North Norfolk District Council Conservation, Design and Landscape MEMORANDUM To: Geoff Lyon Ref: PF/13/0033 From: Kerys Witton, Landscape Officer Date: 25 March 2013 Re: Erection of two wind turbines each with a maximum blade tip height of 126.5m high together with substation and control building, access tracks and other infrastructure. Scottow Estate, land off Potspoon Hole, North Walsham Road, Scottow. This appraisal of the impacts of the proposed development on landscape character, visual amenity and ecology, should be read in conjunction with the assessment by the Conservation, Design and Landscape Manager regarding the impact on heritage assets. The Landscape Section have sought to critically appraise the documents contained in the Environmental Statement in relation to the landscape and visual impact and the ecological impact within North Norfolk District Council’s administrative area, and offer opinion on the perceived impacts of the development in relation to Council policy, national guidelines and relevant legislation. The Landscape Section considers that the significant issue of the proposed development is the impact on visual amenity. The impact of the wind turbines is far greater for visual receptors within the immediate vicinity of the development than for the wider landscape character. This is important in the context of Policy EN2 which aims to preserve, and where possible enhance, the landscape character of North Norfolk in accordance with the recommendations outlined in the North Norfolk Landscape Character Assessment (NNLCA) Supplementary Planning Document. The submitted Landscape and Visual Impact Assessment (LVIA) concludes that although there would be localised significant impacts, the overall effect on the landscape resource of the study area is not considered to be significant. Although the Landscape Section considers that some aspects of the LVIA could be analysed or interpreted differently, the overall conclusions are generally agreed with. The Landscape Section concurs with the assessment and suggests that the proposals are compliant with Policy EN2. However, in the determination of the application the impact on residential receptors should not be underestimated and the benefits of the development in terms of renewable energy must be balanced with the significance of the impact to residents. In respect of ecological impact, including impact on birds, the turbines have not been assessed as having a significant impact under the EIA Regulations, and the Landscape Section considers that the application is compliant with Policy EN9 of the Core Strategy. The Landscape Section does not therefore object to the application with respect to the impact on Landscape Character (policy EN2) and biodiversity (policy EN9). The full critical appraisal of the application is appended to this document. Regards Kerys Witton Appendix – to be read in conjunction with the memorandum Landscape and Visual Impact Assessment (LVIA) Landscape Character The submitted LVIA states that it has been prepared in accordance with the Landscape Institute’s Guidelines for Landscape and Visual Impact Assessment (GLVIA 2002), and generally this is acknowledged by the Landscape Section to be correct. The Landscape Section consider that the scope of the assessment including the study area, zone of theoretical visibility (ZTV), value judgements and assumptions, consultation process and cumulative assessments are appropriate for the type of development proposed; and the potential impacts associated with landscape character and visual receptors have been correctly identified. The methodology of the LVIA focuses on defining and evaluating the sensitivity and capacity of the landscape resource. Whilst the majority of the methodology is generally concurred with, the Landscape Section considers that too great an emphasis has been placed on the ‘value’ and ‘quality’ of the landscape in the Sensitivity Assessment, and should have recognised the constituent parts of the landscape for their own inherent contribution to the landscape character and not just perceived ‘quality’. Placing too much emphasis on ‘quality’ can lead to a more subjective landscape appraisal that is open for conjecture. Additional concerns arise in that the Sensitivity Assessment does not use the same comparators in its three-point scale of High, Medium and Low criteria, comparing the level of distinctiveness of the character, the value of the landscape and the ‘unimportance’ of the landscape as defining criterion. However, these discrepancies within the LVIA methodology are not seen to be an overall failure of the LVIA and can be interpreted as alternative techniques and criteria for judging capacity and sensitivity within the appropriate guidelines. It is worth noting that for the purposes of the LVIA only impacts of moderate and substantial have been considered to be significant in terms of the EIA Regulations. The Landscape Section is satisfied that this is appropriate. The baseline condition assessment in the LVIA considers the various landscape designations that might affect the ‘quality’ of the landscape character; however designated Conservation Areas have not been included in this assessment. The Landscape Section considers that the LVIA should have recognised the contribution that Conservation Areas can provide to landscape value, and by excluding them is a failure of the LVIA. The lack of acknowledgment of Conservation Areas is important within the assessment, as the former RAF Coltishall airbase has been designated as a Conservation Area and is immediately adjacent to the proposed development. Rather than being seen as an asset, the former airbase has been used as justification for the reduction in the sensitivity assessment of the Low Plains Landscape Character Type baseline assessment. Given the heritage value of RAF Coltishall, as noted at the beginning of this memorandum, these comments should be considered alongside the Conservation, Design and Landscape Manager’s comments on heritage impacts. In the critical appraisal of the LVIA, the Landscape Section have considered the given baseline analysis of the Landscape Character Types and evaluated this against the North Norfolk Landscape Character Assessment (NNLCA) SPD. On occasion it is questionable whether the LVIA baseline condition assessment adequately appraises the ‘robustness’ of the landscape as the focus is heavily on scenic quality and value. For example, the baseline assessment of the Large Valleys Landscape Character Type (NNDC) classifies the scenic quality of the landscape as medium, with a medium to high sensitivity to change. This fails to recognise the lack of negative components within the landscape and the intactness of the rural landscape character. However, the Landscape Section considers that overall the baseline condition assessment provides a fairly representative appraisal of the landscape character within the study area upon which to assess the effects of the development. Although the sensitivity of the Broads and the AONB has been classified as high, the LVIA concludes that the impact of the proposals will be negligible due the ‘indirect nature of the changes’, potential effect on designated interest features and the distant proximity of the proposed development from the designation. The Landscape Section concurs with this assessment and considers it a fair appraisal of the potential impacts. Of the Registered Historic Parks and Gardens within the study area and North Norfolk, Beeston Hall was identified with a slight adverse effect principally due to proximity to the development, however intervening vegetation reduces the potential impact. No other notable impacts were identified affecting the other designated landscape assets (other than the aforementioned RAF Coltishall Conservation Area), and the Landscape Section does not disagree with this assessment. Although the Landscape Section has questioned elements of the LVIA appraisal on landscape character, it is not considered that these issues would have a significant effect on the overall appraisal or outcome of the impact. The Landscape Institute guidelines allow for different approaches to LVIA assessment and the methodology in this LVIA is clearly defined. There is an element of subjectivity to the assessment process and this is recognised by the Landscape Section. Visual Amenity Part of the LVIA seeks to identify the impact of the proposed development on visual amenity, focussing on the potential change in views and the extent of the effect from representative viewpoints, residential receptors and significant routes. Twenty-one viewpoints were selected within the 35km study area in consultation with North Norfolk District Council, Broadland District Council, The Broads Authority and Natural England. The LVIA indicates that for each viewpoint a wireframe diagram was produced, together with photographs and photomontages for fifteen of the selected viewpoints. In addition an analysis was carried out for all main route receptors (including roads, railways and footpaths) within 15km of the proposed turbines, together with a residential receptor appraisal for properties within 2km of the development. The methodology of the assessment is robust and it is considered that the appraisal identifies the key visual receptors and viewpoints that may be impacted by the development. The Landscape Section acknowledges that the assessment adheres to current best practice (Visual Representation of Windfarms: Good Practice Guidance, Scottish Natural Heritage, 2007). The affect on visual amenity has been classified according to a four-point scale, ranging from Negligible through to Substantial Adverse, with Moderate and Substantial effects considered to be significant under the EIA Regulations. The Landscape Section is satisfied that this is appropriate. Figures 5.6 to 5.8 of the LVIA graphically illustrate the effect of the proposed turbines on the representative viewpoints, route receptors and residential receptors. The maps are useful to identify the scale of the effect and to gauge geographical extent. Within North Norfolk District Council the main visual effects of the development will be experienced from the southern edge of Scottow; Arch Farm, Swanton Abbott; Skeyton Church and the A1151, Hoveton. Viewpoints beyond 6km of the development were assessed as only having slight adverse or negligible effects due to the diminishing prominence of the turbines in the views. It is worth noting that the ZTV indicates that all A, B and minor roads within the 15km study area would experience views of the proposed turbines, however site appraisal suggests that these views are likely to be filtered by roadside trees, hedgerows, foreground trees and housing. For this reason the impact on route receptors has been assessed as being ‘locally’ significant, where appropriate, due intermittent and localised views from the routes. Overall, the LVIA identifies that six viewpoints and twelve residential receptors (or groups) are expected to experience significant visual effects (in terms of the EIA Regulations), with four route receptors receiving localised significant effects which extend beyond the boundary of NNDC. The LVIA concludes that the significant visual effects of the proposed turbines are limited to within 6km of the development. The Landscape Section considers that the impact appraisal on visual amenity is an accurate representation of the expected effects of the development. Of cause for concern is the moderate to substantial adverse impact predicted for twenty-six individual properties located around the development site, and although the predicted impacts aren’t expected to be “overbearing” it should be recognised that these properties would experience deterioration in the existing view with a significant detracting feature. It is unusual that mitigation measures, such as the introduction of planting, haven’t been proposed where substantial impacts have been identified. This could be due to land ownership issues or physical impracticalities; however opportunities may exist to ameliorate some of the impacts on residential receptors and could be explored further. LVIA summary/statement of significance/Conclusions The LVIA does not identify any landscape character or visual amenity cumulative impacts associated with other wind turbine development within the study area. The Landscape Section does not dispute this conclusion. The LVIA concludes that the significant effects of the development are limited to within 6km of the proposed turbines, locally affecting two landscape character types and less than ten visual receptors (or groups). No significant effects were identified beyond 6km of the development or on any designated landscapes. In terms of the EIA Regulations the LVIA concludes that the overall effect on the landscape and visual resource of the study area as a whole is considered not to be significant. The Landscape Section concurs with this assessment in relation to the EIA Regulations. Policy EN2 of the Core Strategy states that development proposals should be informed by, and be sympathetic to, the distinctive character areas identified in the NNLCA. In addition, development proposals should demonstrate that their location, scale, design and materials will protect, conserve, and where possible, enhance inter alia the special qualities of the area, the pattern of distinctive landscape features, and visually sensitive skylines. The development has been supported by an LVIA which has assessed the impact of the proposals on the local landscape character in accordance with the NNLCA. The LVIA has assessed the magnitude of the impact on the local character areas and demonstrated that the impact will be limited to within 6km of the proposed turbines. The Landscape Section considers that the significance of this impact on the overall character of North Norfolk does not warrant refusal under guiding principles of Policy EN2 and does not raise an objection in this respect. Ecological Impact Assessment (EcIA) The Ecological Impact Assessment was carried out by Wild Frontier Ecology Ltd in accordance with the Guidelines for Ecological Impact Assessment (Institute of Ecology and Environmental Management (IEEM) 2006). The methodology and processes of the assessment are clearly set out in the report together with clarification of the definitions and criteria used for the assessment. The Landscape Section is satisfied that the methodology of the assessment has been carried out appropriately and in accordance with current best practice and have a high degree of confidence in the appraisal results. It is worth noting that in terms of the EIA Regulations, a significant impact has been defined as one that has a major or intermediate negative impact (i.e. affecting the integrity of a defined site or ecosystem or the conservation status of habitats or species within a defined geographical area) or a positive impact. The value of the ecological receptor was used to define the significance of the impact on a geographical scale, with receptors classified at the ‘parish’ level or above being considered sufficiently valuable for a significant effect to be material in the decision making process. In addition, within the scope of the EcIA, the likelihood that a change or activity will occur as predicted and the degree of confidence in this prediction is also important and will affect the overall assessment of the impact. The Landscape Section concurs with this approach in the assessment methodology. Two Phase 1 Habitat Surveys were conducted (the second was to account for a change in the turbine location) together with comprehensive bat surveys and a badger survey. Although a pond was present within 500m of the development, a great crested newt survey was not undertaken due to accessibility problems associated with fencing and vegetation. The Landscape Section is confident that the survey effort was sufficient to establish the baseline ecological conditions across the site. The potential impacts of the proposed development can be divided between those associated with the construction (and decommissioning) phase of the development and the operational phase. The construction phase may result in the loss or fragmentation of habitat, degradation in habitat quality, and noise and disturbance impacts to individual species. These impacts could occur as a direct result of the physical requirements of the turbines and/or access roads, or through construction traffic and personnel. The operational impacts of turbines are generally associated with the disturbance/avoidance effects of the turbines and the potential for collision impacts to occur. The disturbance and avoidance effects include the abandonment, either temporary or permanent, of areas of wildlife significance. The overall operational impacts of the turbines are most relevant for volant (flying) organisms, specifically birds and bats. Survey Results The results of the Phase 1 surveys identified habitats typically found within arable farmland, including hedgerows (with and without trees), dry-ditches and semi-improved grassland. Of note is the presence of two mid-sized, mixed plantation woodlands either side of the development site, and a green lane running south-west to north-east approximately 300m to 400m south-east of the site. Designated nature conservation sites have been identified within 10km of the proposed turbines, and include the Broads SAC, Broadland SPA, and Westwick Lakes SSSI. Several County Wildlife Sites have also been identified within 5km of the site with the closest being 2.3km away to the north. There are no designated nature conservation sites within 500m of the development site. The bat surveys revealed nine species of bat within the study area, of which the most abundant species were common and soprano pipistrelles. No bat roosts were confirmed within the study area, and bat activity was concentrated along the hedgerows and green lane. As expected no bat activity was observed over the open fields. No badger activity or sett was recorded within 50m of the proposed works although badger activity was recorded within the study area. Given the sensitivities surrounding badger data and the public nature of this document, it is not appropriate to identify the exact details of the badger survey results. However, the results of the surveys have been inspected and verified by the Landscape Section and the conclusions which can be drawn from the survey results are likely to be accurate. Impact Assessment Designated sites/habitats The EcIA concludes that there are no expected impacts to the special interest features of the designated conservation sites (this assessment does not include ornithological impacts which are assessed under a separate section of the ES) within the study area. In addition, limited impact will occur to specific habitats, as the majority of the construction will take place on an arable field with the exception of the access route, although some tree pruning will be required. The impact on habitats is deemed neutral. The Landscape Section concurs with the conclusion of the EcIA. Great Crested Newt The EcIA identifies the presence of great crested newt records within 2km of the development site (within the former RAF base). In addition a single pond was also identified within 10m of the new access track and 215m and 220m respectively, away from the two proposed turbines. As noted previously the pond was not surveyed for the presence of great crested newt due to health and safety/accessibility reasons, therefore it cannot be conclusively determined whether newts use the pond for breeding or whether the pond is important for a meta-population of great crested newts. Terrestrial habitat favourable to great crested newts is also evident around the development site, such as woodland, hedgerows and rough grassland, although the arable field is not suitable habitat. The EcIA states that the records identified at RAF Coltishall are likely to indicate that there is a medium sized population of great crested newts in the area. Due to the relative abundance of great crested newts in Norfolk, any newts found at the site are likely to be of local/parish value. Whilst the ‘value’ is relevant in terms of the impact significance in the EIA Regulations and the proposed development, it should also be recognised that great crested newts are a European Protected Species and are therefore subject to the protections afforded by the Habitats Regulations (2010). The report states that there is the potential for increased mortality to great crested newts during construction, which would result in an offence being committed under the Habitats Regulations. However, the report goes on to state that the potential for disturbance (and potential mortality) is reduced by the nature of the construction impacts (e.g. works mainly undertaken during the daytime) and by the location of the construction impacts (i.e. in areas unlikely to support great crested newts such as the arable field). The EcIA concludes that due to the numbers of great crested newts likely to be affected by the development, the effect on the local/parish population of great crested newt are “considered extremely unlikely” and not significant under the EIA Regulations. The risk of an offence being committed under the Habitats Regulations can be further reduced by undertaking precautionary best practice measures in relation to the construction. Based on the above assessment the extent to which great crested newt will be affected by the development has been established by the EcIA as not significant, and measures for their protection identified. In accordance with the guidance contained in paragraph 99 of Circular 06/2005, the Landscape Section conclude that if these measures are secured via a condition of planning permission then the Council will have considered the application in relation to impact on great crested newt in accordance with their statutory duties. As a result, it would be highly unlikely that an offence would occur under the Habitats Regulations as a result of the proposals and the Landscape Section would not raise an objection in this respect. Badger The report indicates that construction work required for the turbine will not disturb a known badger sett, although the potential for construction activity to impact on badger foraging activities is possible although the likely impact is reliable. Based on the assessment of impact, no significant impact on badger is expected as a result of either construction phase or operational phase of the development subject to the proper implementation of mitigation procedures. The Landscape Section considers that the impact assessment is a fair conclusion and does not consider that badgers or setts will be adversely affected by the development. Bats As noted earlier the operational aspect of the development is much more likely to affect volant species such as bats. Some bat species are at higher risk to collision impacts, and may or may not have a higher risk to population threats as a result of the mortality rates. The EcIA has assessed what the potential impact is to individual bats and populations of bats, the degree of likelihood of the impact and the confidence in the prediction, in relation to the species of bat, relevant abundance, population dynamics, and behaviour. The Landscape Section is confident that the impact assessment represents a true reflection of the impact of the development on bats. No significant impacts were found to affect any of the species of bat present within the study area, either individually or on populations of species; although some intermediate/minor negative impacts were acknowledged as conceivable. However, the potential for these impacts to occur was considered unlikely or extremely unlikely. The proposed turbines (including blades) are due to be located more than 50m away from linear, water and woodland features in accordance with the guidance contained in the Technical Information Note from Natural England (TIN051). In terms of the displacement effects of operating wind turbines on foraging bats, the potential for negative impacts are predicted to be unlikely and not significant. The development is not therefore considered to have a significant impact on bats in regard to the EIA Regulations. All species of bat are protected under the Habitats Regulations and the Wildlife and Countryside Act 1981 (as amended). Based on the above assessment, it would be highly unlikely that an offence would occur under the Habitats Regulations/ Wildlife and Countryside Act as a result of the proposals therefore the Landscape Section would not raise an objection in this respect and conclude that the application has been assessed in accordance with the Council’s statutory duties. Cumulative/Access Route Impacts The cumulative impacts of the development on non-avian ecological receptors have been assessed and no potential impacts identified. The access route, along Potspoon Hole, will necessitate the loss of some verge habitats (used by foraging badger) and some trimming of trees and hedges. This could have a temporary negative impact on nesting birds and badger, and a minor negative impact on vegetation/habitat. Potential impacts to protected species can be avoided if best practice measures are followed and mitigation is proposed. The Landscape Section conclude that if the mitigation measures are made a condition of planning permission and implemented as approved, then the access route would be acceptable. Mitigation/Conclusions General mitigation proposals based on current best practice have been proposed within the EcIA. These give an indication of the mitigation techniques available or appropriate given the level of impact. Whilst the mitigation measures are accepted in principle, the Landscape Section consider that a detailed Ecological Mitigation and Management plan would be required as a condition of planning to ensure that sufficient information is available at the time of implementation to secure the mitigation measures required, both in respect of the turbine construction (including access route) and operation. Subject to this condition, the Landscape Section conclude that the proposed development is unlikely to have a significant impact on biodiversity and protected species, that the application has been assessed in accordance with the Council’s statutory duties in respect of protected species and habitats (with the exception of birds – see next paragraph), and that the development will not be contrary to Policy EN9 of the Core Strategy, and no objection is raised in this case. Ornithology The ornithological assessment has followed the same guiding principles as the ecological impact assessment, those being the Guidelines for Ecological Impact Assessment (Institute of Ecology and Environmental Management (IEEM) 2006). The assessment has considered the protection and value afforded to different bird species, individuals and sites designated for their ornithological importance both for habitats and species. This includes inter alia Annex 1 (EU Birds Directive) bird species; birds listed in the British Trust for Ornithology’s list of Birds of Conservation Concern (BoCC) and UK Biodiversity Action Plan species. The survey methodologies included Vantage Point bird surveys, Breeding Bird surveys (based around the Common Bird Census technique) and barn owl surveys, which are considered appropriate for collecting the baseline condition data required for the impact assessment. The Vantage Point survey data was used to inform the collision risk modelling (using the Band Collision Risk Model), therefore the surveys concentrated on the use of the site by wintering waders, wildfowl, birds of prey and those species judged as vulnerable to collision such as geese, ducks and gulls. The Landscape Section has noted that the Vantage Point survey location altered following a repositioning of the proposed turbine locations. This has resulted in a shorter time frame of survey data for all land within 500m of the final turbine locations. The initial Vantage Point location was on Potspoon Lane south-east of the woodland that is located to the south of the development site; this may have obscured views of some of the bird species found in the immediate vicinity of the turbine field. However a total of 36 hours, from September 2012 to November 2012, was spent at the 2nd location to validate the data collected from the first survey location. Although the Vantage Point surveys did not cover a full year for the final turbine locations, the Landscape Section consider that the data collected is sufficient to inform the impact assessment and the collision risk modelling, due to the similarity of the habitat surrounding the two vantage point locations and the small distance separating the two surveys. The Landscape Section is satisfied that the methodologies of the ornithological assessment have been carried out appropriately and in accordance with current best practice and have a high degree of confidence in the appraisal results. Once again a significant impact has been defined as one that has a major or intermediate negative impact (i.e. affecting the integrity of a defined site or ecosystem or the conservation status of habitats or species within a defined geographical area) or a positive impact. Receptors classified at the ‘parish’ level or above were considered sufficiently valuable for a significant effect to be material in the decision making process. In addition, within the scope of the EcIA, the likelihood that a change or activity will occur as predicted and the degree of confidence in this prediction is also important and will affect the overall assessment of the impact. The Landscape Section concurs with this approach in the assessment methodology. Survey Results The desktop survey revealed a variety of bird species records within 5km of the development site, and two Special Areas of Conservation (SPA) were located within 20km, with the Broadland SPA located at just 5km south of the proposal. Broadland SPA is noted for Wintering birds such as northern shoveler, widgeon, gadwall, Berwick’s swan, whooper swan, ruff and hen harrier; as well as for breeding bittern and marsh harrier. Also located by the desktop study was Westwick Lakes SSSI, which is within 5km of the site and is listed for its large flocks of wintering wildfowl, including goldeneye and goosander. The field surveys identified that a number of collision-sensitive bird species used or flew over the site together with a number of red-listed and amber-listed (BoCC) bird species considered to be breeding within 500m of the turbine locations. No barn owls were recorded either during the bird surveys or during the bat surveys; therefore barn owls are considered not to be affected by the development. Of the species recorded on the site, the following were assessed to be valuable at the Parish level: buzzard, golden plover, kestrel, lapwing, dunnock, skylark, yellowhammer, yellow wagtail and whitethroat, and only these species were carried through to the full impact assessment. Whilst the Landscape Section are generally satisfied with the results of the surveys and the decision processes on which species to take further to full assessment, there was a small query regarding pink-footed geese. It was noted by the Landscape Section that a small flock (18 individuals) of pink-footed geese were recorded for one event on the initial vantage point survey. The assessment values pink-footed geese as being BoCC Amber-listed for importance of wintering population, but fails to mention their status as being an additional qualifying feature of the Broadland SPA (based on Natural England’s 2001 SPA review) for the numbers of an over-wintering migratory species. The value of pink-footed geese as a qualifying feature of the SPA is unlikely to change the ecological value of the species relative to the site, given that it is the population numbers that are important within the qualifying feature are not found on the site. However it should be recorded that this was noted within the assessment process and is not deemed significant. In addition, marsh harrier too was recorded on a single occasion and this is listed as an Annex 1 species under the Birds Directive, is a qualifying feature of Broadland SPA, and is a species vulnerable to collision; yet this too has not warranted consideration for a full impact assessment. Impact Assessment Designated sites/habitats The ornithological impact assessment did not identify any adverse effects for Broadland SPA or Great Yarmouth and North Denes SPA or Westwick Lakes SSSI, neither any negative effect on the qualifying features of the designated sites. The Landscape Section concurs with this assessment. Birds at risk of collision Of the species of birds found within the site that may be at risk of collision with the turbines, minor negative impacts at the Parish level were found probable for buzzard and kestrel, yet this was not deemed to be significant. A minor negative impact for golden plover and lapwing were assessed as unlikely at the Parish population level, and again is not significant. Breeding birds There is a potential for the construction phase of the development to impact on breeding birds however the study suggests that best practice working methodologies can help mitigate the potential impacts, these should be secured via a condition of planning. Minor negative effects to the Parish populations of select BoCC red and amber-listed breeding birds as a result of disturbance during operation are assessed as unlikely, and not significant. Once again some passerine fatalities as a result collision may occur (skylarks will fly at blade height during song-flight) but the expected numbers will not affect the Parish populations of the species concerned. Cumulative Impacts The cumulative impacts of the development on avian ecological receptors have been assessed and no potential impacts identified. Mitigation/Conclusions Mitigation measures have been proposed for possible effects during the construction and decommissioning periods that may be preventable. These include carrying out earth works and other ground disturbance outside of the main breeding bird season or under direct ecological supervision, and pre-construction survey checks and creation of buffer zones if necessary. In addition, grass margins are to be reduced in rotor blade swept areas to deter foraging by kestrels. Although some collision impacts to individual birds of varying species cannot be ruled out, the impact on the populations of these species is not deemed significant in terms of the EIA regulations. The Landscape Section concurs with the impact assessment and considers that the proposed development is in accordance with Policy EN9 of the Core Strategy and no objection is raised. Similar to the conclusions drawn under the Ecological Impact Assessment, whilst the mitigation measures are accepted in principle, the Landscape Section considers that a detailed Ecological Mitigation and Management plan, to cover all aspects of ecology including birds, would be required as a condition of planning to ensure that sufficient information is available at the time of implementation to secure the mitigation measures required, both in respect of the turbine construction (including access route) and operation. It is worth mentioning that Natural England have been consulted as part of the decision making process and have not raised any objection to the development. This is important in terms of the considered impact of the proposals by England’s statutory nature conservation body and their assessment of any potential impact on designated sites for nature conservation or their specific conservation interests.