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 economic cornerstones of
this area. The noise limits used are the same as for residential and applied to
caravans and tents. It is clear that these are assumptions and that no research
has been carried out to establish the exact level of impact on holiday campers.
If the reduction is less than assumed in these temporary structures then the
excess experienced may be greater than the 1dB referred to in paragraph 12.6.25.
·
Again the wind shear
effects are an assumption and no data has been collected to substantiate the
view that no such effects will occur.
It may be helpful to
consult the local authority’s environmental health department.
HEALTH AND SAFETY
2.39 Accidents
related to wind turbine operation are not unknown: see the details from Caithness
Wind Farms Information Forums in the attached file named Accident Details.
2.40 This site is located close
to public rights of way, one of which passes through the site and lies with in
48 metres of the nearest turbine, and also so close to residential areas that
one may anticipate that these rights of way are well used. No details of the
level of user are given in the ES.
SOCIO-ECONOMIC
2.41 Paragraph 17.3.1. indicates that there will
be an opportunity to provide employment locally. However the need for
specialist equipment and consultants being required, as noted on page 322,
renders the amount of such employment questionable. Little of the development
costs itemised in Table 17.1 will be spent in the local area. It is therefore
most unlikely to result in a high magnitude of change to the local economy. As
a result the short term significance to the local economy appears to have been
overestimates at the bottom of page 325.
TOURISM
2.42 Tourism is acknowledged to be important to
the Somerset economy. However no specific local tourist enterprises are
described nor is the potential effect on them assessed. The topic is merely
dealt with by a range of surveys carried out in other areas. No attempt has
been made to explain the similarities and differences of the nature of those
areas appeal to tourists from that of the Brent Knoll area.
2.43 One local survey has been carried out, at
Brean, involving a very small number of individuals, and was not by this
developer. It is not clear what the terms of reference of this survey were.. due to
POLICY
2.44 PPS22 makes it clear that the accommodation
of renewable energy developments requires locations where the technology is
viable and environmental, economic and social impacts can be satisfactorily addressed.
The question of viability, since no community benefits linked to the production
of the site are being offered, is a matter for the developer. However it is
clear from the above that the ES fails to adequately assess the environmental,
economic and social aspects of this development. That being so one cannot be
assured that they can be “satisfactorily addressed”.
2.45 Local Plan policy CNE2 raises a strong
presumption against development which adversely affects local landscape
character or scenic quality. Paragraph 8.21 of the reasoned justification for
that policy particularly notes the significant local importance of “isolated
hill of Brent Knoll, the distinctive profile of which is visible across a wide
surrounding area”. This development will detract from that dramatic isolation
and that impact has, as set out above, been insufficiently assessed or
portrayed in the ES.
2.46 Local Plan Policy PCS5 requires that all
criteria are met before permission for renewable energy proposals are
permitted. Such proposals must, in accordance with criterion a), be “sited and
designed so as to minimise their impact on the landscape, utilising landscape
features”. This development, sited in open land close to the important isolated
hill of Brent Knoll signally fails to comply.
2.47 It must also “not unacceptably affect the
character or setting of….a Scheduled Ancient monument” (criterion d). This
site, lying within the wider setting of and affecting
the historic outlook of, the hill fort on Brent Knoll, fails to comply with
this criterion.
2.48 It must also “not unacceptably affect a site
designated for its ecological value either
before or during construction” (criterion e) For the reasons set out above,
concerning the lack of information provided in respect to the nearby
internationally designated sites and the effects upon them, this site is not
demonstrated not to have such an effect.
2.49 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 flaws in the ES Chapters
on ecology and ornithology detailed above make it impossible to assess whether
the objectives or integrity of such sites will be affected. CNE8 and CNE10 also
apply.
CONCLUSION
2.50 kNOll to Wind Farm contends that the
proposed development would be in breach of both national, regional, and local
planning policies, and that the developer’s Environmental Statement is
deficient.
2.51 We ask that these deficiencies in the ES and
the points made in this submission be taken into account in the determination
of this application and be brought to the determining Committee’s attention.
2.52 We also request that the Council would
please advise the group of :
·
any additional material
or information which is submitted in respect of this application;
·
any intended site visit
by the Committee so that we may attend;
·
the proposed committee
date and, if possible, permit the group to make a formal oral representation to
the Committee;
·
provide a copy of the
committee report as soon as it becomes public and notify the group of the
outcome of the application.
ENVIRONMENTAL
IMPACT
A
WIDE RANGE OF CONSIDERATIONS
3.1 The Environmental Impact
of the proposed wind farm development on the area known as “Brent Marsh” covers
a wide range of factors, including;
·
Visual impact;
·
Impact on flora and fauna;
·
Impact on landscape quality;
·
Impact on drainage systems;
·
Noise impact- covered under Health and Safety Issues at Section 5.0
VISUAL
IMPACT
Planning Policy: PPS22 and Visual Impact
3.2 The
Governments Planning Policy Statement 22- Renewable Energy comments as follows about visual and landscape
impact.
“Of all renewable
technologies, wind turbines are likely to have the greatest visual and
landscape effects. However, in assessing planning applications, local
authorities should recognise that the impact of turbines on the landscape will
vary according to the size and number of turbines and the type of landscape
involved, and that these impacts may be temporary if conditions are attached to
planning permissions which require the future decommissioning of turbines”
It also recognises that
“Proposed developments
should be assessed using objective descriptive
material and analysis wherever possible even though the final decision on the visual and landscape effects will be, to
some extent, one made by
professional judgement.”
3.3 The starting point for consideration of
the proposal therefore is that it is recognised that wind turbines are likely
to have the greatest visual and landscape effect of all renewable energy
solutions, and that impact will vary from location to location.
Assessing visual impact
3.4 In
September 1996 an attempt was made by Mr Gareth Thomas, the Planning Officer of
Montgomeryshire (arguably the local authority with the greatest experience of
dealing with wind power station proposals) to define the potential visual
impact of wind turbines by descriptors which could be assessed in the field,
and which, with repeated observation, should produce a degree of observer
consistency. The approach assumes good normal visibility, and is intended only
to be a general guide, especially at the margins of each band, recognising the
importance of local conditions, viewing direction, turbine angle and the scale
and nature of the landscape context. The Matrix incorporates the following nine
bands of visual impact ranging from "dominant" to
"negligible", identified as 'A' to 'I' in the Table below.
3.5 The
Thomas Matrix was originally determined in respect of the 25 and 31m hub
machines at Cemaes and Llandinam (overall height 41.5 - 45.5m respectively:
significantly less than that of turbines subsequently constructed throughout
the UK). Mr Thomas concluded from this that "15km is considered to be the
appropriate radius distance for study", although many Zone of Visual
Influence (ZVI) maps in Environmental Assessments have employed a much smaller
radius (even for much larger turbines). Several hundred field observations have
since been carried out in the visual hinterlands of constructed wind power
stations throughout Britain by Geoffrey Sinclair of Environment Information
Services to test the Thomas Matrix and the relevant ZVI threshold. Initially
this exercise was confined to the two installations in Montgomeryshire where
the Thomas Matrix was developed, and then extended to others using
similar-sized machines. This established broad agreement with Mr Thomas'
descriptions of visual impact, but found that his original distance bands were
rather conservative. Minor amendments were made to his distances, as shown by
the results in the second column of the Table below headed the "Revised
Thomas Matrix".
3.6 The
Thomas approach was extended to viewpoints around other wind power stations
which used larger turbines in order to establish the extent to which distances
for each visibility band (and thus the appropriate ZVI radius) needed to be
extended in relation to the increase in turbine size. In practice, the larger
turbines used in most installations constructed since the 41-45m '1st
generation' have tended to cluster around 52-55m, and the results for these are
shown in the first column of what may now be called the 'Sinclair-Thomas
Matrix'. Provisional results from the largest turbines subsequently built (the
four 750kW 70m machines at Great Eppleton, Houghton-le-Spring, County Durham)
have also been used to construct a further tentative set of distances. A
projected series has been added to extrapolate the sequence in relation to the
latest proposals for the 1.5MW 95m turbines at Mynydd Hiraethog, North Wales.
THE 'THOMAS' AND 'SINCLAIR-THOMAS' MATRICES
to estimate the potential visual impact of different sizes of wind turbines
|
|
Overall
height of turbines (m): |
41-45 |
41-45 |
52-55 |
70 |
95
** |
|
Descriptors |
Band |
Thomas
Matrix |
Sinclair-Thomas
Matrix |
|||
|
|
|
Original |
Revised |
|
||
|
|
Approximate Distance Range (km) |
|||||
|
Dominant
impact due to large scale, movement, proximity and number |
A |
0-2 |
0-2 |
0-2.5 |
0-3 |
0-4 |
|
Major
impact due to proximity: capable of dominating landscape |
B |
2-3 |
2-4 |
2.5-5 |
3-6 |
4-7.5 |
|
Clearly
visible with moderate impact: potentially intrusive |
C |
3-4 |
4-6 |
5-8 |
6-10 |
7.5-12 |
|
Clearly
visible with moderate impact: becoming less distinct |
D |
4-6 |
6-9 |
8-11 |
10-14 |
12-17 |
|
Less distinct:
size much reduced but movement still discernible |
E |
6-10 |
9-
13 |
11-15 |
14-18 |
17-22 |
|
Low
impact, movement noticeable in good light: becoming components in overall
landscape |
F |
10-12 |
13-16 |
15-19 |
19-23 |
22-27 |
|
Becoming
indistinct with negligible impact on the wider landscape |
G |
12-18 |
16-21 |
19-25 |
23-30 |
27-35 |
|
Noticeable
in good light but negligible impact |
H |
18-20 |
21-25 |
25-30 |
30-35 |
35-40 |
|
Negligible
or no impact |
I |
20 |
25 |
30 |
35 |
40 |
|
Suggested
radius for ZVI analysis |
15 |
18 |
20 |
25 |
30 |
|
Application
of the above approach indicates that the proposal for 5 wind turbines each some 120 metres tall, at
Inner Farm would have a dominant impact on the area shown on the map at below- ie. Burnham- on- Sea, Highbridge,
Brent Knoll, Berrow, Brean, Lympsham, and a moderately potential intrusive
impact on large parts of Bridgwater.
3.7 The
University of Newcastle was commissioned by Scottish Natural Heritage to
produce a document entitled “Visual Assessment of Wind Farms: Best Practice” which
was published in 2002. It states that
“There is universal
acknowledgement that visual effects are important, that they depend on
·
distance,
·
size,
·
visibility; and
·
other factors,
and on both landscape and visual receptors.”
3.8 This
study examines a range of sources discussing visual impact and summarise these
as follows:
- “Department of the Environment (1995) quotes as an example that the
zone of visual influence for a particular wind farm development in Britain
has been calculated to be approximately 10 miles (16 km), but without any
detail.
- Scottish Executive (2002)(Planning Advice Note 45) offers the
following
general guide (Table 3)
to the effect that distance has on the perception of a wind farm development in
an open landscape (without relating this to tower height, but having earlier
referred to turbines of tower height >70m and rotor diameters of >80m):
Table 3: General
Perception of a Wind Farm in an Open Landscape
Perception
Up to 2 kms: Likely to be
a prominent feature
2-5 kms: Relatively prominent
5-15 kms: Only prominent
in clear visibility – seen as part of the wider landscape
15-30 kms: Only seen in
very clear visibility – a minor element in the landscape
Source: PAN 45 (revised
2002): Renewable Energy Technologies.
A similar table appeared in the Draft
NPPG6 Consultation Document (2000), and the comments made on that Draft are of
interest. For example, the British Wind Energy Association (BWEA) asked for the
term “impact” to be replaced by “effect”; argued that the table of perceptions
of impact was prejudicial and asked for its removal; and offered that
“significant visual
effects of wind turbines are only experienced within 5 km; beyond 15 km wind
turbines can generally only be seen in very clear visibility and even when
visible are likely to be a minor element in the landscape”
(Powergen Renewables
made essentially the same argument).
·
3.1.4 Other
consultees referred to the fact that turbines are increasing in size; that the
Novar wind farm is clearly visible at 30 km; preferred a recommendation of
semi-matt to matt surfacing for towers; and raised the issue of cumulative
effects.
·
Several consultees referred to the
Sinclair-Thomas Matrix (see section 3.7 and Table 4) without identifying its
source, pedigree or publication. As a result of these consultations, almost all
reference to particulars was removed from the final version of NPPG6. Some
details do however reappear in PAN45, but the word “dominant” which appeared in
the table in NPPG6 Consultation Draft is changed to “prominent” in the table in
PAN45 (above)
·
3.1.5 Scottish
Natural Heritage (2001) is the most detailed of any statutory agency guidance
available or published. Whilst it contains detailed information on issues of
siting and design, and the processes of site planning, it also contains a
specific recommendation that a ZVI should usually extend to at least 25 km.
·
The Countryside
Council for Wales(1999) specifies a ZVI of at least 10 km from the site (for
wind turbine proposals) and up to 20 km on the fringes of National Parks and Areas
of Outstanding Natural Beauty (AoNB) and in areas likely to be seen from such
distances. Countryside Commission (1991) suggests an outer limit of 10 – 15 km
for ZVI.
·
There is no
up-to-date Countryside Agency guidance in existence but we understand it is in
preparation.”
3.9 It can
be seen that which ever of the above distance criteria are applied to the
proposal for Inner Farm, that the 5 wind turbines will have a significant
visual impact for the Burnham-on-Sea, Highbridge, Brent Knoll, Berrow, Brean,
Lympsham area- i.e. a significantly populated, and highly visited part of
Sedgemoor; we understand that the permanent residential population of this area
is in the region of 106,000 and a sizeable percentage of the yearly 9.9 million
visits to Somerset are made to Burnham-on-Sea and the immediate area. When the millions of visitors who
travel up and down the nearby M5 Motorway are added to these figures, it is
clear that the impact in terms of numbers of the population affected will be
very significant. The following map shows the proximity of the site to the M5.
Map
is copyright of Ordnance Survey
Visual
Impact of site
3.10 Another way of considering the visual impact
is to have regard to scale and local geographic features. Firstly, it is
important to remember that the proposed location is in an extremely flat area,
with visibility extending for miles. Large structures do not therefore get
“lost” or “blend in” to the landscape such as may be the case in mountainous/hilly/undulating
landscapes; they stick out like the proverbial “sore thumb”.
3.11 In terms
of scale, it is possible to assess the size of the proposed development in
terms of well known local and national monuments, as demonstrated by the
diagram below.
3.12
Another perspective is
that telegraph poles are approximately 10 metres tall, so the turbines proposed
would be 12 times taller. The turbines are also around 250% higher than high
voltage electricity pylons.
3.13
The only significant
local geographic feature is Brent Knoll, which is 129 metres tall. The proposed
turbine heights are up to 120 metres; i.e. 90% of the height of the Knoll. The
photograph below, which has been prepared by a professional photographer with
over 30 year’s experience, illustrates the relative scale of the turbines to
Brent Knoll. (The following photographs were prepared to reflect the visual
impact of turbines built to a height of 99 metres, which was the height
originally suggested by ecotricity)
Photomontage No: 1.
This view is from the Manor House on the slopes of the Knoll. This photograph
is the copyright of kNOll to wind farm action group.
Photomontage No: 2.This
view is from outside the village primary school. This photograph is the copyright
of kNOll to wind farm action group.
Photomontage No: 3. This view
is from the railway bridge in Stoddens Lane. This photograph is the copyright
of kNOll to wind farm action group.
Summary
3.14
Having regard to the factors set out in PPS22 at paragraph
3.2 above, and those in the Scottish Heritage “best practice guide”, it is
clear that because
·
The surrounding
landscape for miles is flat;
·
The turbines proposed
are amongst the largest proposed anywhere in the UK;
·
The turbines have a
very significant, tall, green, “backdrop” in the form of Brent Knoll- which
indeed is the only significant landscape feature for miles;
And
also having regard to the various forms of “Visual Impact” assessment models
set out above, the visual impact of the proposed scheme is highly significant,
and it would become a domineering feature of the local landscape.
CRITIQUE OF THE LANDSCAPE AND VISUAL
LVIA CHAPTER PREPARED BY THE DEVELOPER
The
kNOll to Wind Farm Action Group commissioned a Chartered Landscape Architect to
prepare the following critique to augment the previous chapter:
The
Landscape and Visual Impact Chapter which forms part of the Environmental
Statement accompanying the application for the Wind Farm at Inner Farm, near
Burnham on Sea follows the appropriate guidelines developed by the Landscape
Institute and Institute of Environmental Management and Assessment. However, having undertaken the process
appropriately, it is our opinion that the conclusions reached in section 8.12
are unjustifiably biased towards the development.
At
8.12.2 the assessment concludes that “Government guidance clearly states that
the wider environmental and economic benefits of renewable energy development
are material considerations which should be weighed against any dis-benefits
such as impact on the landscape”.
Whilst this may be correct in principle, the purpose of the chapter is
not to make judgments on this balance (which is for the Planning Authority to
decide) but solely to assess the impacts on landscape and visual amenity.
With
regard to each of the ‘reasons’ given that the windfarm is ‘acceptable in this
location’, we have the following comments:
i.
as set out in the separate planning statements, the
development complies with policies and guidance relevant to landscape and
visual impact at national, regional, county and local level;
Comment: It is a sweeping generalization to say that the
development complies with policies and guidance relating to landscape and
visual amenity. Whilst the development
may be compliant with some policies
and guidance, other policies need to be considered and it is the purpose of the
Planning Authority to take a view as to whether the development is appropriate
overall. Whilst PPS22 is quoted in the
assessment, other national guidance such as PPS7 is equally relevant as well as
various policies of the Local Plan which seek to preserve landscape character
and quality
ii.
the land on which the turbines are located is
undesignated and of medium sensitivity to wind turbine development;
Comment: It is true that the subject site is
undesignated. However, it does not
follow that a landscape of medium sensitivity is appropriate for turbine
development. The various landscape
character assessments referred to in the chapter emphasize the sensitivity of
the landscape around the Site. For
example, the Countryside Agency Assessment notes the significance of openness
and also specifically refers to important elements of local character including
the “dramatic and prominent hills such
as Brent Knoll…rising above the Levels and Moors” (para 8.4.2 of
LVIA). Likewise, the Land Use
Consultants’ Assessment notes the importance of the “sense of quiet and unspoilt rural charm” (para 8.4.5 of
LVIA). It is also of particularly
pertinent that this assessment states that the issue of scale of development is
important, noting that in this flat landscape “structures such as electricity pylons…demonstrate the more intrusive
impact of tall buildings”. By
inference turbines would have an even more significant impact. Whilst the assessment notes the opportunity
of screening for low level development this does not apply to the turbines, due
to their scale (8.4.8). The importance
of elevated viewpoints (such as the Knoll) in relation to potential development
sites are also recognized in this paragraph.
In fact, the LUC assessment notes that the area around the Site is of
“High Sensitivity” and the Brent Knoll area is identified as being visually
prominent and of “high quality landscape” (8.4.9).
iii.
the development is located over 6km from the Mendips
AONB and will not harm its natural beauty or character;
Comment: There will
be no direct impacts on the AONB and it is accepted that impacts would be
minimal. However, it would be more
accurate to conclude that the proposals “would not significantly harm its natural beauty or character” since some
distant views may be affected.
iv.
the turbines will not impact on the setting of any
Conservation Areas
Comment: Whilst the turbines will not be prominent in views
from any Conservation Area, there will inevitably be, at the very least, some
indirect impacts on the perception of the Burnham on Sea Conservation Area that
people travelling through the rural hinterland on the approach to the area
would experience.
v.
the turbines will not cause unacceptable harm to any
other features of cultural heritage interest such as Listed Buildings,
Scheduled Ancient Monuments, Historic Landscapes, or to their settings;
Comment: Brent Knoll
is a historic landscape, managed by the National Trust. The Site forms part of the setting of the
Knoll. Views from footpaths on the
Knoll would be significantly affected by the proposal. This effect is judged by many people to be
wholly negative and is accepted in the LVIA chapter to be of Major
significance. The viewpoints assessed
in the LVIA/photomontages are all summer views and the assessment was carried
out in the summer and early autumn months when the leaves would have still been
on the trees. There would potentially
be more significant views obtained, for example from the Grade 1 listed church
at Brent Knoll, in winter views when vegetation is not in leaf. This factor needs to be considered in
drawing conclusions as to the impact of the proposals on the setting of
historic features and their settings.
vi.
the proposed development does not cause unacceptable
harm to the essential characteristics of the Somerset Levels and Moors
landscape character type (Levels sub-area)
Comment: Table 8.8
sets out the conclusions with regard to landscape impact, including reference
to the Somerset Levels and Moors. It is
noted that there is one minor impact, two minor - moderate impacts, eight
moderate impacts, two moderate – major impacts and one impact of major
landscape significance (from the area around viewpoint 8). Turbines are not currently characteristic of
the Somerset Moors and Levels.
Therefore, there will be an inevitable impact on landscape character
which is judged to be significant.
Whether this impact is acceptable is, at best, subjective and it is the
view of the Knoll to Wind Farm campaign that it would in fact be
unacceptable.
vii.
the proposed development will not, in combination
with other currently proposed wind turbines, cause any unacceptable cumulative
impact to the features and characteristics listed in iv) to viii) above;
Comment: Whilst the assessment has considered the proposals
in relation to the West Hinkley Proposals, cumulative impact is also relevant
in terms of existing detracting non-rural features around the Site and the
potential for future proposals at Inner Farm.
The
assessment refers on several occasions (e.g. at para 8.5.10) to the detracting
influences of such features as the M5 and the Sanders Garden World nursery on
rural character, whilst accepting that the area around Inner Farm maintains a
strip of rural character between Brent Knoll village and Burnham maintaining
“very pleasing” views. It should be
recognized that the construction of the proposed wind farm has potential to
interact cumulatively with these urbanizing features, particularly in the
sensitive views obtained from footpaths on Brent Knoll, creating an
industrialized setting for the Knoll and divorcing it from its rural
setting.
The
assessment has also stated that five large turbines is the optimum layout in
terms of visual amenity/energy yield and is “less cluttered” (see 8.7.9 and
8.7.14). This presupposes that
development of any turbines in this location is necessary at all. Also, there is concern that once five
turbines have been erected there would potentially be an easier case for any
future developer to argue that the visual damage had ‘already been done’ and
that, therefore, additional turbines would have a lower impact. Accordingly the potential for future
cumulative impacts in this location needs to be considered when determining
this application and/or planning conditions imposed (should the development be
granted) that no more turbines would be permitted in proximity to the current
proposals.
viii.
the layout is sympathetic to the scale of the
existing landscape;
Comment: There are five 78.3 metre high turbines proposed
with 41 m long blades leading to a total height (stated at para 8.3.1 of the LVIA) of up to 120 metres,
constructed on land lying at 6 metres AOD.
That total height of the turbines would fall around only 13 metres lower
than the upper point of the Knoll (at 139 metres AOD), which is recognized as a
prominent local landscape rising above a smaller scale farmland landscape. Therefore, it is difficult to justify this
statement; for example were electricity pylons of a similar scale being
proposed then it is hard to imagine that anyone would support this
statement. Indeed, the assessment
accepts that, when viewed from the top of Brent Knoll or against the backdrop
of Brent Knoll, the pylons are “prominent
and uncharacteristic” (para 8.6.8 and 8.6.37 respectively).
The subjectivity of this conclusion is also emphasized with reference to
the analysis of viewpoint 3 (para 8.6.14), where the localized and inevitably much
smaller impact of a telegraph pole is considered to somewhat detract from the
rural and peaceful character.
ix.
the proposed turbines are well-designed, slim,
elegant structures;
Comment: This may be true when viewed against other turbine
designs. However, they are also very
large, tall and imposing structures which are uncharacteristic of the
locality. Whilst a well designed
structure is preferable to a poorly-designed one, it is considered that no
design could render these large and intrusive structures acceptable in the
local context of Brent Knoll/Burnham.
IMPACT ON VISUAL RECEPTORS
Moreover,
whilst addressed in the LVIA, the conclusion does not refer specifically to the
visual impact on sensitive receptors
in the surrounding landscape such as the public footpaths running across,
around and overlooking the Site, local residents and workers as well as those
travelling on local roads.
The
applicant’s information demonstrates that there are relatively many public
rights of way crossing and surrounding the Site. These are also in close proximity to the caravan and camping park
which also emphasizes the attractiveness of this area and its importance for
casual recreation.
At
Paragraph 8.2.9 it is stated that the ZVI mapping clearly illustrates the
effect of topography in “screening” such views. Figure 8.2 actually demonstrates that a very narrow funnel free
from visual influence would be created to the north of the development and, in
fact, topography alone has very little influence on the potential visibility of
the turbines.
Based
on the applicant’s assessment of the fourteen representative viewpoints
assessed (see for example Table 8.7) only one was considered to be of minor
significance, with seven moderate, one moderate-major and five of major
significance. Therefore, had
conclusions related to impact on visual receptors been included, then based on
the findings which are already set out in LVIA, the appropriate conclusion
would have been:
The turbines will cause an effect of
major significance on a number of visual receptors, particularly on sensitive
views obtained from Brent Knoll and local footpaths close to the subject site,
as well as impacts of moderate significance elsewhere.
It
is noted that a major effect is recognized to be one which in isolation could have a material influence on the decision-making
process and should particularly influence the decision-making process in
combination with other identified effects.
The author of the LVIA chapter notes that the value of the effect is
subjective, which is of course correct.
However, a large number of those visual receptors who would be directly
affected by the proposals, including the Knoll to Wind Farm group, are clearly
of the opinion that this effect would be negative.
Accordingly,
despite the conclusions presented at the end of the Landscape and Visual Impact
Assessment, the major significant impacts on landscape and visual amenity
identified in the main body of the applicant’s LVIA chapter are of considerable
importance and will require very careful consideration by the planning
authority in coming to the conclusion as to whether the development is
acceptable.
Summary
3.15
Having regard to the factors set out in PPS22 at
paragraph 3.2 above, and those in the Scottish Heritage “best practice guide”,
it is clear that because
·
The surrounding
landscape for miles is flat;
·
The turbines proposed
are amongst the largest proposed anywhere in the UK;
·
The turbines have a
very significant, tall, green, “backdrop” in the form of Brent Knoll- which
indeed is the only significant landscape feature for miles;
And
also having regard to the various forms of “Visual Impact” assessment models
set out above, the visual impact of the proposed scheme is highly significant,
and it would become a domineering feature of the local landscape.
IMPACT ON FLORA AND FAUNA
Impact on birds and bats- “Eagle Slicers”
3.16
In some parts of the
world, wind turbines are colloquially known as “Eagle Slicers”- a description
that requires no further elaboration. As more and more research emerges into
the detrimental effect wind turbines can have on bird life, leading bodies such
as the Royal Society for the Protection of Birds [“RSPB”], have significantly
changed their views on wind farms. Recent research in Norway which shows that
wind turbines have caused the deaths of a number of rare white-tailed eagles
and led to many more to go missing, led Mark Avery, the RSPB’s Conservation
Director to comment as follows:
“These
findings are shocking, yet may only be the tip of the iceberg. Research [on the
islands in Norway] is being stepped up and if more dead birds are found, and
even fewer are able to breed, we will be doubly determined to fight wind farm
plans that could cause similar destruction in the UK.”.
Bird life in the proposed area
3.16 A
wide range of bird life is found in the proposed area- both those types that
are domiciled in the region for all or parts of the year, and those that
migrate through the region. Species found in the area include;
|
Large birds |
Medium sized birds |
Small birds |
|
|
·
Starling |
|
|
·
Hedgesparrow |
|
|
·
Swallow |
|
·
Moorhen |
·
House martin |
|
·
Coot |
·
Thrush |
|
|
·
Blackbird |
|
|
·
Pied wagtail |
|
|
|
·
Blue tit |
|
|
|
·
Great tit |
|
|
|
·
Wren |
|
|
|
·
Gold crest |
|
|
|
·
Robin |
|
|
|
·
Skylarks |
|
|
|
·
Long tailed tit |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
3.17 It
can be seen that the area, with a rare combination of wetland, meadows, hedges,
woodland, and hill, supports a highly diversified, and large, bird population.
Whilst many bird types are protected, some of these found locally are
particularly rare- such as
·
Marsh harriers;
·
Barn owls;
·
Lapwing;
·
Fieldfare;
We understand from residents in Berrow that the
nesting grounds for Lapwings in the East Brent/Lympsham/Berrow area are one of
a few such areas left in the UK. Recently the RSPB published remarkable evidence of
the re-establishment of the Marsh Harrier, a bird whose survival is still
threatened in this country. These birds are often seen on The Somerset Levels
as they migrate from their permanent homes in Norfolk, and it is not uncommon
to see these magnificent birds on Brent Marsh. Can we afford to see these
beautiful birds “sliced”?
3.18 The
proximity of the area to major wildlife centres on the Somerset moors is likely
to raise a number of different and, sometimes, new issues. It is recognised that
wind farms can "act as barriers to
bird movements" and that some birds "do not like living within or next to wind farms and are therefore
displaced." Bird movements across this area, however, occur at all
times of the year. They are not just concerned with migration paths. As there
are numerous wildlife centres near to the site, movements to and from the
refuge for feeding, mating and nest building frequently cross Brent Marsh.
3.19
These are obvious
concerns. Yet other problems can occur, for instance, if large flocks of
starlings, which have recently been attracted to a local reserve in
considerable numbers, do not have adequate feeding grounds within a reasonable
distance from that reserve. Exclusion of an area this size may have a
considerable impact as they have become regular visitors to the farm. This
could also apply to the lapwings which congregate here at certain times of the
year and the skylarks which migrate here in the summer. Will any of these
populations be under threat because of this loss?
3.20 The
large population of buzzards around the Knoll reflect the re-establishment of
this species over the past few years.
Will the proposed development at Inner Farm become known as the “Buzzard
Slicer”? There is also a very large rookery on the Knoll and the birds traverse
the Inner Farm site on a twice daily basis for at least 7 months of the year.
The developer does not acknowledge this in the Environmental Statement.
3.20
The report published by
the Sustainable Development Commission, "Wind
Power in the UK," notes that "there
remains a dearth of studies into
the displacement effects on birds of the onshore wind farms in upland Britain and the scientific knowledge
is therefore scant." This comment
is contrasted to coastal habitats (i.e. the sea shore and associated dunes) where, there is generally more evidence"
and makes no comments on lowland areas
as "the majority of onshore wind farms are based in upland areas."
This suggests that special research is
essential before any conclusions can be reached about the possible concerns and effects at this particular
lowland site.
It
goes on to say that problems for birds can be caused due to "fatal collisions with turbines" and
from "loss of habitat due to the
development of roads and turbine bases." Whether construction (and
later possible decommissioning) will have lasting effects is not properly
understood.
3.22 The Centre for Evidence-based Conservation
(“CEBC”) at Birmingham University have published a recent paper known as
“Systematic review no. 4 : Effects of wind turbines on bird abundance”,
reviewing a range of studies on the subject matter. It concludes:
“Available evidence
suggests that wind farms reduce the abundance of many bird species at the wind farm
site. There is some evidence that Anseriformes (ducks) experience greater
declines in abundance than other bird groups suggesting that a precautionary
approach should be adopted to wind farm developments near aggregations of
Anseriformes and to a lesser extent Charadriformes particularly in offshore and
coastal locations. There is also some evidence that impact of wind farms on
bird abundance becomes more pronounced with time, suggesting that short term
bird abundance studies do not provide robust indicators of the potentially
deleterious impacts of wind farms on bird abundance.”
Bats
3.23 There are numerous bat colonies around Brent
Knoll. In early summer evenings, bats are frequent sights to residents with
gardens backing on to Brent Marsh, and walkers on the footpaths there, as the
bats feed on the numerous insects which live around the wetlands. The
Environmental Statement is scant on details on these protected animals.
3.24 We
understand that one of the reasons for the application for a similar wind farm
at West Hinkley, Nr. Stogursey, being turned down was the threat of such a
development to local bat colonies.
Wild
animals
3.25 The rare combination of wetland,
agricultural land, meadow, wood and hillside around Brent Marsh plays host to a
wide range of wild animals, large and small. These include;
·
Foxes;
·
Badgers; see below
·
Rabbits;
·
Hares- see below;
·
Squirrel;
·
Deer;
·
Water vole;
·
Otter-occasionally;
·
Rats, mice, voles and
shrews; and
·
Various amphibians and
reptiles;
3.26 UK Bio Diversity Action Plan exists for the
brown hare and part is re-produced
below.
“Formerly
considered abundant, the brown hare appears to have undergone a substantial
decline in numbers since the early 1960s, with population estimates now varying
between 817,500 and 1,250,000 Similar patterns of population change appear to
have occurred throughout much of Europe.”
A
very well known and sadly missed expert on brown hares was Tony Holley, who
lived in Brent Knoll. Recognised for his research we are sure he would be
saddened that numbers of lepus europeaus still decline, and that the local
population is further threatened by the “industrialisation” of Brent Marsh.
This may be a fight they can’t win!
Badgers are numerous on The Knoll and transverse Brent Marsh.
The Environmental Statement issued by the developer was prepared in just two
weeks at the end of September 2005. Has the developer completed a thorough
enough assessment of the ecology of the area, and does it comply with PPS9 and
DEFRA’s advice to planners?
Reptiles and amphibians
3.27 The area
in and around Brent Marsh is home to a range of reptiles and amphibians- indeed
in ancient times the Knoll was known as the “Isle of Frogs”! These species
include;
·
Greater Crested Newts*;
·
Frogs;
·
Toads;
·
Slow worms; and
·
Grass snakes.
The following is an extract from ecotricity’s
Environmental Statement. It clearly
states that Great Crested Newts are known only 2km from the site. It also clearly states that further
investigation is needed, and apparently
none has been conducted. Planners must ensure that these amphibians, if present, are protected
during and after the construction stage.
The piece is copyright of ecotricity
*
We understand that the protection of a population of Greater Crested Newts was
a Planning consideration when consent was given for the development of the
nearby Isleport Business Park.
Any
disturbance to a balanced eco-system in and around Brent Marsh- particularly
the drainage system, may have significant repercussions for such species.
Domesticated animals
3.28 The area
is also home to pastoral animals such as sheep and cattle, as well as a large
number of horses. We are not aware of the implications to pastoral agriculture
of such a development, but the significant impact on horses is covered under
“Social Impact” at Section 5.0.
Summary
3.29 A well balanced, bio-diverse local
eco-system has developed around Brent Marsh over hundreds of years. The
proposed development is one of the most significant threats to this balance
that the area has faced- probably since the area was drained a few hundred
years ago.
IMPACT ON LANDSCAPE QUALITY
3.30 A
further key consideration in terms of Environmental Impact is the quality and
“scarcity” of the landscape which is threatened with development. The area
known as Brent Marsh is an area of high landscape quality and scarcity.
Sedgemoor District Council has recognised this itself in the Local Plan, which
states at Policy CN17
“
A development which would adversely affect the distinctive features of the
local landscape (for example the Somerset Levels and particularly Brent Knoll
itself) will not be permitted”
So
how important is the local area?
3.31
A picture,
shown here, appears on the DEFRA Rural Affairs website for the Somerset Levels and Moors ESA
(Environmentally Sensitive Area). It
is a landscape which is remarkably similar to that seen on the Inner Farm site between Edithmead and Brent
Knoll (although not named, it is
almost certainly Brent Knoll in the background). Its inclusion raises a number of questions concerning the small
difference existing between the ESA
areas and the Inner Farm site:
3.32 DEFRA
defines ESAs as "farmer managed"
sites, "which offer protection for
some of our rarest plants (orchids, cornflower) and establish a suitable
environment for the recovery of native species (brown hare, otter, water vole).
They also claim that environmental benefits include, "protection of historic features, such as ancient field systems."
3.33 Amongst
the 22 ESA sites in England the one which is most pertinent is that of the
Somerset Levels and Moors. It is described as "of outstanding environmental interest" and "the network of ditches is of special
interest for aquatic flora and invertebrates." The only reason given
for excluding the adjoining area, extending westward from the moors to the
coast of the Bristol Channel, is that the Levels (as they call them) "are an extensive area of slightly higher
estuarine alluvium."
3.34 However,
when we look at the criteria established for all the areas covered, we see that
the plants and native species mentioned are also found in the area
traditionally known as Brent Marsh (the term 'moor,' as used in Somerset, is
derived from the same root as 'marsh'). Because of its very slightly higher
level most of the fields are not quite as waterlogged as those in the ESA area.
Even so, in wet years, many of the fields forming part of Inner Farm, including
those with which this planning application is concerned, are under water for
weeks and, sometimes, months.
3.35 DEFRA,
asked to comment on the suitability of ESAs and Environmental Stewardship lands
for wind farms, responded by stating (via personal email to a member of the kNOll
to Wind Farm Action Group), "ESAs
and Environmental Stewardship do not have any status or powers in the planning
process. Decisions on whether permission will be given for a wind turbine to be
erected will lie with planners who will be taking into account all local
aspects, including all the environmental aspects addressed by the
agri-environment schemes."
3.36 This
supports a view that, for Planning purposes, the precise boundaries of ESAs are
irrelevant, and that the important consideration is whether a locale as a whole
is environmentally sensitive. Large parts of Sedgemoor would clearly appear to
fall into this category.
3.37 It
should also be noted that ESAs are now running down (no new designations have
been made for some time now and each lasts for a maximum of ten years). The new
scheme replacing it, Environmental Stewardship, is not tied to specifically
designated areas, as the previous scheme specifically did, but provides for a
more general approach to the concerns of farming in sensitive areas wherever
they happen to be. This suggests that the government has realised that closely
designated areas are not the solution. Now it is possible to designate any area
which can be demonstrated as of environmental importance as a Stewardship area.
3.38 Dwight
Peck, Communications Officer for the Convention on Wetlands (RAMSAR) in Geneva,
has stated (again via personal email to a member of the kNOll to Wind Farm
Action Group) that they have "no
policies against any specific land uses." An environmental impact
Analysis would, of course, be required "to ensure that the planned development would not cause any change in
the ecological character of the site."
3.39 Simon
Nash, Chief Executive of the Somerset Wildlife Trust, has commented on the
problems of wildlife sites in Somerset in a recent promotional document for
Triodos Bank (also quoted as the Bank used by the developer). They have opened
a "Wildlife Saver Account" in conjunction with both the Dorset
Wildlife Trust and the Somerset Wildlife Trust. Simon Nash stated, "Most conservation sites are too small, too
isolated and don't have the right qualities to sustain wildlife." The
obvious implication is that he believes the hinterland of these sites is
extremely important to sustain their objectives. "No man is an island,
entire unto himself" said Donne. That is even truer when looking at the
implications for wildlife sites.
3.40 Presumably
ecologically sensitive areas and wildlife areas will only be excluded from the
assessment if there is some concern about the effect that wind farms will have
on the wildlife present there. The fact that ecotricity has claimed "there were very few places in the whole
region (that covered by Sedgemoor District Council) that were suitable for a wind farm," suggests that it feels
there are concerns about the impact of wind turbines in these areas.
Historic
landscape
3.42 Not only is this a landscape of unusual environmental quality, it
is a landscape of historical importance, occupied by mankind for thousands of
years.
3.43 The top
of the Knoll, looking down over the proposed development, is owned by the
National Trust, and is the site of Bronze and Iron Age settlements. Later it
was occupied by the Romans, who built a temple there, and Roman coins of the
Emperor Trajan (AD98 -117) and Septimus Severus (AD145 - 211) was found in an
urn on the Knoll in 1610.
3.44 A few
centuries later the Knoll was used as a look out post for firstly Anglo-Saxons,
and later Vikings coming up the Severn on raids/looking for areas to settle.
3.45 The
South-East slopes of Brent Knoll, overlooking Brent Marsh, was the site of a
historic battle in 875 AD where the Saxons defeated the invading Danes.
3.46 Edithmead,
where Inner Farm farm house is located, also has strong historical connections,
being named after Queen Edith, wife of Edward the Confessor, and mother of King
Harold- of 1066 and Battle of Hastings fame. It was Edith who handed the keys
to Winchester, the capital of Wessex, to William the Conqueror. This
association with Brent Marsh is due to the fact that she is reputed to be buried close to the proposed
access route to the Wind farm.
3.47 The area
is also mentioned in William the Conqueror’s “Doomsday Book”, commissioned in
1086.
3.48 The network of ditches around all the fields locally, were
originally established by the Abbots of Glastonbury in the late medieval
period, which also implies that the field systems in this area are long
established; most still retaining the rhynes around their borders established
by these various Abbots.
3.49 St.
Michael’s Church, Brent Knoll has a Norman doorway and a Nave dating from 1290
AD. This is another one of the key historic features in the area that would be
obscured by the proposed development.
3.50 During
the English Civil War in the Seventeenth Century, Royalist soldiers ran amok in
the village around St. Michael’s church, and local residents under the
leadership of John Somerset rallied around to fight and defeat these intruders.
3.51 It is
also speculated, that the top of the Knoll and areas around it also featured as
look out posts and retreats for soldiers during the “pitchfork” rebellion led
by the Duke of Monmouth in 1685 , which culminated in the Battle of Sedgemoor a
few miles away.
3.52
At least 16 houses in
the area date from the seventeenth and eighteenth centuries, and many are
listed Grade 2.
The conservation of
these is likely to be negatively impacted by the development [See Section 4.0
below on Economic Impact]. Certainly their outlook will be changed considerably
from an idyllic rural view to an industrialised agricultural view.
3.53
In AD 1837 a Chapel was
erected by the Bible Christian Society. The founder of Methodism, the preacher
John Wesley once climbed the Knoll and declared:
"I know not wherever I saw
such a prospect."
3.54 There can be no doubt of the historic importance of the area of
Brent Marsh and its immediate surrounds. The proposed development will not be
keeping with such a landscape, so jealously protected and sympathetically built
over thousands of years.
IMPACT
ON DRAINAGE SYSTEMS
3.55 It
is also important to consider whether the development would impact the local
landscape by changing the drainage characteristics of an important area of
landscape and agricultural use. It has been clearly established that this is an
important and historic area of wetlands, drained by rhymes created hundreds of
years ago, yet still prone to flooding on occasion. The Environment Agency
details the Brent Marsh as an area of extreme flood. The map below is shows
this clearly. The dark blue shows areas prone to sea and river flood and the
light blue shows areas prone to flood due to heavy precipitation.