W1T 2NSTel: 0203 7010381

Email: [email protected]: www.SOLRAC.co.uk

TOTAL POWER:

No. of MODULES:

MODULE POWER:

INVERTERS:

No. of CCTV:

NOTES:

PROJECT DETAILS

DESIGN KEY

C SOLRAC Ltd

Gates:

PROJECT:

DESCRIPTION:

DRAWING No.

DRAWN by:

CHECKED by:

APPROVED by:

Date:

ISSUE:

SCALE:

Lamby Way

Site Layout Plan

LAM-DWG002

Davide Orio

Carlos Javier

Carlos Javier

10/01/2019

V1

1:1250 @ A1

Lamby WayUnnamed Road,Rumney, CardiffCF3 2HP

8,746.08 kWp (DC)

30,688

285Wp

120x60kVA@25CTotal 7,200kW (AC)

2

39

AutoCAD SHX Text

9.385

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9.056

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Manifold 6

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9.123

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9.160

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9.506

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9.450

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9.067

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9.521

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MH

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9.221

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9.371

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9.670

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Manifold 5

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9.066

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9.532

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9.525

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MH

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8.681

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9.099

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Manifold 2

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Manifold 1

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GENERATOR No. 4

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ACCESS GATES

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TANK

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DIRTY OIL

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GENERATOR No. 2

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GENERATOR No. 3

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CLEAN OIL

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178000N

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Revision/Issue

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30

Figure 2: Designated sites

WentloogIndustrial

Park

Lamby SaltMarsh

Pengam Moors

Rhymney RiverValley Complex

Lamby Way

Lamby North

River Rhymney

RhymneyGrassland

East

RoathBrook

Howardian

Gwent Levels- Rumney And

Peterstone

SevernEstuary

Contains OS data © Crown Copyright and database right 2018

Site Boundary2km BufferSevern Estuary SPASevern Estuary SACSSSISINCLocal Nature ReservesSevern Estuary Ramsar site

K:\Environmnet UK_GIS\10025418 - Lamby way\D. Mxd (Drawings)\0001-10025418-P01-UE31-Lamby Way HRA Report.mxd © Copyright reservedPrint Date: 11-02-18 15:19:3050mm on Original

Revision:Drawing Number:0001-10025418-P01-UE31-DESIGNATED SITES P01

Suitability Description:FOR INFORMATION

Datum:

Grid:

Drawn M.SHETYEChecked L.TURLEYApproved S.SIMONSScale:Original Size: A3Suitability Code: S2

Signed

Signed

Signed

Project Number:

AODOS10025418

Date02NOV18Date02NOV18Date02NOV18

TITLE:

Figure 2: Designated sites

Client

SiteLamby Way, Rumney,Cardiff

CITY OF CARDIFF COUNCIL

Client

PROJECT:

LAMBY WAY

City Of Cardiff Council, County Hall, CardiffCF10 4UW

DescriptionDateRevP01 FIRST ISSUE MS

Drawn

LT SS

Check Approv

02/11/18

LEGEND:

0 500 m

1:15,000

1:15,000

www.arcadis.com

Registered office:Arcadis House34 York Way, London N1 9AB

Coordinating office:5TH Floor,401 Faraday Street,WarringtonWA3 6GA

Arcadis Consulting (UK) Limited

The Mill

Brimscombe Port

Stroud

GL5 2QG

United Kingdom

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