Buttington Quarry - ERF
From National Trust
National Trust (NT) is Wales’ largest private landowner and proud to care for 46,000 hectares of land, 157 miles of coastline and 18 of the nation’s finest castles, houses, gardens, and industrial sites. With the support of our staff and volunteers, more than 1.8 million visitors enjoy our places in Wales every year. We place great importance on the conservation, management, and enjoyment of the natural and historic environment both within and beyond our boundaries.
The environment needs us now more than ever and we are making landscape-scale improvements for nature and playing our part to tackle climate change. We are committed to becoming carbon net zero by 2030, restoring and creating 4,600 hectares of priority habitat by 2025 to reverse the decline in wildlife and taking a bigger, better and joined-up approach to nature conservation and for all of our land to be of high nature status. As a conservation charity, it is our responsibility to look after special places and ensure that they are accessible for future generations, as well as those visiting right now.
We welcome the opportunity to comment on the proposed Energy Recovery Facility (ERF) in Buttington.
National Trust own and manage Powis Castle on behalf of the Nation. The Castle and Garden was bequeathed to NT on the death of Lord Powis in 1952.
There was a castle on the site by the 13th century, with earliest references to a park and garden dating to the 16th century. Externally the castle has changed little since the early Middle Ages. The castle constitutes four separate Grade 1 listed buildings, and the Park and Garden also Grade 1. The terraces at Powis date back to 1700 and described by NT Head of Gardens in Wales as “one of the best surviving Italian terrace gardens in Europe” and by CADW as “to be the finest surviving Baroque late seventeenth/early eighteenth century garden terraces in the United Kingdom”. The proposed Buttington ERF will be seen from the terrace and castle, with key views to and from the East Front at Powis.
The earliest cartographic evidence for the East Front at Powis is dated to 1629 and shows the castle at that date as a square structure with a bailey to both east and west. The eastern bailey is defined by a substantial wall with towers flanking a potential gateway to the east. Drawn views of the east front dating to 1684 suggest that major alterations to this approach to the castle have taken place, with a series of formal gated enclosures and stairways leading to the main east entrance to the castle itself. A raised terrace is also evident.
By 1752 the raised terrace, the steps, and the enclosure now known as the bowling green, are in place on a measured plan essentially as seen today.
The importance of the landscape and heritage setting of the terraces at Powis Castle was recognised in the deliberations of the application and Appeal (Extension to Existing Dairy at Lower Leighton Farm) (APP/T6850/V/12/2169855). Para 208 of the Inspectors decision relates to the setting of Powis Castle “Over 100,000 people would potentially experience this view each year and the fact that this would be a key part of most people’s visits to Powis Castle gardens makes this a highly sensitive location. The assessment of sensitivity made by the applicant’s landscape and heritage witness seems unable to give any weight to the huge numbers of people affected from this viewpoint”.
Landscape, Visual Impact and Heritage setting issues
National Trust consider that the submitted scheme underestimates the level of landscape, visual and heritage harm at Powis Castle.
Section 6.9.1. of the Landscape and Visual Impact Assessment (LVIA) provides one viewpoint (Location 24) from Powis Castle stating “the architectural and scenic merits of Powis Castle and its gardens hold the viewer to scrutinise close range views rather than the available distant backdrop. Thus, the property itself is the key feature. The background composition is an important character facet, but the sensitivity of these areas is subservient to the overall Powis Castle estate”. This is a wholly inadequate assessment of the role of long-distance views in the setting of the Grade 1 listed building and Grade 1 Registered Park and Garden. This conflicts with all evidence submitted to the Leighton Farm Dairy public inquiry whereby all parties recognised the significance of long-distance views to and from Powis Castle.
Section 12.4.19 of the Environmental Statement (Heritage) states in relation to Powis Castle “the castle and gardens are surrounded by fields and woodland, particularly to the north-east. Far to the north-east lies Welshpool which blocks any intervisibility between the castle and gardens and the Development Site. Consequently, there will be no effect and no further assessment is required”. Photographs taken from the Bowling Green below the East Front terrace, show how the development site is clearly visible to and from Powis Castle.
An article in Country Life magazine from January 5th, 1901 states that the terraces ‘...command surpassingly beautiful views, the most delightful of all being through a long vista of trees to the distant peaks of Moel-y-golfa and the Breidden Hills.’
The Conservation Management Plan for Powis Castle and Garden identifies key views from the property including the view from East front towards the development site.
We would suggest that several additional/alternative viewpoints are required including: the end of the East Terrace adjoining the sculpture, the easterly view from the Bowling Green terrace on the east front and from the lower bowls lawn terrace. Views of the scheme will also be possible from the Castle East Front porch at higher level and also from all floors and roof of the Castle on the East Front.
The magnitude of impact in the LVIA states that during construction the impact would be ‘Small (generally) Medium (worst case scenario). National Trust challenge this conclusion in the absence of any consideration of cranage and lighting. We consider these will bring forward Medium to Large effect considering the open views obtained from the East Front and also considering that Powis Castle is a Very High Receptor.
During Operation, the LVIA states that the Impact would be ‘Small’. Although the building structure may be partially obscured and ‘Small’, the visibility of the Plume from the stack would be visible during operation and could be Medium to Large, again considering the open views to the wider landscape of the Powis site and also the higher ground that it sits on.
A more accurate and considered LVIA may result in a change to the overall significance of effect. The lack of recognition in the role of long-distance views at Powis Castle undermines the confidence in the conclusions it makes with regards to harm on heritage assets.
National Trust consider that a revised assessment is required, and the conclusions incorporated into a revised Heritage Assessment.
At the current time the submitted application makes no attempt to consider setting issues associated with heritage assets at Powis Castle. Attention should be given to the Inspectors conclusions (paras 372-382 Appeal Ref APP/T6850/V/12/2169855) in relation to Powys castle, para 372 stating “when considering the impact of a proposed development on the setting of a heritage asset, the recent High Court judgement in East Northamptonshire Council, English Heritage and National Trust v SSCLG and Barnwell Manor Wind Energy Ltd  EWHC 47389 has given a timely reminder that decision takers should consider the significance of the asset and the contribution that the setting makes to that significance. The effect of the proposed development on the setting should then be considered and evaluated, as should the impact on the significance of the asset and the appreciation of that significance”.
National Trust requests the applicant gives further consideration and assessment of this issue.
Stack height and plume assessment
National Trust consider that the stack height and plume visibility will have important implications for concluding the level of harm from long distance views to and from Powis Castle.
We would note that this issue will also be determined by a separate Environmental Permit from NRW.
Section 6 of the submitted Air Quality Assessment confirms that the plume from the proposed 70m stack will be around 107m for 5% of the time. The submission also indicates that the plume will be within the site boundary for 95% of the time (no length confirmed), the submission provides a graphic illustrating average plume visibility (no length or % time is provided). The assessment concludes that plume visibility is not significant, and no mitigation is provided within the scheme.
Section 4.19 of the Heritage Statement in relation to visible plume states “it is acknowledged that this has the potential to heighten the visibility of the stack and therefore the development in a wider landscape context”.
National Trust note third party comments relating to the uncertainty in topography in concluding that a 70m stack would bring forward the required air quality and health issues. We await commentary from NRW on the scheme and confirmation that the air quality modelling and results/conclusions provided within the application are sufficient and reliable for the purpose of considering whether planning permission should be granted for a 70m stack?
The location of the 70m stack and associated plume is at the centre of the long-distance view from the Bowling Green terrace at Powis Castle, and from the eastern elevation of the castle. National Trust would note that this has not been assessed within the submitted Landscape and Visual Impact Assessment, with wholly inadequate conclusions made at the outset of the submission with regards to the significance of long-distance views to the setting of the property. The submitted Heritage Assessment acknowledges the potential role of a visible plume to heighten the visibility of the stack but does not consider that the site is visible from Powis Castle. Might there be any colour issues associated with the visible plume?
We would wish to see further consideration of this issue with further viewpoints, and an updated Table 6-8 (page 6-33) with regards to the Interactive Effects of Air Quality and Landscape. We consider a modified Heritage Assessment should be submitted incorporating new Viewpoints from Powis Castle and including consideration of the effects of visible plume and stack height.
We would also suggest that mitigation should be considered within the submission, and if required an off-site landscape scheme brought forward.
We wish to revisit this issue further following the response from NRW.
National Trust wishes to raise the following issues:
• The scheme underestimates the level of landscape, visual and heritage harm from Powis Castle, additional work should be completed to that provided in the submission relating to Viewpoint 24 including the content of the Conservation Management Plan Key Views.
• Additional viewpoints should be taken from Powis Castle East Front to inform the submitted LVIA and Heritage Assessment and consider winter and summer seasonality for long distance views.
• Construction CGIs for the scheme should be prepared.
• Assessments and CGIs regarding impacts at the construction phase and operational phase for night-time, together with the consideration of issues at dawn and dusk.
• Assessment of lighting levels, fittings, quantity, area of illumination, assessment of viewpoint sensitivity. Further information is required within the submission to establish the principle of an acceptable scheme on long distance landscape and visual harm. Mitigation through either downlighting, point lighting or no lighting will be eliminated or reduced should be consider within the scheme, prior to acceptance that details could progress by planning condition.
• Information on any resilience funding/off site landscape fund available for visual mitigation in the future.
• Although colour schemes for the building have been produced, was an Environmental Colour Assessment (ECA) undertaken to aid the integration of the building into the landscape. Link to the Landscape Institute note here: https://landscapewpstorage01.blob.core.windows.net
Thank you for your consideration.