THE RIGHT SOLUTION
IN
THE WRONG LOCATION
AN
OBJECTION
TO
THE PROPOSED DEVELOPMENT OF A WIND FARM
AT
INNER FARM, EDITHMEAD, BURNHAM-ON-SEA
SOMERSET
PREPARED BY: kNOll to Wind Farm
Action Group
DATE: JUNE 2006
CONTENTS
SECTION 1 - EXECUTIVE SUMMARY
SECTION 2
- PLANNING POLICY
SECTION 3
- ENVIRONMENTAL IMPACT
SECTION 4
- ECONOMIC IMPACT
SECTION 5
- HEALTH AND SAFETY ISSUES
SECTION 6
- SOCIAL IMPACT
SECTION 7
- TECHNICAL ISSUES
1.0
EXECUTIVE
SUMMARY
INTRODUCTION
1.1 This document has been prepared by the kNOll
to Wind Farm Action Group (“kNOll to Wind Farm”) to set out its objections to
the planning application by Next Generation Ltd, Application Number
12/06/00007, for 5 wind turbines at Inner Farm, Edithmead.
1.2 The
document examines the proposal in terms of key local and central planning
policy, and also critiques the Environmental Statement (“ES”) and other aspects
of the application made by Next Generation Ltd. For the purposes of this document,
Next Generation Ltd is referred to either as “the developer” or “ecotricity”-
the brand name employed by the group of companies of which Next Generation is
just one.
1.3 This
objection is based on considerable in-depth research undertaken by kNOll to
Wind Farm over a number of months. Further information can be sourced or
located via kNOll to Wind Farm’s website at www.knolltowindfarm.org.uk.
BASIS
OF OBJECTION.
National Planning Policy
1.4 This
application runs contrary to the guidelines set out in the relevant National
Planning Policy as set out in PPS22. This document requires assessment of
applications to consider Environmental, Economic and Social impact of
developments-
“(i) Renewable energy
developments should be capable of being accommodated throughout England in
locations where the technology is viable and environmental, economic, and
social impacts can be addressed satisfactorily.”
“(viii) Development
proposals should demonstrate any environmental, economic and social benefits as
well as how any environmental and social impacts have been minimized through
careful consideration of location, scale, design and other measures.”
It also refers repeatedly to “appropriate locations”.
1.5 The
supporting documentation submitted by ecotricity does not adequately
demonstrate that there are any significant benefits from the proposed scheme,
and the significant environmental, economic and social aspects are not
addressed satisfactorily.
1.6 The Environmental impact,
in terms of visual impact, noise impact, impact on a historic landscape and
unique visual feature, impact on landscape quality, impact on local drainage
systems, impact on animals and birds, and on general levels of amenity is unacceptable;
1.7 The Economic impact - in
terms of destruction of local capital due to falling house prices and the knock
on effects on jobs and spending power, and the impact on Tourism,- is such to
create a significant risk to the health of the local economy; we should not
forget that the biggest employers in the region are the tourist, and property
and construction related industries, nor that the largest single element of the
population are pensioners who increasingly rely on the equity in their houses to
bolster their pensions and hence their purchasing power in the local economy.
1.8 The impact on social
amenity, both in terms of visual and noise impact, but also in terms of local
land use for walking, horse-riding and husbandry, etc., and potential impact on
television signals is unacceptable.
1.9 We also believe that the
potential Health and Safety risks, which include “blade throw”, “ice throw”,
low frequency noise, “shadow flicker”, structural collapse, and scaring horses,
which would exist by locating such a development close to large numbers of
houses, community facilities, school, roads, Retirement and Nursing homes,
footpaths and bridleways, flight paths are too significant.
1.10 Under PPS22 in terms of cost/benefit
, the costs far outweigh the relatively minor benefits, and accordingly this is
not an “appropriate location”; the vast majority of the risks and potential
impacts set out above can be mitigated by locating such developments in
alternative locations- particularly away from large residential and business
communities.
Local Planning Policy
1.11 This proposal also runs contrary to Local Planning Policy.
1.12 Local Plan policy CNE2
raises a strong presumption against development which adversely affects local
landscape character or scenic quality. The proposed development would adversely
affect these factors.
1.13 Local Plan Policy PCS5
requires that all proposals for renewable energy must meet all criteria set out
in the Policy including that developments must be
·
“sited and designed so
as to minimise their impact on the landscape,
utilising landscape features
·
“not unacceptably affect the character or
setting of….a Scheduled Ancient
monument” (criterion d).
·
“not unacceptably
affect a site designated for its ecological value either before or during construction” (criterion e)
The proposal for this site does not meet these
criteria.
1.14 Local
plan policy CNE7 raises a strong presumption against development which is likely to have a significant adverse
effect on the conservation objectives or the integrity of site of international
importance. The objectives or integrity of such sites will be affected. CNE8
and CNE10 also apply.
`
Precedent local Planning decisions
1.15 This
proposal runs contrary to previous planning decisions in the area related to
the height and/or visual impact of proposals for various radio masts, buildings
etc. These previous applications have been refused due to being in breach of
various local plan policies and the reason that height and form would be intrusive in the flat open landscape of
the Somerset Levels and Moors, and would not have proper regard to the context
of the immediate setting and the defining characteristics of the wider local
area which includes Brent Knoll.
Technical critique of developer’s proposals
1.16 Our research, based on
information generated by central government etc. indicates the claims of the
developer concerning the number of homes that would be supported by the
development is significantly exaggerated. Independent analysis by other parties
at other locations where ecotricity propose similar developments has come to
similar conclusions.
1.17 We
believe that the amount of carbon dioxide displacement claimed is also
significantly exaggerated.
1.18 We believe that the environmental
impact studies, covering, for example, noise impact and potential impact on
birdlife, that have been undertaken by ecotricity are far from adequate and do
not meet best practice.
1.19 We believe that the
photographic images produced by ecotricity inadequately demonstrate the visual
impact, both in terms of the locations from which the photographs have been
taken and also the background which has been used. We believe that these may
also not reflect best practice for producing such photomontages. We also
believe that the production of photomontages in isolation is not sufficient to
demonstrate the impact on the environment or amenity.
OTHER
MATTERS
1.20 To put the situation in context, we would comment that
·
Wind farms are not an
alternative to nuclear or any other forms of mainstream power generation;
·
Wind farms are not the
only form of renewable energy;
·
It was recognised by
the House of Commons, Committee
of Public Accounts,Department of Trade and Industry, Renewable energy Sixth Report of Session 2005–06 that the Renewables Obligation, which
is driving the “rush for wind” is more expensive than the other mechanisms
currently being used under the Climate Change Programme to reduce carbon
dioxide emissions. The expense of the Obligation reflects the high cost of
renewable generation and poor targeting of the scheme.
·
On the 8th
May of this year, the Energy Minister, the Rt. Hon Malcolm Wicks MP confirmed that the forthcoming Energy Review
would address the fact that the Renewables Obligation has focused on one
technology to the detriment of others. The Minister said:
“Yes, I agree that the renewables obligation, despite its
strengths, which have brought forward much renewable energy, could appear to be
a blunt instrument and certainly seems to be favouring one technology—the wind
farm
1.20 A
changing political and scientific wind is therefore now blowing around wind
farms. At the very least we should wait and see what the Energy Review comes up
with, before committing the community to years of what could potentially be
very large white elephants or wind mill stones around our necks!
SUMMARY
1.21 Are
wind farms the right solution? Not our collective position to judge- albeit
we can have an opinion.
1.22 Is
this the right location for a wind
farm?- it is our collective position to judge this- In our opinion it is
clear cut this is the wrong location, and it has only be selected in an
opportunistic manner by a commercial developer.
1.23 This
application involves a lot of risk and dis-benefits for extremely marginal
gain.
1.24 We all
recognise that this is the most significant planning decision that this
location has had to have made for
years. We need to defend the Knoll in the same way it has defended the local
population for thousands of years.
2.0
PLANNING POLICY
OBJECTION
2.1 kNOll to Wind Farm, an Action Group
established by local residents, wishes to register its objection to the
planning application by Next Generation Ltd, Application Number 12/06/00007,
for 5 wind turbines at Inner Farm, Edithmead.
2.2 The group considers that the description
of the development and its effects are wrongly described and understated in the
Environmental Statement. This objection follows in the main the Chapter
headings of the Environmental Statement.
ENERGY OUTPUT
2.3 The fact that a wind turbine scheme produces only a
small output is not, in itself, a reason for refusal of planning permission.
However the benefits of any development, such as contribution to national
energy needs or saving of carbon dioxide emissions, need to be balanced against
any harm to other interests of acknowledged importance, such as the landscape,
visual amenity or archaeology. It is therefore necessary to examine the basis
for the claims in the Environmental Statement for output and savings. See
Section 7.0 below for a Technical critique of the proposal.
. We strongly believe that the
developer should be asked to justify his assertion that the output will be
adequate to supply all the local households identified in Figure 3.1 of the ES.
The developer should be
asked to justify his very high estimate of the number of homes that could be
supplied.
CARBON SAVING
2.4 Using a grid average displacement the carbon dioxide
savings would be more accurately predicted and approximately half that
indicated by the ES. The developer should be asked to justify the basis of
29,525 tonnes of predicted carbon dioxide savings.
2.5 PPS22 advises that “The wider
environmental and economic benefits of all proposals for renewable energy
projects, whatever their scale, are material considerations that should be
given significant weight in determining whether proposals should be granted
planning permission”. It is therefore essential to have an accurate, evidence
backed, statement of what those benefits will be rather than a potentially
exaggerated and unjustified assertion.
SITE SELECTION
2.6 It is accepted that alternative sites do not have to
be considered, although an application may be more robust if they are, however,
if they are considered they should be described. The regulations require an
outline of the main alternatives studied and an indication of the main reasons
for his choice, taking into account the environmental effects.
2.7 The ES describes a sieving
technique for identifying this site. However in describing the sites considered,
the principle reasons for discard are: lack of landowner agreement and
practical access route. The first is a commercial difficulty rather than
environmental reason. It may be a reason for choice but does not take into
account the environmental effects. It is identified as a reason in 3 out of the
4 alternative sites considered.
2.8 The second reason, lack of a practical
access, may or may not be based on environmental effects. Many wind farms are
accessed for construction purposes by temporary routes when existing access is
substandard. Is the practicability of the access a question of expense or
topography? The ES gives no indication of the nature of the access problems
relied upon as a reason for discard. The developer should be asked to clarify
his reasons.
LANDSCAPE
AND VISUAL IMPACT
2.9 It should be noted that the criteria
thresholds set out in the Guidelines for Landscape and Visual Assessment were adapted not adopted. (8.2.19, page 131 of the Environmental Statement). The number
of criteria, used to create the matrices indicating magnitude, differs, and in
some instances include a greater number of below significance indicators than
above. This results in a distorted indication of significance. This can best be
seen from Table 8.8 if viewpoints 2 and 4 are examined and contrasted. A medium
high impact on a medium sensitive landscape and a medium impact on a low-medium
landscape both give rise, by reason of this distortion, to a moderate
significance.
2.10 Again the ES fails to
describe the worst case scenario: see for instance 8.7.8 where summer
photographs, which depict a maximum level of screening, have been used to
produce the photomontages.
2.11 The appraisal of the landscape appears to
have been carried out from the photomontages rather than as an in field
assessment. When assessing changes to landscape character and giving a magnitude
range (8.8.10) the assessment is “based on analysis of the photomontages”.
2.12 The difficulty of judging visual impact of
turbines, whether from photographs of existing turbines or photomontage
predictions, has been acknowledged by Inspectors in several appeal decisions
(e.g. Inspector John Davies, Llethercynon Wind Farm, A-PP106-98-014 – other
similar statements are to be found at Appendix 1).
2.13 The size of the turbines is described as
“greatly diminished” at Viewpoint 9 (2.99km from the site) and at Viewpoint 5
(2.7 km distant). Describing 76m to tip turbines at 6.2 and 4.6km distance
Inspector John Davies found them to be prominent. At 1.97 km he found them
verging on the dominant. The turbines proposed for this site are significantly larger
and their potential for dominance must, inevitably, be greater. This assessment
appears therefore to be understated and should be checked in the field.
2.14 Although the viewpoints
were agreed with the planning authority during the scoping exercise that
generally establishes a rough location from a desktop study. The local and
precise selection of the viewpoint is carried out on site. The affect of minor
relocation of the photographer can have a significant impact on the view. A
minor adjustment of angle of view at Viewpoint 2 would have omitted the strong
feature of the railway line, increasing the apparent dominance of the turbines,
and providing a more representative view, particularly as seen by users of the
line.
2.15 Viewpoint 3 (wide) includes a telegraph
pole, which serves to minimise the vertical impact of the turbines. The impact
is greater on the second photograph from the same viewpoint, giving a 40 degree
angle of view. That photograph is not described.
2.16 Viewpoint 5. The impact of the turbines from
this viewpoint is much diminished by the farm buildings, pylons and telegraph
poles. The viewpoint is set on a small rural road. (8.6.23) and the ES states
that further north the turbines are screened from view by the high land of
Brent Knoll. Is there not, between this viewpoint and the northern screening,
an aspect of the site which can be appreciated by the public from the road, and
does not include this visual clutter in the foreground?
2.17 Viewpoint 6 – Inner Farm Footpath. Is there
on this footpath a location where the unsightly clutter of farm buildings does
not intrude into the view? We note that the ES (8.6.27) describes these
buildings as “very prominent and dominant in this section of the view”. A
“section of the view” which omitted the buildings is more likely to be part of
the enjoyment of the walker on this route.
2.18 Viewpoint 7 is representative of the view
from the B3140, where it is busy; the sensitivity of the receptor will be low.
The ES (8.6.29) identifies a footpath running from that point. It appears from
the OS to run towards the wind farm over level ground. If the view from that
path is similar then the effect on a more sensitive receptor, a walker, would
be greater.2.19 Viewpoint 8. The Es says
this was selected as a “worst case scenario” (8.3.36) However, when assessing
the “view and experience of the landscape”, valency of the viewer is
introduced, to attempt to minimise the effect. The degree of alteration to the view cannot be affected by the
sympathies of the viewer, although his experience,
be it of enjoyment or distaste, will be.
2.20 Viewpoint 9. Although it is accepted that
this viewpoint is dominated by the M5, and no objection is taken to its
inclusion as representative, it is unfortunate that the base photograph has
been taken in conditions which present a skyscape of piled clouds. This reduces
the apparent prominence of the turbines in the accompanying photomontage. The
potential for greater prominence in different climatic conditions is not
mentioned, although the assessor is keen to note the ameliorating effects of
atmospheric haze in other parts of the assessment (8.6.2).
2.21 We note that there are no viewpoints from
within the residential settlements. As such receptors are amongst the most
sensitive we would have expected a representative series of views to include
them. There are two residential areas, the eastern part of Burnham-on-Sea and
the village of Brent Knoll, situated within a kilometre from the site. The
impact upon their amenity, when enjoyed from their homes and in their going and
coming on daily business or recreation, will be highly significant and has been
inadequately addressed.
2.22 Paragraph 8.7.13
discusses the nature of visual impact. A study of residents local to Mynydd y
Cemmaes concludes that perception of the windfarm is mainly positive. The ES
does not analyse the essential differences between this large scale, striking
and rugged terrain and the landscape within which this proposal is to be set.
Nor does it advert to the remoteness of residential areas from the Cemmaes
site.
LISTED BUILDINGS
2.23 St Michael’s Church Brent Knoll is a Grade 1
listed building. The ES opines that it is unlikely that there will be views
from the church door or the churchyard. It would be helpful to have a
photomontage to confirm that opinion given the sensitivity of the resource and
its raised elevation.
2.24 The ES appears to
concentrate on views towards the point of interest not being seen through the
wind farm rather than assessing the importance to setting or views from the
building or point of interest which may be altered by the presence of the wind
farm.
2.25 It may be helpful to seek the views of the
local conservation officer. SCHEDULED ANCIENT MONUMENTS
2.26 Again the ES opines that it is likely that
trees will block views of the turbines from the moated site at Edithmead. Again
it would be useful to have a montage from which a proper judgement could be
made.
2.27 It is clear that the wider setting of the
important hill fort at Brent Knoll will be affected by introducing a modern
element into the landscape. Historically it will have been an observation point
over the wide empty marshes and seas and that relationship will be lost by the
introduction of these massive mobile structures. The Photomontage No: 1 (page
24) gives an approximation of the impact.
2.28 It may be helpful to seek the views of the
county archaeologist.
ECOLOGY AND ORNITHOLOGY
2.29 We note that the RSPB and English Nature, at
scoping stage, were concerned that bird monitoring, given the areas importance
to birds, should be carried out for 2 years. Further English Nature was
concerned that bird movements be monitored during day, night and poor
visibility, and that 2 migration periods (September to November and March to mid-May)
should be surveyed weekly.
2.30 The ornithological studies undertaken appear
to have been daytime only and are stated to have been between the months of
September 2005 and January 2006. This is both a shorter period than that
recommended and one in which not all major migrations would be anticipated.
Furthermore there appear to have been only 10 visits in all: the migratory
periods alone suggested by English Nature would amount to 23 weekly visits.
2.31 It would appear from the desk top study that
there is limited information about inland bird movements as studies have in the
main concentrated on the coastal areas. It would have been helpful to the
assessment of the impact of this site if such work had been carried out.
2.32 We note that some mitigation of lost habitat
is suggested (page 211) as well as changed management of areas of off-site
land. Has the developer submitted a unilateral obligation under s.106?
2.33 It is further noted that RSPB sought
monitoring of post-construction effects on important bird populations. That
does not form part of the mitigation proposed.
2.34 PPS 22, paragraph 14, makes it clear that
“the potential impact on designated areas of renewable energy projects close to
their boundaries will be a material consideration to be taken into account in
determining planning applications.” It is therefore essential that the full
implications of this development for the nearby Somerset Levels and Moors SPA
and Ramsar and the Severn Estuary SPA and Ramsar sites are evaluated in accordance
with the consultees advice.
2.35 The ES does not address the objects of
designation of these 2 internationally important sites. However it appears from
the English Nature letter of 2/11/05 that their concerns centred on 1) the
wintering waterfowl, the internationally important numbers of wigeon, shoveler,
teal and lapwing and nationally important numbers of Bewick’s swan, gadwall and
golden plover, supported on the Somerset Levels and Moors site and 2) wildfowl
and waders, internationally important numbers of European white fronted goose,
shelduck, gadwall, dunlin, redshank and Bewick’s swan at the Severn Estuary
site.
2.36 Examining the raw results of the Lapwings
Consultants Ltd and Just Ecology it is apparent that 3 of the site visits,
those in September 2005, are concerned simply with corvid movement. The
remainder of the site visits appear to have taken place between 01/12/05 and
30/01/06.
2.37 These dates fall outside the range suggested
by English Nature and they may not, therefore, address adequately the important
migratory periods of these internationally important birds. It is suggested
that the local planning authority consult English Nature, and their own local
ornithologist adviser, regarding this potentially significant deficit.
NOISE
2.38 Page 256 refers to noise impacts upon Home Farm Holiday Park. The holiday industry is one of the