1

Electricity Act 1989: Section s36

Town and Country Planning Act 1990: Section 90

Electricity Works (Environmental Impact Assessment) (England and

Wales) Regulations 2000

Electricity Generating Stations and Overhead Lines (Inquiries Procedure)

(England and Wales) Rules 2007

Application by RWE Innogy UK Limited for a 150 MW wind farm and habitat restoration

at Carnedd Wen

Conjoined Public Inquiry (Session 4)

Matters in Common/Cumulative Effects

PROOF OF EVIDENCE:

TRANSPORT (Strategic)

Stuart Atkinson B.Sc(Hons) CEng MICE MCIHT MAPM

of Stuart Michael Associates

________________________________________

25 February 2014

2

CONTENTS

Page

1.0 INTRODUCTION

1.1 Qualifications, Experience and Instructions 3

1.2 Scope and Content of Evidence 4

2.0 STRATEGIC TRANSPORT CONSIDERATIONS

2.1 The Management, Co-ordination and Scheduling of AIL Deliveries 10

2.2 The strategic Traffic Management Plan (sTMP) and Transport Tool 13

2.3 Cumulative Impact Assessment of non-AIL Construction Traffic 17

2.4 Stage 1 Road Safety Audits and sTMP Environmental Assessment 20

3.0 OBJECTORS’ STATEMENTS OF CASE 21

4.0 DRAFT PLANNING CONDITIONS 23

5.0 SUMMARY OF EVIDENCE AND CONCLUSIONS 24

APPENDICES

Appendix 1 – Draft Planning Conditions

SUMMARY PROOF OF EVIDENCE (provided under separate cover)

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1.0 INTRODUCTION

1.1 Qualifications, Experience and Instructions

1.1.1 My name is Stuart Michael Atkinson. I hold a Bachelor of Science Honours Degree

in Civil Engineering (University of Wales, Swansea) and I am a Chartered

Engineer. I am a Member of the Institution of Civil Engineers (ICE), the Chartered

Institution of Highways and Transportation (CIHT) and the Association for Project

Management (APM). I have served as Vice Chairman of the Thames Valley

Association of the ICE and most recently, (2011/2012), I have served as

Chairman of the CIHT’s Thames & Chilterns regional branch. I am a transport

advisor to the Thames Valley Chamber of Commerce (West Berkshire Council).

1.1.2 I have over 30 years experience in transportation and highways, major

infrastructure evaluation and planning, environmental assessment and civil

engineering design (highways, bridges, culverts and retaining structures).

1.1.3 I am a Director and Chairman at Stuart Michael Associates (SMA), an independent

firm of multi-disciplinary consulting engineers, which I established in 1988. SMA

has offices in Berkshire, South Wales and Devon. I am responsible, inter alia, for

the direction and management of the company’s transportation and environmental

group.

1.1.4 In June 2012 I was appointed by RWE Npower Renewables, now RWE Innogy UK

Limited (RWE), to act on its behalf in respect of the transportation and associated

highways and traffic management considerations related to its proposed wind

farm development at Carnedd Wen.

1.1.5 I have previously appeared at this public inquiry on behalf of RWE, during Session

2, when the site specific matters associated with the proposed development at

Carnedd Wen were dealt with.

1.1.6 My instructions in relation to Session 4 of this Inquiry (Transport – Strategic) have

been, and are, with regard to:

i) the ongoing engagement with Officers at Welsh Government

(Transport) and Powys County Council (including its Transport

consultant Vectos) and with the Highways Agency, Welsh Police and

4

West Mercia Police in order to reach agreement upon the common

approach to be taken to scheduling and managing the movement of

Abnormal Indivisible Loads from the proposed ports of entry to the

wind farm development sites;

ii) the wider engagement with the other developers (and their

respective transport consultants) that are involved in the Public

Inquiry, specifically in relation to the preparation of further SEI and

other information for consideration during Session 4;

iii) the ongoing consultations with WG(T) and PCC with regard to any

necessary transport related planning conditions and to seek

agreement on these;

iv) considering and advising upon any additional (new) matters that

may be raised by third parties in evidence that may not have been

covered in the Statements of Case submitted to date;

v) to represent the Applicant, as required, at the Inquiry

1.1.7 The evidence which I have prepared for this public inquiry is true and has been

prepared and is given in accordance with the guidance of my professional

institutions and I confirm that the opinions expressed are my true and

professional opinions.

1.2 Scope and Content of Evidence

1.2.1 This evidence is submitted for Session 4 of the Public Inquiry and addresses the

strategic transport and cumulative construction traffic considerations. This relates

to the Inspector’s and the Secretary of State’s consideration of the relevant

Matter 5:

“5. The individual and combined impact of construction traffic on the

surrounding locality, including transportation access routes and

traffic management, taking into account the cumulative impact with

other wind farms in the Powys area which have already been

granted planning permission or where planning permission has been

applied for;”

5

1.2.2 It is important to note that the individual and local impact of construction traffic

associated with Carnedd Wen (inclusive of site access and construction traffic

management) has been dealt with in Session 2 of the Inquiry.

1.2.3 During Session 2 it was demonstrated and confirmed in evidence that there were

no highways objections to Carnedd Wen raised by either the strategic highway

authority (Welsh Government (Transport)) or by the local highway authority

(Powys County Council), subject to the imposition of appropriate planning

conditions. A Statement of Common Ground was submitted to the Inquiry to

confirm that position.

1.2.4 The Alliance did not challenge the highway authorities or RWE with regards to the

appropriateness of the agreed Carnedd Wen site access arrangements. Whereas

the Alliance had queried some of my estimates of construction traffic for Carnedd

Wen, the Inspector (and other parties present) will have noted that I provided the

clarification sought by the Alliance during my evidence in chief. This was not

disputed in cross examination. It is also relevant, in my view, to be reminded that

the statement of common ground (between WG(T), PCC and RWE for Session 2)

had recorded agreement upon the robustness of my methodology (reference

paragraph 2.2 of the SoCG).

1.2.5 In respect of Session 4 (Matters in Common/Cumulative Effects), the Welsh

Government’s Statement of Case (21 January 2014) advises that:

“WG is satisfied that the potential impact of the Carnedd Wen development

on the trunk road network can be managed in accordance with the

methodology set out in Section 1 to 3 of the sTMP to ensure the safety and

free flow of trunk road traffic.”

1.2.6 WG has proposed that five planning conditions be attached to any grant of

planning permission (discussed later in Section 4.0 of my evidence).

1.2.7 Powys County Council has advised in its Statement of Case for Session 4 that in

relation to Transport (Section 5 of the Statement):

“5.4 The Cumulative Effect, including the sTMP

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5.5 PCC judges that the AIL route from Ellesmere Port to the combined

sites, set out in the sTMP, is reasonable and appropriate subject to

clarifications and Conditions .....

5.6 PCC will seek Conditions requiring a common approach to mitigation

design and implementation, as well as traffic management, between

individual developments utilising the same routes or the same

services.”

1.2.8 RWE is confident that agreement can be reached upon an appropriate set of

transport related Planning Conditions and I comment further upon these in

Section 4.0 of my evidence.

1.2.9 With regard to the topics for consideration during Session 4, it is important to

appreciate that the assessment of construction traffic relates to two distinct and

separate areas of focus.

a) the delivery process and efficient management of the transportation

of wind farm turbine components as Abnormal Indivisible Loads

(AILs), and

b) the cumulative effects of and management of other non-AIL

construction traffic upon the local and strategic road networks.

Supplementary Environmental Information (SEI)

1.2.10 In the first matter (paragraph 1.2.5 a)), various documents have been submitted

to the Inquiry either as SEI or as other information to ensure that all participants

at the Inquiry will have been able to familiarise themselves with the following:

i) the proposed strategic Traffic Management Plan (Sections 1 to 5)

for managing the safe and convenient movement of AILs from

Ellesmere Port to wind farm developments in TAN8 strategic search

areas B and C

(CD-COM-TRA-001)

ii) a Technical review of AIL Routes around Welshpool

(SEI/CUMULATIVE/TRANS/6)

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iii) the Stage 1 Road Safety Audit Reports on the proposed highway

works listed in the sTMP (Sections 2 to 5) that are deemed

necessary to: provide adequate passing places; accommodate AIL

manoeuvres in constrained locations and to minimise delays

(SEI/CUMULATIVE/TRANS/4);

iv) the environmental assessment of the proposed sTMP highway works

(undertaken by Amec on behalf of Renewable UK Cymru)

(SEI/CUMULATIVE/TRANS/8);

Other Information

v) an Agreed Statement on the Delivery Process for Abnormal

Indivisible Loads (AILs)

(CD-COM-TRA-002);

vi) Water Preferred Policy Assessment

(CD-COM-TRA-002).

1.2.11 In the second matter (paragraph 1.2.5 b)), SEI has been submitted comprising

the:

Cumulative Impact Assessment of non-AIL Construction Traffic on the

Strategic Road Network (prepared by Aecom on behalf of the developers)

(CD-COM-TRA-003)

1.2.12 It is understood that Session 4 will include a Hearing Session to consider the

underlying principles of the sTMP, the AIL delivery process and the cumulative

impact analysis of the non-AIL traffic.

1.2.13 My evidence hereafter will have regard to the entirety of the above documents but

draw attention only, where necessary, to the key and salient points associated

with each document.

1.2.14 Extensive consultation with, and participation by, the key transport stakeholders

(trunk road and local road highway authorities, the Police and developers) has

taken place prior to the finalisation and submission of the sTMP (Sections 1-5) to

the Inquiry.

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1.2.15 Similarly to ensure that all interested parties and participants at the Inquiry will

be fully informed of the AIL delivery process, an Agreed Statement has been

prepared and submitted to the Inquiry. This again was preceded by extensive

consultations and engagement with the key stakeholders.

1.2.16 Section 6 of the sTMP is similarly being finalised in relation to route selection,

traffic management and associated highways works to enable AIL deliveries to be

made from Ellesmere Port via Newtown to wind farm developments in TAN8 SSA

C. This does not apply to Carnedd Wen.

1.2.17 The cumulative impact assessment of non-AIL construction traffic has been

prepared by Aecom on behalf of the developers and has had regard to all of the

information that was publicly available prior to its submission to the Inquiry. This

has included a detailed examination of the various Environmental Statements and

SEI transport chapters for each proposed development. Information has been

adduced upon construction programmes and with regard to providing reasonable

estimates of traffic generation and assignment of construction traffic on the

strategic and local highway networks.

1.2.18 The assessment is presented as a spreadsheet based model enabling all of the

wind farm proposals before this Inquiry to be considered in combination with the

currently consented/committed wind farm development (Tirgwynt) and both

exclusively and mutually with other non-Section 36 proposals which are yet to be

determined.

1.2.19 Taking all of the foregoing into account, I propose to cover each of the key

strategic transport topics in Section 2.0 of my evidence.

1.2.20 In section 3.0 I will briefly consider and comment upon the Statements of Case

submitted by the Objectors in so far as there may be issues that may not have

been already covered in Section 2.0.

1.2.21 In Section 4.0 I will refer to the Statements of Case submitted by the Welsh

Government (Transport) and Powys County Council and consider the requirements

and content of any planning conditions that may be necessary in order to ensure

the safe and efficient management of construction traffic associated with Carnedd

Wen.

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1.2.22 My evidence will demonstrate that Matter 5 has been comprehensively dealt with

as evidenced by the extensive consultations that have taken place with the key

stakeholders in relation to the development of the strategic Traffic Management

Plan and the Transport Tool and supported by the Agreed Statement on the AIL

Delivery Process. I consider the cumulative impact analysis has provided a robust

basis upon which the potential effect of non-AIL construction traffic on the

strategic and local road networks can be examined and quantified.

1.2.23 In Section 5.0 I provide a summary of my evidence and conclude that the

Inspector and Secretary of State can be satisfied that the proposed development

at Carnedd Wen, either individually or in combination with other development

proposals, can make adequate provision for the effective management of all

construction traffic such that the impact upon the strategic and local highway

network will generally be slight or neutral in significance.

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2.0 STRATEGIC TRANSPORT CONSIDERATIONS

2.1 The Management, Co-ordination and Scheduling of AIL Deliveries

2.1.1 National Policy Statement (NPS) for Renewable Energy Infrastructure

(EN-3), (July 2011), paragraphs 2.7.80 to 2.7.83, set out guidance on what

mitigation measures may be necessary and how a co-ordinated approach

(applicants working together) can be undertaken to ensure, inter alia, that the

timings and deliveries of abnormal loads will be managed to minimise disruption

to other highways users. The NPS states that this can be achieved through the

active management of delivery schedules through the abnormal load approval

process.

2.1.2 Paragraph 2.7.82 of the NPS advises on the appropriateness of a collaborative

approach amongst applicants and highway authorities:

“2.7.82 Where cumulative effects on the local road network or

residential amenity are predicted as a result of multiple wind

farm developments, it may be appropriate for applicants for

various projects to work together to ensure that the number

of abnormal loads and deliveries are minimised and the

timings of deliveries are managed and coordinated to ensure

that disruption to local residents and other highway users is

reasonably minimised. It may also be appropriate for the

highway authority to set limits for and coordinate these

deliveries through active management of the delivery

schedules through the abnormal load approval process. Once

consent for a scheme has been granted, applicants should

liaise with the relevant local highway authority (or other

coordinating body) regarding the start of construction and

the broad timing of deliveries. It may be necessary for an

applicant to agree a planning obligation to secure

appropriate measures”

2.1.3 I consider the wind farm industry has responded positively and constructively

towards ensuring that the delivery of the large components for the wind farms in

mid Wales can be managed in a co-ordinated way. Renewable UK Cymru acting on

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behalf of its subscribing members has consulted widely on a strategic Traffic

Management Plan (sTMP) for access to areas B & C from Ellesmere Port whilst

some wind farm developers have established other Traffic Management Plans

(TMP) from alternative ports of entry. The intention will be that all of the TMPs

should aim to adopt the same underlying principles including a range of mitigation

measures to facilitate safe and convenient movement of AILs.

2.1.4 It is important to understand the process involved in terms of the notification and

approvals required before AILs are permitted to use the highway network.

Accordingly I have represented the developers’ transport consultants alongside

Mr. David Tucker (for Celtpower) and Mr. Ruari Lean (for Renewable UK Cymru) at

a number of meetings with the Highways Agency’s AIL Team, The Welsh Police,

West Mercia Police and officers of Welsh Government (Transport) and Powys

County Council.

2.1.5 An Agreed Statement on the Delivery Process for Abnormal Indivisible Loads

(dated 29 January 2014) has been submitted to the Public Inquiry (Core

Document: CD-COM-TRA-002).

2.1.6 The Agreed Statement summarizes the procedures and requirements necessary to

ensure that AILs can be transported safely and conveniently along the highway

network. It explains how various criteria need to be met and the important role

that the respective parties will play in the process and the nexus between the

various essential legal and practical requirements to ensure safe passage and

minimal disruption to other road users.

2.1.7 Crucially it explains how the Police will escort the AILs and how this will be

resourced and managed.

2.1.8 The key points relating to the AIL delivery process that I would draw attention to

are that:

i) the route selection, any necessary highways works and traffic

management plans require the prior approval by the relevant

highway authorities before any AIL deliveries can take place

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ii) a communications strategy will be key to ensuring the communities

alongside the delivery routes and the travelling public are kept

informed of scheduled deliveries

iii) a Transport Co-ordinator will be appointed and given the necessary

authority to schedule and co-ordinate delivery slots to each

development and be the main point of contact between the relevant

stakeholders. The TC will manage and update a spreadsheet based

system (Transport Tool) within which delivery slots for AILs to each

development shall be allocated. The delivery slots will reflect the

state of readiness of the developments and be ranked according to

their status (e.g. planning consented, discharge of conditions

completed, grid connections confirmed) and prioritised accordingly.

(Appendices 1 and 2 of the Agreed Statement).

iv) there is a legal requirement for seeking the approval and

authorisation (by the Highways Agency’s AIL Team) for any

proposed AIL movement; the HA in turn consults with the relevant

highway authorities and Police prior to any AIL deliveries being

undertaken to ensure that access onto the highway network at the

appointed time of delivery is free from constraint

v) the Police will be setting up an AIL Escort Unit for supporting the

multiple AIL movements anticipated in mid Wales; the manner in

which the AILs are escorted will be at the ultimate discretion of the

Police and will have regard to the following:

- All AIL convoys to the mid Wales wind farms shall be

undertaken under Police escort and will include command

vehicles and motor cycle outriders

- Only 1 AIL Convoy per day to any wind farm development will

be permitted whether it originates from a port of entry to the

north or south

- The general aim by the Police will be to keep the AIL convoy

moving, without stopping, as far as traffic conditions and road

safety permit; passing places will be used when required to

minimise delays to the travelling public

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- In the event of emergencies Police will temporarily move the AIL

convoy off the road and hold in a passing place.

2.1.9 In respect of cumulative effects, these will not arise in terms of the movement of

AILs. Only one AIL convoy will travel to a selected wind farm development on any

particular day. There will not be multiple AIL movements made to more than one

development at any time.

2.1.10 AIL deliveries for Carnedd Wen are not anticipated to commence until Quarter 20

(Table 14.6 of SEI 2013), which assuming a start on site in 2016 would be during

2020. It is reasonable to assume that both Tirgwynt and Llanbrynmair could be

operational before then.

2.1.11 During the periods of the day when AILs are delivered to Carnedd Wen, other

construction materials deliveries will be suspended.

2.2 The strategic Traffic Management Plan (sTMP) and Transport Tool

2.2.1 The sTMP has been developed on behalf of Renewable UK Cymru in order to

manage the delivery of AILs to potential wind farms in mid Wales. The underlying

principles and details have been developed following extensive consultation within

the renewable energy industry and externally with the Police and highway

authorities in Wales and England. This has included stakeholder workshop

meetings in July and September of 2011 and the circulation of draft versions of

the document (for comment) through to September 2012. It is structured such

that it can be applied to all potential wind farm developments located in Strategic

Search Areas B and C that will use Ellesmere Port as the port of entry for their

turbine components.

2.2.2 Sections 1 to 5 of the sTMP (Core Document reference: CD-COM-TRA-001) have

been approved by the trunk road authorities and Powys County Council. A further

Section 6 to the sTMP deals with the management and routeing of AILs to SSA

Area C, south of Newtown, and is being consulted upon.

2.2.3 The key guiding principle in the selection of the strategic route for AIL deliveries

has been to focus movements principally upon trunk roads. These all purpose

highways form part of the national strategic road networks in Wales and England

and are recognised as being capable of accommodating AIL deliveries with

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appropriate traffic management. With the exception of relatively short sections of

the overall strategic route, at Welshpool town centre and at Ellesmere Port, the

recommended AIL route for deliveries to Carnedd Wen would be entirely upon the

trunk road network.

2.2.4 Section 1 of the sTMP provides an overview upon the key considerations (for

example: route assessment, convoy size, traffic management, highways

improvements, communications strategy etc.) and demonstrates how the sTMP

has been structured to deal with the management of Abnormal Indivisible Loads

(AILs) upon various parts of the strategic (motorways and trunk roads) and local

highway network.

2.2.5 The sTMP is a management plan concerned only with the movement of AILs.

Separately each developer will be responsible for the management of other

construction traffic. Site specific construction management plans are likely to be

required by planning condition.

2.2.6 The key components of the sTMP are set out in Section 1 of the document and

deal with, for example:

a) route selection and the identification of any consequential

requirements for highways modifications and structural

assessments in order to accommodate the movement of the AIL

convoy (passing places and overnight parking at layover areas)

b) the timing of convoy movements and scheduling of these to be

undertaken during daylight hours and to avoid peak periods,

specifically at Newtown and Welshpool town centres

c) the arrangements for police escorts and traffic management

incorporating the provision of a sufficient number of passing places

to allow the travelling public to pass the convoy and to ensure, for

the most part, that any delays do not exceed 10 minutes

d) the requirements for a public awareness campaign to inform local

communities and the travelling public of scheduled deliveries

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e) the requirements for the environmental assessment and road safety

audits of the proposed sTMP highway works.

2.2.7 The sTMP overview report (Paragraph 3.2.4 of Section 1) refers to previous

studies that were undertaken for Welsh Government and that these had

recommended Ellesmere Port as a preferred port of entry to SSA B and C. It is

stated that the selection of Ellesmere Port, being the nearest port of entry to the

destination, would be compliant with the Highways Agency’s Water Preferred

Policy.

2.2.8 This has been confirmed in the WPP assessment that has been undertaken by

David Tucker Associates on behalf of Renewable UK Cymru. A copy of this has

been submitted to the Inquiry.

2.2.9 Sections 2 to 5 deal with specific sections of the strategic and local highway

network that will be utilised by the AIL convoys. These sections provide more

detail upon where any highways modifications will be required, where specific

traffic management measures will be implemented and also provide estimates of

AIL journey times.

2.2.10 Passing places have been proposed at locations along each route and spaced to

ensure any opposing queuing traffic (held up by the Police) should not be delayed

by more than 10 minutes. Convoy speeds are likely to be, on average, 30mph on

A-class roads and 20mph on minor roads with the exception that slower speeds

will be necessary at tight bends and where manual rear wheel steering is

required. On dual carriageways and motorways it is likely that the convoy will be

able to travel up to 40mph. Where safe to do so, light goods vehicles and cars will

be able to overtake the convoy. Oncoming traffic on dual carriageways will not be

affected by the convoy.

2.2.11 It is relevant to note that, in any event, there are existing speed limits along the

AIL delivery routes that apply to all motorists and delivery vehicles. Consequently

in those situations where vehicles will be following the AIL convoy at 30mph or

40mph, as directed by the speed limit, there should be no significant delay.

2.2.12 Section 1 to 3 of the sTMP are of direct relevance to the Carnedd Wen

development and have been submitted as SEI. Sections 2 and 3 deal with the

trunk road corridors and local highways that will be commonly shared by

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abnormal load deliveries to the Mid Wales wind farm proposals in Strategic Search

Areas B (north) and C. Section 2 deals with the route from Ellesmere Port to

Welshpool. Section 3 deals specifically with the route through Welshpool town

centre and along the A458 trunk road to Carnedd Wen and to other potential wind

farms to the west of Welshpool. Figures 2.1 and 3.1 of the sTMP provide maps of

these routes.

2.2.13 Of the proposed developments being examined at this Inquiry: Carnedd Wen,

Llanbrynmair and Llanbadarn Fynydd would utilise the strategic AIL route from

Ellesmere Port to Welshpool. This is similarly the case for Tirgwynt (previously

consented but not yet implemented). Whereas AIL deliveries to Llanbadarn

Fynydd would continue south along the A483 to Newtown, the AIL deliveries to

Tirgwynt , Llanbrynmair and Carnedd Wen would turn westwards and travel

through Welshpool town centre and onwards along the A458 trunk road (Section 3

of the sTMP).

2.2.14 Welsh Government (Transport) and Powys County Council have approved the

route through Welshpool town centre as being suitable for AIL deliveries and

construction traffic. This corridor is 0.8 miles (1.29km) long from the railway

station roundabout to the Raven Inn roundabout (at the western end of

Welshpool).

2.2.15 It is a relatively wide corridor flanked by commercial, retail and residential

development. The western section (Broad Street, High Street, Mount Street) is

trunk road (A458). The eastern section (0.4 miles / 0.53km) is along the B4831

county road extending from the A483 over the canal to the traffic signal controlled

junction at Berriew Road and Church Street. There are no weight restrictions and

although classified as a B-class county road, Powys County Council had previously

sought to upgrade this corridor to trunk road status.

2.2.16 During the respective construction periods for Tirgwynt, Carnedd Wen and

Llanbrynmair only one AIL convoy will pass through Welshpool town centre on any

one particular day. Moving at an average speed of 20mph, the AIL convoy would

take only 2.4 minutes to travel from the railway station roundabout to the

western end of Welshpool (The Raven Inn) and less than 5 minutes if travelling at

a speed of 10mph.

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2.2.17 Other options for alternative AIL routes around Welshpool were previously

examined by Capita Symonds (for WG) and Arup (for RWE). A more recent review

has been undertaken (on behalf of Renewable UK Cymru and the developers) and

this has been reported upon and submitted to the Inquiry (Document reference:

SEI/CUMULATIVE/TRANS/6):

“Technical Review of Alternative AIL Routes around Welshpool (January

2014)

2.2.18 The review has highlighted the significant constraints that alternative routes

around Welshpool would present to AIL convoys and consequently reaffirms the

appropriateness of the route through Welshpool town centre.

2.2.19 The proposed site access to Carnedd Wen is situated on the A458(T) some 20.5

miles from the western side of Welshpool (The Raven Inn roundabout). The route

from here is entirely along a trunk road. It is rural in character with little

development frontage other than at Llanfair Caereinion, Llanerfyl, Llangadfan and

Foel. There are speed limits of 30mph at Llanfair Caereinion and 40mph at

Llanerfyl, Llangadfan and Foel.

2.2.20 Welsh Government (Transport) is the highway authority responsible for the

maintenance of the A458 trunk road. Between Welshpool and Mallwyd the

highway authority has, during the past 8 years, carried out various maintenance

and road safety schemes. It continues to monitor road accidents and undertake

accident remedial investigations.

2.2.21 In various locations road safety has been improved by enhancing visibility,

realigning bends, laying high friction surfacing (HFS), providing additional signage

(warning signs and chevron boards) and road markings (“Slow” and non-

overtaking central markings).

2.3 Cumulative Impact Assessment of non-AIL Construction Traffic

2.3.1 Details of the assessment are provided in Core Document CD-COM-TRA-003 and

the report has been submitted as SEI.

2.3.2 The spreadsheet based Model will be presented, via a powerpoint presentation,

during the strategic transport hearing session.

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2.3.3 The Model allows various modifications regarding assumptions on construction

programme to be assessed as well as examining differing combinations of

development.

2.3.4 For the purposes of this Inquiry, I consider the most relevant assessment would

be to consider the combined effects of potentially all of the schemes (160

Turbines) before the Inspector and Secretary of State at this Inquiry. In addition,

this should also take into account the consented wind farm at Tirgwynt (12

Turbines).

2.3.5 This assessment (referred to as Scenario 1) assumes, as a worst case, that all

schemes will commence in 2016 other than Llandinam (end Qtr 2015). The results

are reported upon in the SEI (Section 5). However the analysis will be reworked

and presented at Session 4 to demonstrate the effect of any potential

rescheduling of construction programmes (later starts).

2.3.6 Figure 2 of the SEI indicates the road network that has been examined in terms of

the cumulative impact of construction traffic.

2.3.7 Appendix G of the SEI shows how the traffic flows and HGV movements on the

road network could change on a month by month basis.

2.3.8 The assessment indicates that in terms of the percentage change to prevailing

background annual average daily traffic, AADT, (resulting from all six wind farms

inclusive of Tirgwynt) this would, for the majority of the roads that have been

examined, amount to less than 10%. Where this is exceeded, for example along

A483 south of Newtown, this would only be for a limited period.

2.3.9 No part of the strategic and primary road network is likely to experience an

increase in excess of 30% in AADT. This is the screening threshold advised by the

IEA guidelines as warranting further consideration.

2.3.10 Changes of 10% or less can be regarded as having no discernible impact. Changes

of between 10% and 30%, depending upon the sensitivity of the receptor can be

regarded as being of slight or neutral significance. It is also important to note that

the extent of change varies by month and year. Those changes exceeding 10% on

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the routes south of Newtown are only likely to occur during a relatively short

period.

2.3.11 Of specific interest and relevance to Carnedd Wen is the effect on Welshpool town

centre and westwards along the A458 trunk road leading to Carnedd Wen where

development related traffic converges. These are sections of road labelled: Links 9

(Welshpool), 10, 12 and 13 and other connecting Links 11 and 31.

2.3.12 In terms of overall traffic, the changes will be less than 10%. In terms of changes

in volume of HGVs (delivery lorries) there will be occasional periods where the

10% threshold is likely to be exceeded:

Link 9 Welshpool Town Centre

Year 2015 3 months (pre: Carnedd Wen)

Year 2016 11 months (10.7% to 19.3%)

1 month (Feb) (30.9%)

Year 2017 6 months (10.1% to 13.4%)

Year 2019 1 month (Jan) (10.4%)

2.3.13 The above percentage changes can be regarded as having a “slight” (1 month) or

“neutral or slight” impact. This would not be considered significant. In terms of

the largest change (during one month), this would amount to only 79 additional

HGV movements per day over base.

2.3.14 Further west along the A458, beyond which other connecting roads from the north

(A495 and B4392) converge on the trunk road, the predicted changes in HGV

volumes (delivery vehicles) could be as follows:

Link 12 at Llanerfyl

Years 2015, 17 & 18 (less than 10%)

Years 2020, 21 & 22 (less than 20%)

Years 2016 & 19 (less than 30%)

2.3.15 The above percentage changes can be regarded as having “no discernible impact”

during three years of the overall construction period and as having no more than

a “neutral or slight” impact at other times. Overall, this would not be considered

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significant. In terms of the largest change (27.5% during three months), this

would amount to only 45 additional HGV movements per day over base.

2.3.17 The SEI has also considered the effects of other potential wind farm proposals

even though they are not before this Inspector or the Secretary of State for

determination at this Inquiry.

2.4 Stage 1 Road Safety Audits and sTMP Environmental Assessment

2.4.1 An independent Stage 1 Road Safety Audit (RSA) for Sections 2-5 of the sTMP has

been undertaken by gm Traffic Consultants on behalf of Renewable UK Cymru,

Vattenfall, Celtpower, RES and RWE. This has been submitted as SEI.

2.4.2 A Stage 1 RSA considers the safety aspects and identifies where specific measures

may be required. The outputs from the safety audit inform the detailed design

process and is subsequently followed by Stage 2, 3 and 4 audits during the detail

design and implementation stages.

2.4.3 The Auditors have drawn attention to need to consider trimming of overhanging

trees, relocation of signs, the need to clearly delineate between normal

carriageway and overrun areas and have recommended additional advance

warning signage.

2.4.4 All of the Auditors’ recommendations will be taken forward and addressed prior to

the Stage 2 audit on the detailed designs.

2.4.5 An Environmental Assessment of the proposed sTMP highway works has been

undertaken by Amec on behalf of Renewable UK Cymru, Vattenfall, RES, RWE and

Celtpower. This has been submitted as SEI.

2.4.6 The conclusion drawn from the environmental assessment is that with appropriate

mitigation no significant environmental effects would occur (Ecology/Ornothology,

Cultural Heritage, Landscape and Visual, Hydrology, Noise).

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3.0 OBJECTORS’ STATEMENTS OF CASE

3.1 The Alliance

3.1.1 I have examined the Alliance’s Statement of Case for Session 4, specifically in

relation to Transport and Highways (paragraphs 17 to 22).

3.1.2 One is informed (paragraph 17) that the Alliance’s evidence will relate to the

impacts on the wider highway network (road users and communities) both

individually and cumulatively.

3.1.3 It should be noted that the individual traffic impact of Carnedd Wen was dealt

with during Session 2 and I do not anticipate the need to reconsider this again

during Session 4.

3.1.4 In paragraph 19 it is stated that the Alliance’s evidence will, inter alia, include

information regarding general disruption in Welshpool town centre, the availability

of Police resources, the repeated removal of street furniture and the effect of

outside influences.

3.1.5 In evidence earlier (Section 2.0), I have considered the impact of AIL deliveries

upon Welshpool town centre. Details of the technical review of alternative AIL

routes around Welshpool have also been referred to. It is a matter of record that

both the strategic and local highway authorities have approved the route through

Welshpool. The corridor through Welshpool is capable of accommodating all

construction traffic. The passage of an AIL convoy through Welshpool (no more

than once a day) can be effectively managed and carried out during a short period

(less than 5 minutes journey time).

3.1.6 As far as Police resources are concerned, the position on this is made clear in the

Agreed Statement on the Delivery Process for Abnormal Indivisible Loads

(paragraph 1.8). The Welsh Police will be setting up an AIL Escort Unit specifically

to deal with and provide necessary resources for the escorts to the wind farms.

Frontline resources will not be affected.

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3.1.7 As clarification, I can confirm that there is no intention to repeatedly remove

street furniture. Any modifications in place would be undertaken prior to the

commencement of AIL deliveries and remain as such throughout the construction

period.

3.2 Statement of Case by Three Community Councils

(Carreghofa, Llandysilio, Llandrinio and Arddleen)

3.2.1 I have noted the points raised by the Community Councils and appreciate that

their time and resources may not have permitted full examination of the detailed

information that has been submitted prior to Session 2 and that which is now

before the Inquiry for Session 4.

3.2.2 In so far as the matters that I am able to assist with, I consider that the

information sought by the Community Councils is covered in the documentation

that I have referred to in Evidence.

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4.0 DRAFT PLANNING CONDITIONS

Strategic Highways

4.1.1 The Welsh Government (Transport) has in its Statement of Case for Session 4

confirmed that it is satisfied that the Carnedd Wen development’s construction

traffic impact can be managed in accordance with the methodology set out in

Sections 1 to 3 of the sTMP and thereby ensure the safety and free flow of trunk

road traffic. Accordingly WG(T) has proposed five planning conditions for Carnedd

Wen and has requested that these be included with any permission granted by

DECC.

4.1.2 These correspond to RWE’s proposed planning conditions 12 to 16 (Appendix 1 to

my evidence). With the exception of a few minor changes proposed by RWE

(highlighted red) they now represent the proposed conditions covering strategic

highway matters in relation to trunk road access, the sTMP Sections 1 to 3 and

the assessment of the structures and embankments along the proposed AIL

delivery routes and provision for any remediation.

Local Highways

4.1.3 PCC is proposing its own draft set of Conditions. They have been based, in part,

upon a number of the draft generic conditions that had been presented to the

Inquiry by PCC during Session 1. Whilst some of the draft Conditions currently

suggested by the Council could apply, in some circumstances, to other wind farm

proposals, RWE and I consider they would not all be relevant to Carnedd Wen.

4.1.4 Carnedd Wen is to be accessed from the trunk road. It will not be undertaking any

significant highway works on the local highway network. Of the list of draft

Conditions that have been suggested by PCC, RWE and I consider that four of

these with some amendment (in addition to those agreed with WG) would be

relevant to Carnedd Wen. These are listed as RWE’s draft conditions 17 to 20 in

Appendix 1 of my evidence. Discussions over Conditions are ongoing and the

Inspector will be informed of progress prior to, or during, Session 4 of the Inquiry.

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5.0 SUMMARY OF EVIDENCE AND CONCLUSIONS

5.1 In June 2012 I was appointed by RWE Npower Renewables (RWE) to act on its

behalf in respect of the transportation and associated highways and traffic

management considerations related to its proposed wind farm development at

Carnedd Wen.

Site Specific Matters

5.2 I have previously appeared at this public inquiry on behalf of RWE, during Session

2, when the site specific matters associated with the proposed development at

Carnedd Wen were dealt with.

5.3 During Session 2 it was demonstrated and confirmed in evidence that there were

no highways objections to Carnedd Wen raised by either the strategic highway

authority (Welsh Government (Transport)) or by the local highway authority

(Powys County Council), subject to the imposition of appropriate planning

conditions. A Statement of Common Ground was submitted to the Inquiry to

confirm that position.

Key Considerations for Session 4 (Matters in Common/Cumulative Effects)

5.4 This evidence, which has been submitted for Session 4 of the Public Inquiry, has

addressed the strategic transport and cumulative construction traffic

considerations. These relate to the Inspector’s and the Secretary of State’s

consideration of the relevant Matter 5:

“5. The individual and combined impact of construction traffic on the

surrounding locality, including transportation access routes and

traffic management, taking into account the cumulative impact with

other wind farms in the Powys area which have already been

granted planning permission or where planning permission has been

applied for;”

5.5 With regard to the topics for consideration during Session 4, the corresponding

assessment of construction traffic relates to two distinct and separate areas of

focus.

25

a) the delivery process and efficient management of the transportation

of wind farm turbine components as Abnormal Indivisible Loads

(AILs), and

b) the cumulative effects of and management of other non-AIL

construction traffic upon the local and strategic road networks.

SEI and Other Information

5.6 I have listed, reviewed and commented upon the various documents that have

been submitted to the Inquiry for Session 4, either as SEI or as other information.

These have included all of the following:

i) the proposed strategic Traffic Management Plan (Sections 1 to 5)

(CD-COM-TRA-001)

ii) a Technical review of AIL Routes around Welshpool

(SEI/CUMULATIVE/TRANS/6)

iii) the Stage 1 Road Safety Audit Reports on the proposed highway

works listed in the sTMP (Sections 2 to 5)

(SEI/CUMULATIVE/TRANS/4)

iv) the environmental assessment of the proposed sTMP highway works

(SEI/CUMULATIVE/TRANS/8)

v) an Agreed Statement on the Delivery Process for Abnormal

Indivisible Loads (AILs);

(CD-COM-TRA-002)

vi) a Water Preferred Policy Assessment; and

(CD-COM-TRA-004)

vii) the Cumulative Impact Assessment of non-AIL Construction Traffic

on the Strategic Road Network

(CD-COM-TRA-003)

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The Stated Positions of the Strategic and Local Highway Authorities

5.7 The Welsh Government (Transport) has in its Statement of Case for Session 4

confirmed that it is satisfied that the Carnedd Wen development’s construction

traffic impact can be managed in accordance with the methodology set out in

Sections 1 to 3 of the sTMP and thereby ensure the safety and free flow of trunk

road traffic. Accordingly WG(T) has proposed five planning conditions for Carnedd

Wen and has requested that these be included with any permission granted by

DECC. I have considered these in Section 4.0 of my evidence.

5.8 Powys County Council has advised in its Statement of Case for Session 4 that in

relation to Transport (Section 5 of the Council’s Statement):

“5.4 The Cumulative Effect, including the sTMP

5.5 PCC judges that the AIL route from Ellesmere Port to the combined

sites, set out in the sTMP, is reasonable and appropriate subject to

clarifications and Conditions .....

5.6 PCC will seek Conditions requiring a common approach to mitigation

design and implementation, as well as traffic management, between

individual developments utilising the same routes or the same

services.”

5.9 PCC is proposing its own draft set of Conditions. They have been based, in part,

upon a number of the draft generic conditions that had been presented to the

Inquiry by PCC during Session 1. Whilst some of the draft Conditions currently

suggested by the Council could apply, in some circumstances, to other wind farm

proposals, RWE and I consider they would not all be relevant to Carnedd Wen.

5.10 Of the list of draft Conditions that have been suggested by PCC, RWE and I

consider that four of these with some amendment (in addition to those agreed

with WG) would be relevant to Carnedd Wen. These are listed as RWE’s draft

conditions 17 to 20 in Appendix 1 of my evidence. Discussions over Conditions are

ongoing and the Inspector will be informed of progress prior to, or during, Session

4 of the Inquiry.

27

Consideration of the Objectors’ Cases

5.11 I have examined the Alliance’s Statement of Case for Session 4, specifically in

relation to Transport and Highways (paragraphs 17 to 22).

5.12 In response I have considered and commented upon the matters raised by the

Alliance (Sections 2.0 and 3.0 of my evidence refers). I have considered the

impact of AIL deliveries upon Welshpool town centre. Details of the technical

review of alternative AIL routes around Welshpool have also been referred to. It is

a matter of record that both the strategic and local highway authorities have

approved the route through Welshpool town centre.

5.13 As far as Police resources are concerned, the position on this is made clear in the

Agreed Statement on the Delivery Process for Abnormal Indivisible Loads

(paragraph 1.8 of the document). The Welsh Police will be setting up an AIL

Escort Unit specifically to deal with and provide necessary resources for the

escorts to the wind farms. Frontline resources will not be affected.

5.14 I have also considered the points raised by the Community Councils. I consider

that the information sought by the Community Councils is covered in the

documentation that I have referred to in Evidence.

Conclusions

5.15 Taking all of the foregoing into account I therefore conclude that the Inspector

and Secretary of State can be satisfied that the proposed development at Carnedd

Wen, either individually or in combination with other development proposals, can

make adequate provision for the effective management of all construction traffic

such that the impact upon the strategic and local highway network will generally

be slight or neutral in significance.

5.16 An appropriate mitigation strategy can be secured through appropriate planning

conditions dealing with both AIL and non-AIL construction traffic. This would be

consistent with the manner in which other consented wind farm proposals have

been dealt with regionally and nationally.

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29

APPENDICES

Appendix 1 – Draft Planning Conditions

30

APPENDIX 1

Amalgamated Draft Planning Conditions to Cover Strategic & Local Highway Issues

(Version dated 13 February 2014)

Carnedd Wen Wind Farm

12. Prior to the commencement of development, full details of the highway works for the

proposed new junction onto the A458 trunk road shall be submitted to and approved

by the local planning authority, in consultation with Natural Resources Wales,

following consultation with the Welsh Government as trunk road highway authority.

The details submitted shall accord with those indicated on the approved plans and

include:

a) the detailed design

b) geometric layout

c) details of visibility splays that shall be kept free at all times of any

planting tree or shrubs or any other obstruction exceeding 1.05 metres

above the

adjoining carriageway)

d) construction details

e) drainage details; and

f) road markings and signage

The works shall be implemented in accordance with the approved details.

13. Abnormal Indivisible Loads associated with the development shall be delivered strictly

in accordance with the approved strategic Traffic Management Plan for Mid Wales

Wind Farms Sections 1, 2 and 3 or any subsequent approved Pre-construction Traffic

Management Plan. In this respect, the Pre-construction Traffic Management Plan

shall be submitted to and approved in writing by the local planning authority following

consultation with the Welsh Government as trunk road highway authority or other

relevant highway authority (as appropriate) prior to the commencement of any

abnormal indivisible load deliveries to the development site.

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14. No development works other than tree clearance and the construction of new and

upgraded access tracks within the site and the construction of the proposed new

junction on to the A458 trunk road referred to in Condition 12 shall be undertaken

until full details of the highway works associated with the construction of layover

areas, passing places and highway improvements as indicated in the approved

strategic Traffic Management Plan for Mid Wales Wind Farms Sections 1, 2 and 3 or

any subsequent Pre-construction Traffic Management Plan including:

a) the detailed design of any works

b) geometric layout

c) construction methods

d) drainage; and

e) street lighting, signage and road markings.

have been submitted to and approved in writing by the local planning authority

following consultation with the Welsh Government as trunk road highway authority or

other relevant highway authority (as appropriate). The highway works shall be

completed in accordance with the approved details prior to the commencement of any

abnormal indivisible load deliveries to the development site.

15. No development works other than tree clearance and the construction of new and

upgraded access tracks within the site and the construction of the new junction on the

A458 trunk road referred to in Condition 12 shall be undertaken until an assessment

of the capacity and impact on all structures along those parts of the trunk road

network which shall be utilised for the delivery of Abnormal Indivisible Loads to the

development including bridges, culverts, retaining walls, embankments and details of

any improvement works required to such structures as a result of construction of the

development shall be submitted to and approved by the local planning authority

following consultation with the Welsh Government as trunk road highway authority or

other relevant highway authority (as appropriate). The required improvement works

identified in the assessment shall be completed prior to the commencement of any

Abnormal Indivisible Load deliveries to the development site.

16. Prior to the commencement of development a scheme to provide for the remediation

of any incidental damage directly attributable to the development to the parts of the

trunk road and local road network which will be utilised during the construction of the

development including street furniture, structures, highway verge and carriageway

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surfaces shall be submitted to and approved by the local planning authority following

consultation with the Welsh Government as trunk road highway authority or other

relevant highway authority (as appropriate). The scheme shall be implemented as

approved throughout the construction phase of the development.

17. No Abnormal Indivisible Loads associated with the development shall be transported

along a highway until a detailed Transport Tool Plan has been submitted to and

approved in writing by the local planning authority. All Abnormal Indivisible Load

deliveries shall be carried out in accordance with the approved Transport Tool Plan

which will include details of the following:

a) Management and maintenance of the Transport Tool

b) Timing of delivery Abnormal Indivisible Load movements;

c) Temporary traffic diversions and traffic hold points;

d) Details of banksmen/notification and escorts for abnormal loads

e) Coordination with all other Abnormal Indivisible Load deliveries to

other wind farms in Mid Wales

f) Description of procedures for the allocation of delivery slots including

delivery slot triggers and trading

g) The appointment and role of a Transport Coordinator to administer the

Transport Tool in relation to Abnormal Indivisible Load deliveries

h) Management and maintenance of Layover areas and welfare facilities

i) Liaison with relevant highway and planning authorities, the Highways

Agency, Welsh Government and Police

j) Liaison with local communities

k) Liaison with the hauliers, developers and landowners prior to the

submission of notifications for Abnormal Indivisible Load deliveries and

applications for Special Orders for Abnormal Indivisible Load

deliveries.

18. No development works shall take place on site until a Construction Management Plan

for the development has been submitted to and approved in writing by the local

planning authority which shall thereafter be fully implemented in accordance with the

approved details. The Construction Management Plan shall include details relating to:

a) construction vehicle routing;

b) the management of junctions with and crossings of the public highway;

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c) temporary traffic diversions and traffic control;

d) means of monitoring vehicle movements to and from the site;

e) the timing of deliveries of construction materials to the site.

19. No turbine components associated with the development requiring transportation as

an Abnormal Indivisible Load shall be removed from or replaced until a revised Traffic

Management Plan, dealing with that removal or replacement, has been submitted to

and approved in writing by the local planning authority.

20. No Abnormal Indivisible Loads associated with the development shall be transported

until a Building Condition and Building Structural Survey Plan for properties on B4381

Severn Street, Welshpool (between the Canal and the Cross), to include details of its

timing and implementation, has been submitted to and approved in writing by the

local planning authority. This will include details of the following:

a) Frequency and timing of Building Condition and Building Structure

surveys in relation to Abnormal Indivisible Load deliveries

b) Relevant matters to be contained within a Building Condition and

Building Structure Survey

c) Details of Survey report submission requirements to the local planning

authority

d) The appointment of a competent independent professional approved in

writing by the local planning authority who has relevant experience

within the building surveying sector to undertake the Building Condition

and Building Structure Surveys.

No Abnormal Indivisible Loads associated with the development shall be transported

until the approved Building Condition and Building Structural Plan has been

implemented and the approved Building Condition and Building Structural Plan shall

continue to be implemented in accordance with the timing contained in the approved

Building Condition and Building Structural Plan.