Page 1 of 1
Appendix 4
Geoff Lyon
From:
Cathy Batchelar
Sent:
14 August 2012 11:02
To:
Geoff Lyon
Cc:
Phil Godwin; Steve Oxenham
Subject: Bodham Wind Turbine and Barningham Hall
Geoff, The report received from John Phibbs on the historic parkland at Barningham Hall gives insight into the design aspects of the Repton landscape. Although 2.4km north of Barningham Hall, the turbine will impact on the Grade II registered historic designed landscape, less so on the Hall itself. The visual impact will be greatest on the main southern approach to the Hall from Matlaske village as the drive sweeps round to the Hall. Entering the parkland on this approach, the Hall is screened by a clump of trees, typical of Repton’s design style. The turbine will come into view on the wooded horizon to the north just as the first views of the Hall are revealed to the east. It should be noted that there would be little incidence of collective views of the turbine, the Hall and the parkland together. The east‐west avenue is another key feature of the designed landscape. Occasional glimpses of the turbine would be available looking north between the vegetation along this avenue, but the main intended vista of the Hall to the east along this avenue would not be affected. The turbine will also be visible on the horizon from church of St Mary, Barningham Winter located within the parkland. However these views are partial and distant and would not be significant. The historic parkland of Barningham Hall remains very much intact and merges seamlessly with the pastoral landscape beyond. Apart from the existing mast, there are no other recent features such as modern agricultural buildings or structures which interrupt the quiet rural setting of this historic designed landscape. The proposed turbine would undoubtedly impact on this scene, its prominence increased by the moving element and this should be taken into consideration. However, given its distance from the historic asset and the wooded nature of the landscape causing glimpsed views, refusal of the application solely on the grounds of substantial harm to the Grade II registered parkland of Barningham Hall could not be justified. Regards Cathy Batchelar LANDSCAPE OFFICER Conservation Design & Landscape North Norfolk District Council Tel: 01263 516155 cathy.batchelar@north‐norfolk.gov.uk 4.1
14/08/2012
Page 1 of 1
Geoff Lyon
From:
Cathy Batchelar
Sent:
12 July 2012 11:34
To:
Geoff Lyon
Cc:
Andy Mitchell; Steve Oxenham; Phil Godwin; Steve Blatch
Subject: PF/11/0983 Wind Turbine Bodham
Geoff, Thank you for your email dated 25th June attaching the Landscape Partnership response to my comments on their Landscape & Visual Impact Assessment. The difference of opinion over which factors are applicable when assessing the Sensitivity and Magnitude of Impact criteria demonstrates the subjective nature of LVIA, even when the methodology is clearly laid out. I note their comments, and can confirm that I remain of the opinion that the visual impact of this large scale single turbine would be sufficiently adverse on the surrounding landscape, in particular TF3 Tributary Farmland as defined in the NNLCA, and affected designated heritage assets (historic landscapes, listed buildings and Scheduled Ancient Monuments) to warrant refusal of the application in accordance with Policy EN2: Protection & Enhancement of Landscape and Settlement Character of the North Norfolk Local Development Framework. My conclusion is that the degree of visual impact of a single turbine of this scale in the open landscape in one of the highest points in North Norfolk is not outweighed by the public benefit to be gained in terms of renewable energy. I trust this is of assistance. Regards Cathy Batchelar LANDSCAPE OFFICER Conservation Design & Landscape North Norfolk District Council Tel: 01263 516155 cathy.batchelar@north‐norfolk.gov.uk 4.2
10/08/2012
North Norfolk District Council
Conservation, Design and Landscape
MEMORANDUM
To: Geoff Lyon, Team Leader, (Enforcement & Special Cases) Ref: PF/11/0983 From: Cathy Batchelar, Landscape Officer Date: June 6th 2012 Re: Erection of single wind turbine max hub height 60m, max tip height 86.5m, associated infrastructure, single storey sub‐station, access tracks, & crane hard‐
standing, land at Pond Farm Bodham. ADDITIONAL INFORMATION This response should be read in conjunction with previous comments, dated 17th Oct 2011 submitted in relation to this proposal. These comments incorporate the following submitted additional information: 1. Landscape & Visual Impact Assessment, The Landscape Partnership, May 2012 Part 1: Supporting Text Part 2: Figures Part 3: Appendices 2. Booklet 2: Additional Photomontages & Wireframes, Genatec , 20/03/2012 3. Booklet 3: Winter Views, Genatec, 20/03/2012 4. Historic Environment Report, Grover Lewis, April 2012 5. Arboricultural Implications Assessment, A T Coombes Associates, 10th April 2012 The Landscape & Visual Impact Assessment (LVIA) undertaken by the Landscape Partnership in May 2012 supercedes the LVIA carried out by Genatec, July 2011 and seeks to address concerns raised in relation to the earlier submission. These concerns are summarised below: • Lack of consistency in assessment methodology • Lack of objective assessment • Lack of consistent reference to the North Norfolk Landscape Character Assessment (June 2009) SPD • Need for additional viewpoint modelling to demonstrate winter views • Additional viewpoints to demonstrate impact on the A148 and the AONB boundary and existing landmark features. The Landscape Partnership submission largely addresses these issues and is based on a structured and reasoned methodology that is used consistently across the assessment. However, LVIA, by its very nature inevitably has a degree of subjectivity in making the value judgements against the criteria that are set. 1 4.3
Landscape Assessment This involved an assessment of each affected Landscape Character Area (LCA), as defined in the North Norfolk Landscape Character Assessment, June 2009 SPD. The condition of each LCA was assessed and judgement made on the sensitivity of the landscape (Sensitivity), together with a measure of the capacity of the landscape to accommodate a development such as this (Magnitude). These two factors combined to give a rated Impact Significance on the LCA (page 8 of Part 1 of the Landscape Partnership LVIA). The greatest Impact Significance features in three LCA’s: Tributary Farmland (TF3), Wooded with Parkland, Holt to Cromer (WP2), Wooded with Parkland (WP5) Plumstead & Barningham. The rating here was Medium‐Low Adverse. The same conclusion is drawn for a sub‐area of TF3, Valley Headlands, defined as part of this report. The development site lies within TF3 and the assessment acknowledges that the appearance of the turbine would be a ‘significant localised change ‘ to the appearance of this LCA and that views would be affected for a ‘large proportion of this LCA’ (Appendix 1, page 1). This LCA was given a Medium Sensitivity rating and Moderate Magnitude. Considering the Sensitivity values in Table 2.1 (page 4 of the LVIA), it could be argued that several of the factors in the High category could apply to TF3. The same could be applied to the Magnitude factors where many of the factors within the Substantial category could be justified. This could therefore have resulted in a higher Impact Significance rating of Medium‐High and demonstrates that however robust a methodology is employed, a degree of subjectivity becomes part of the assessment. The transmitter masts in the vicinity of the site are cited as existing vertical elements in the landscape which would reduce the degree of change in the landscape. In my opinion these features are only slightly comparable to the proposed wind turbine. They are static, lighter grid structures which are smaller in scale and have no moving parts to attract the eye. In my opinion, their presence is over exaggerated within this LVIA in diminishing the effects of a solid large scale moving turbine. The area around Bodham within Landscape Type TF3 is a tranquil arable area where the outlying hamlets and farmsteads give the impression of an older landscape. The effects of the proposal, by virtue of its scale and nature, on this quiet character and the resultant altered perception of the landscape have not been fully considered within the assessment. For the reasons stated above I am of the opinion that the Impact Significance on TF3 (Tributary Farmland) has been under‐rated and a rating of Medium‐High Adverse would be a more accurate conclusion. Wooded with Parkland areas, WP2 & WP5 are assessed as Medium – High Sensitivity landscapes, given the designated historic parkland and proximity to the AONB and this is a fair assessment. The Magnitude of impact is concluded to be Slight with undulating landform and existing vegetation cited as factors which providing partial screening and diminish the impact of the proposal on these landscape character areas. WP2 (Holt ‐ Cromer area) comprises some of the highest level topography within the District and contains one of the busiest tourist routes, the A148. While blocks of woodland would provide some screening, views of the turbine would be intermittent yet frequent from 2 4.4
the busy A148 and given the high number of road users affected, the description applied to the Moderate Magnitude rating would be more appropriate, resulting in a Medium‐
High Impact rating. The degree of containment afforded by the vegetation and landform within each of the Wooded with Parkland landscape types appears to have been used excessively to diminish the effect of the development. Visual Impact Assessment This involved analysis of the visual change that would result from the development from a range of typical public and residential viewpoints. Impacts were assessed at three points in the life cycle of the development: winter of Year 1, summer Year 15 and at decommissioning. A range of additional viewpoints, as well as those previously submitted, were also considered to represent a further range of receptors: those in close proximity, within designated landscapes, at designated features, at high points within the surrounding landscape and to represent winter views without leaf cover. The sensitivity of the receptor was combined with the magnitude of change incurred by the development to give an Impact Significance rating. Significant impacts were defined as those with a High, Medium‐High or Medium Adverse rating and these occurred at the following locations in both Year 1 & Year 15: Viewpoint 7, Osier Lane West Beckham Viewpoint 9, Plum Lane West Beckham Viewpoint 31, Hill Farm Bodham Viewpoint 48, Bodham Church from Manor House The angle of the turbine within the view of the receptor is one of the factors used to determine the magnitude of change. Where it is oblique, (i.e. not within the centre of a view) the degree of change is reduced (e.g. Plum Lane, West Beckham). In my opinion this is arguable as the moving element of the turbine would draw the attention and dominate the view, regardless of whether it is central or not. Mitigation in the form of proposed hedgerow planting in the vicinity of the site will have a negligible impact in diminishing the visual effects of the development for local residents, given the large scale of the turbine within the landscape and the length of time it would take for a newly planted hedge to form an effective screen. For local residents within 1km of the turbine, the impact of this development will therefore be significantly adverse. The designated National Cycle Route no 30: Norfolk Coast Cycleway passes 600m north of the site along Osier Lane, West Beckham. The effect on this receptor group would be substantial, given the proximity of the route to the site. 3 4.5
Arboricultural Report The submitted report entitled ‘Arboricultural Implications Assessment’, carried out by A.T Coombes Associates, 10th April 2012 is actually a Programme for Tree Works and does not contain the tree categorisation element of a full AIA which would have been useful. However, the information provided is sufficient enough to make an assessment of the amount and extent of tree and hedge clearance that would be required to facilitate the specific vehicular access to the site that would be required. 40 trees and tree groups require some crown pruning work. One oak (no. 33) is to be felled and approximately 45m of mature hedgerow will have to be removed. None of the trees have protected status. The main detrimental impact will be the hedge removal which is in close proximity to the site and provides mature screening for local residents. Apart from this aspect, I believe the pruned vegetation will recover quickly and therefore conclude that the amount of required clearance would not have a permanent detrimental visual impact on the rural lanes and wider landscape along the specified route. However, the cutting back of the road verges, as laid out in Appendix 10, Transport & Access of the main Genatec submission document, does give rise to concern, both from an ecological aspect and in terms of visual impact. The required clearance for vehicles delivering components and for the crane is 5.5m horizontal clearance and 5m vertical clearance. Within Chapter 11 of the Environmental Report by Genatec 21/7/11, it states that the agreed route would have to be 3.5m wide which contradicts that stated in Appendix 10.. This will involve lifting of the grass verge and road widening along Rectory Road and Church Road. This will alter the character of these quiet rural lanes and contribute to erosion of features typical of the prevailing landscape character. Landscape mitigation proposals include a substantial amount of hedge planting, and hedgerow tree planting which is appropriate, but it should be noted that any effectual screening afforded by this planting will not be realised for many years. In this regard the detrimental aspects of this development in terms of visual impact cannot be made acceptable and it is contrary to Clause 97 in the NPPF which states that ‘LPA’s should ensure that adverse impacts of renewable and low carbon energy development are addressed satisfactorily….’ Conclusion The submitted Landscape & Visual Impact Assessment prepared by The Landscape Partnership concludes that the landscape has the capacity to accommodate this development without significant detriment to its character, to designated features within the landscape and without significant detrimental change to visual receptors in the vicinity. 4 4.6
Having considered this I am of the view that the existing vertical masts, together with the undulating landform and vegetation, have been used in excess to diminish the effect of this proposal. The frequency of views of the turbine that would occur in both the local and wider landscape would have a lasting impact on the receptor, be they walkers, car users, residents, tourists, cyclists etc and would significantly alter their perception of the landscape. In addition the large scale of the single turbine would dilute the impact of the churches in the landscape. As is typical of Norfolk, the church towers act as focal points and their inter‐visibility is an important feature of the landscape providing strong visual links between settlements throughout the countryside. They are historic landmark features which punctuate the skyline and are in keeping with the scale of other elements making up the built form in this intimate pastoral landscape. The North Norfolk Core Strategy document, Policy EN7 Renewable Energy states at 3.3.35 that ‘All proposals for renewable energy should complement the particular characteristics of the surrounding landscape and the Landscape Character Assessment will assist in assessing the impact of individual proposals.’ Weighing up these factors and having due regard to the North Norfolk Landscape Character Assessment (Supplementary Planning Document), June 2009, I am of the opinion that the proposal, by virtue of its scale and nature and subsequent visual impact. would have a detrimental effect on the surrounding landscape type, Tributary Farmland (TF3). The proposal is contrary to the assessment of TF3 within this document which concludes that ‘some parts of TF3 may be appropriate for small‐scale wind turbines, taking care not to place them so prominently that they can be seen for miles (i.e. near the Cromer ridge)’. A key characteristic of the Tributary Farmland landscape type is an ‘Open character with uninterrupted views’. The condition of this character element is concluded to be Good and the Sensitivity to change assessed as Moderate to High. The siting of wind turbines within the more rural locations as being inappropriate is specifically stated (p.42). The prominent skyline is highlighted as another key characteristic of this landscape type due to the domed plateau and expanses of open landscape. Sensitivity to change within this characteristic is considered to be High and developments which affect or impinge on the open skyline should be avoided (p.43). The North Norfolk Landscape Character Assessment (Supplementary Planning Document, June 2009) is a material consideration within the planning process. NPPF Clause 98, states that LPA’s should ‘approve applications for renewable energy if its impacts are (or can be made) acceptable…unless material considerations indicate otherwise’. For the reasons stated above, this proposal cannot be considered to protect or enhance the defined landscape character and it would therefore be contrary to Core Strategy Policy EN2: Protection & Enhancement of Landscape and Settlement Character which states that proposals should be informed by, and sympathetic to, the distinctive character areas identified in the North Norfolk Landscape Character Assessment and I therefore recommend refusal. 5 4.7
Cathy Batchelar Landscape Officer 6th June 2012 6 4.8
North Norfolk District Council
Conservation, Design and Landscape
MEMORANDUM
To:
Geoff Lyon, Senior Planning Officer
Ref:
PF/11/0983
From:
Cathy Batchelar, Landscape Officer
Date:
Oct 19th 2011
Re: Erection of wind turbine max hub height 60m, max tip height
86.5m, associated infrastructure, single storey sub-station, access
tracks & crane hard standing, Pond Farm, Bodham
ADDITIONAL COMMENTS RELATING TO THE ACCESS ROUTE
Further to receipt of the response from Highways dated 23 Sep 2011 regarding this application,
the comments relating to the free passage along the public highway overruling any TPO’s do
give rise to concern.
More clarity is required at this stage as to the extent of vegetation removal that would be
required to facilitate the 5.5m wide by 5m high clearance route to the site from High Kelling.
Further information is required by way of an Arboricultural Implications Assessment to BS
5837:2005. This will identify the extent and nature of potential impact on vegetation along the
route and include a Method Statement which will propose measures to minimise any impact and
compensate for any loss.
Cathy Batchelar
Landscape Officer
4.9
North Norfolk District Council
Conservation, Design and Landscape
MEMORANDUM
To:
Geoff Lyon, Team Leader, (Enforcement & Special Cases)
Ref:
PF/11/0983
From:
Cathy Batchelar, Landscape Officer
Date:
Oct 17th 2011
Re: Erection of single wind turbine max hub height 60m, max tip
height 86.5m, associated infrastructure, single storey sub-station,
access tracks & crane hard standing, Pond Farm, Bodham
This response assesses the Landscape & Visual Impact Assessment (Appendix 3) and the
Ecology Report (Appendix 9) submitted in conjunction with this application. A further response
will be provided from the Conservation Design & Landscape Manager in respect of the effect of
the proposed development upon the historic environment.
The site
The site is located on a 24ha arable field at Pond Farm, Bodham which is bounded by hedging
to the west and east and a wooded area to the south. The site lies at an elevation of 90m which
is one of the highest points in the district.
Landscape & Visual Impact Assessment
The Landscape & Visual Impact Assessment (Environmental Report, Appendix 3) submitted
with this application has followed accepted methodology laid out in The Landscape Institute
publication, “Guidelines for Landscape & Visual Impact Assessment” (2nd edition 2002) (GLVIA).
It has been prepared by ‘Genatec’. There is no summary of the relevant professional expertise
and competence within this company to demonstrate the eligibility of the company to carry out
the assessment and this should be provided.
The assessment has been carried out using a number of accepted methods. These include a
desktop study, ZVI (Zone of Visual Influence), photomontage from representative viewpoints, a
baseline study of the existing landscape, assessment of the significance, scale & extent of the
development on the landscape, mitigation.
Criteria for Assessment
Prediction and the evaluation of significance lies at the heart of Visual Impact Assessment.
There is no statutory guidance on the definition of significance, which, by its nature is value
laden. It is therefore relative and specific to the context. There are however two key facets in
determining significance.
1. The scale and magnitude of the impact
2. The sensitivity of the location or receptor.
Within this submission, the criteria for assessing the significance of the impact appears to be
clearly laid out (Tables 1,2,3 on p7-8) and to some degree incorporates these two important
elements. However, there are some anomalies which are described below:
1. The methodology for the assessment of the sensitivity of the landscape in Table 1 has
not taken account of the North Norfolk Landscape Character Assessment, June 2009
(Supplementary Planning Document) (NNLCA) which assesses the condition and character
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of landscape Types within the District. When each Viewpoint is assessed later in the
report, the landscape Types, as defined in the NNLCA, are used in some but not all cases.
This is inconsistent.
Terms such as ‘unimportant and ‘unspoilt’ are used as criteria for landscape sensitivity
within Table 1. These statements are too subjective and need to be quantified. Historical,
social, cultural or contextual elements are not considered. More evaluation of the condition
of the landscape is required, including current land use & evidence of historical
landownership in order to determine the sensitivity of a given landscape.
2. The assessment of the sensitivity of the receptor in Table 1 does not take account of the
expectations of the receptor and uses the value of the landscape as a factor in the
sensitivity of the receptor e.g. using terms such as ordinary, degraded and scenic
landscapes. All users of public rights of way, regardless of their location such as walkers,
bridleway users may be more sensitive receptors, as their attention or interest may be more
directly focused on the landscape and they are moving more slowly through it than, say,
vehicle users.
Clarification is also required as to whether this set of criteria is based on a system devised
by others, or whether it has been formulated by the report’s author. If the latter, some
background explanation would be useful
The assessment distinguishes between landscape effects and visual effects (p1) which is
accepted practice. The Landscape Institute GLVIA publication (Section 2.14) states that
‘landscape effects derive from changes in the physical landscape which may give rise to
changes in its character and how it is experienced. ……. Visual effects relate to the changes
that arise in the composition of available views as a result of changes to the landscape, to
people’s responses to the changes and overall effects with respect to visual amenity’.
This LVIA is divided into 3 sections; a visual analysis, landscape impact assessment & visual
impact assessment and these are evaluated below;
1. Visual Analysis
a) Viewpoints
The viewpoint analysis was undertaken in order to predict the magnitude of change that would
occur from a sample of locations around the site from where the turbine would be visible. The
locations were selected in consultation with NNDC and the Norfolk Coast Partnership as
representative of various receptor groups, designated landscapes and landscape character
areas. The turbine will also be visible from many other surrounding viewpoints within the 10km
study radius, as indicated on the submitted ZVI (Zone of Visual Influence).
The assessment of the viewpoints has not been uniformly carried out. Some viewpoint
assessments have incorporated the impact on the defined landscape type and others have not
e.g. VP 7,8,9. These are the viewpoints in close proximity to the turbine and the magnitude of
change on the landscape is a vital aspect to consider at these locations. This should be
addressed.
It is logical to conclude that the magnitude of change diminishes with the distance from the
development as stated in the Summary of effects of the viewpoint assessment (p 44).
The assessment relies heavily on the presence of the existing vertical structures to diminish the
impact of the turbine and has not sufficiently taken into account the moving element of the
proposed turbine. At Viewpoint 8, Osier Lane the magnitude of change is assessed as High.
One of reasons given is that it is ‘only a medium sized turbine’. At this location the turbine
would be very close and prominent and because of the scale and moving element would ‘totally
dominate the view’. The magnitude of change would therefore qualify as being Very High.
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2
Sandy Lane VP4 (Photomontage 3). This is a busy tourist area, given the proximity of Kelling
Heath Holiday Park and the surrounding footpaths on the southern edge of Weybourne Heath
are heavily used during the tourist season. The magnitude of change for footpath users has
been assessed as Low but this may well qualify as Medium as the turbine would be a
‘conspicuous element within the overall view’.
VP 10 (Plum Lane) The landscape character Type defined in the NNCLA has not been used
here. It is classified as ‘local site landscape’. The sensitivity of the landscape at this viewpoint
is assessed as Low. Reasons cited are the presence of man-made structures, intensive
farming resulting in a ‘degraded landscape’. This does not concur with the assessment made
within the NNLCA which assesses this part of the Tributary Farmland character type as in Good
condition with a Moderate strength of character.(NNLCA p 52). Defined Landscape character
types as defined in the NNLCA should be used throughout the viewpoint assessment for
consistency. Reasons such as the ’elegance of turning blades’ p42 are used to conclude that
the impact on the landscape at this point is Moderate and this is too subjective a judgement.
Due to the high number of receptors and the fact that this road marks the southern boundary of
the AONB, the impact of the development from the A148 should be more thoroughly assessed
than the single location at Roman Camp (VP 6). Additional viewpoints are required. The open
stretch of road after High Kelling travelling East is one and the A1082 junction (Holway Road)
with the A148 is another busy section that merits analysis.
b) ZVI
The extent of the study area has been justified according to the extent to which the
development can viewed from the surrounding landscape (Zone of Visual Influence, ZVI).
Based on a ZVI computer modelling package, this has been set at a10km radius from the site
for viewpoint appraisal and a 5km radius for more detailed landscape and visual assessment.
The justification for this range of study is, for the most part, appropriate and does allow for a
representative assessment of the visual impact of the development. However there are
exceptions to this, namely high points in the open landscape beyond the 10km radius from
where the development will still be visible, albeit in the distance. In particular, the higher
topography to the west, for example the B1354 at Swanton Novers, the open stretch of the
A148 from Thursford to Sharrington and the landscape to the north of this road around
Saxlingham and Field Dalling.
The LVIA concludes that the ZVI shows that the development would be visible from 60% of a
10km radius, but states that in reality there are few places where it would be visible due to the
large amount of woodland (p70). This is perhaps misleading, as there are numerous points,
other than the selected Viewpoints, within the 10km radius and locations beyond, from where
the development would be visible.
It is not stated whether the ZVI is based on the height of the turbine to the blade tip, or to the
nacelle and this should be clarified.
The limitations to the ZVI mapping are acknowledged within the document, namely that
landscape features such as woodland, hedges and buildings are not taken into account in
obscuring views, neither are atmospheric conditions.
c) Photomontages
Wireframes and photomontages are used to illustrate the predicted views. These have been
constructed using a computer modelling package and are a useful aid in explaining the visual
effect of the development. However, it must be remembered that these are not actual images.
Having visited the photo locations, I am of the opinion that from some of the viewpoints the
turbine will, in reality, be far more visible than the photomontage implies e.g. Photomontage 6:
Roman Camp-A148, no.7, Osier Lane West Beckham, no.8 The Street between West Beckham
& Bodham, no. 17, All Saints Church Bodham.
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Seasonal Change
Only a limited proportion of the photos images have been taken in winter to demonstrate when
visual impact will be greatest. Of the 27 images submitted, only 6 demonstrate the view when
there is no leaf cover. This should be revised to show these situations with no leaf cover.
As mentioned above, a further response will be provided in respect of the impact upon the
historic environment and landscape. In this regard the setting and context of Baconsthorpe
Castle, a Grade I listed building and Scheduled Ancient Monument is of particular significance.
Also the impact, if any, upon the setting of Sheringham Park and Barningham Hall, both
registered historic landscapes should be further assessed during the winter months. Further
viewpoints within these landscapes may be required to undertake a comprehensive
assessment. NB: Woodland cover is specifically cited within the LVIA as a reason for the
turbine not being visible from within Sheringham Park.
2. Landscape Impact Assessment
The study area for this aspect of the LVIA was restricted to a 5km radius from the site. This
was justified by the conclusions from the ZVI, the viewpoint analysis and the scale of the
development and this is appropriate.
The two aspects of this part of the assessment were:
a) The effect on the landscape fabric of the site.
b) The predicted impact on affected Landscape Types as defined in the NNLCA.
The report states that the sensitivity to change of the proposed turbine site is Low as it is
currently under arable cultivation and this is somewhat illogical. It is the capacity of the site to
accommodate change that should be considered along with the nature of the development.
Given that this is a high point in a relatively open landscape coupled with the height of the
development, the sensitivity to change should be much higher.
The site lies within the Tributary Farmland character type as defined in NNLCA. This landscape
Type extends across the middle section of the District and is characterised by an open
landscape with long uninterrupted views comprised of predominantly arable landuse. Prominent
features of this mainly pastoral landscape are cited as telecom towers, larger isolated
farmsteads and houses and churches. The overall condition of this Type is assessed as Fair to
Good with a Moderate strength of character. Bodham lies within the sub-area defined as TF3
incorporating Hempstead, Aylmerton & Wickmere. The landscape character of this area is
evaluated as being in a Fair to Moderate condition with a Moderate strength of character, given
that the majority of the landscape has been affected by commercial agricultural activity over the
past 50 years, resulting in the removal field boundaries which defined the underlying structure
of a relatively old landscape, pre-dating the Enclosure movement of the C18th & C19th. Where
this has not occurred, the impression of an older landscape is prevalent and the character is
therefore much stronger. Outlying hamlets and farmsteads around Bodham are defined as
such an area.
According to the LCA , landscape area TF3 is moderately sensitive, depending on the location
within the area and the type of development proposed. Small scale wind turbines are assessed
as possibly being suitable, so long as care is taken with the siting so that they are not ‘apparent
for miles’, meaning not near the Cromer ridge.
In Table 5.2 of the LCA Tributary Farmland: Analysis of Key Characteristics, wind turbines sited
within the more rural locations of this character Type are mentioned as features which would be
inappropriate and would adversely affect the open character with uninterrupted views and the
open skyline, two key characteristics of this landscape Type.
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The assessment in relation to this application claims that ‘the proposed turbine would not be a
visible element from a significant amount of the surrounding landscape’, due to the amount of
enclosure afforded by hedging and woodland. This has been underestimated, as has the
impact of the height of the development and the moving nature of the blades.
The assessment argues that this landscape type is disturbed and degraded because of the
presence of the two masts. This is contrary to the assessment of the landscape condition within
the NNCLA which claims the landscape is well preserved.
The magnitude of change is assessed as Medium, using the existing vertical structures to
diminish the impact. The impact of the height of the turbine (20m taller at blade tip than the
adjacent mast) has not been adequately addressed, neither has the moving element.
The report concludes on p 53 that there are ‘no significant effects on landscape character within
5km study area.’ The presence of the existing vertical structures and existing topography and
woodland cover appear to have been used excessively to diminish the visual impact and
insufficient objective assessment is made of the height of the feature and the effect of
movement of the turbine blades.
3. Visual Impact Assessment
This element of the assessment looked at the potential effects upon the visual amenity of
a) fixed viewpoint receptors, namely residents, visitors to the area
b) linear route receptors, such as walkers, cyclists, horse riders, road users.
Significant effects were found to be confined within a 1.6km radius of the site and included local
residents, cyclists, footpath users, minor road users and the village of Barningham/North
Barningham.
One aspect affecting receptors which has not been assessed is the effect of the scale of this
development. Because the feature would be considerably taller than any other solid structure in
the area, it will alter the way a receptor interprets the surrounding landscape. Where previously
landmark features such as historic churches (North Barningham and All Saints, Bodham) were
in relative harmony in terms of scale with natural features such as woodland, this development
introduces another scale that alters the perception of the existing features.
The two telecom masts (35m & 65m in height) do provide some ‘verticality’ within the landscape
and may play some part in diminishing the impact or magnitude of change within the existing
landscape. However their presence has probably been used excessively to argue this case.
The masts are of a lattice structure and are static objects, making them relatively transparent
and unassuming. The solid mast and moving blades of a turbine, 21m taller in height is a
different type of feature that bears only limited comparison with a visually more prominent
feature like the turbine. This aspect has not been sufficiently or objectively considered.
The undulating topography and degree of woodland cover surrounding this site do go some way
to mitigating the visual impact of the development, but again, this has been overestimated.
Further analysis is required of the visual impact during winter months when there is no leaf
cover.
Sub-station
The siting, design, scale and appearance of the proposed sub-station are appropriate for the
setting and there are no issues of concern relating to this element of the application.
Access
The proposed access route to the site from High Kelling is acceptable, given that it is stated that
only selective trimming of hedges and trees will be required to facilitate this and no wholesale
removal of vegetation. Adequate mitigation is proposed in the form of hedge planting.
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Landscape & Visual Mitigation
It is acknowledged that this is limited due to the nature of the development. The proposed
annual sum towards landscape enhancement in line with the recommendations of the NNLCA is
a relevant proposal, as is the proposed hedge planting.
ECOLOGY
Phase One Habitat Survey
Three pieces of further information are required:
1) The study area has not been defined or justified for this survey and this should be submitted.
2) The survey does not include the access route and the potential impacts on protected species
and habitats along this route.
3) The survey refers to NBIS records and a check has clearly been undertaken as part of the
desktop research but the results have not been included in the document.
Ornithology Report
The submitted report by ECUS, 1st August 2011 is robust and has been carried out according to
recommended methodologies.
61 species were recorded over the study period between Nov 2009 and Dec 2010. Of these 30
were considered of conservation concern in relation to the EC Birds Directive, the Habitats
Regulations 2010 and the Wildlife & Countryside Act 1981 (as amended). Of particular note is
the seasonal presence of Pink-footed Geese and Golden Plover of which Norfolk holds
internationally important numbers. These species were therefore subject to further Collision
Risk Analysis which considered the two height options for the turbine.
The Pink-footed Geese are likely to be part of the population using the North Norfolk Coast and
Wash SPA. (Special Protection Area). 450 birds were recorded within the survey area at a
given time. Given the increasing numbers of Pink-footed Geese recorded within the SPA
(339,732 recorded in 2010), the predicted mortality rate of 2.2 - 2.3 is deemed to be insignificant
in nature conservation terms.
Golden Plover is an Annex 1 species under the EU birds Directive. A predicted increase in
mortality of 1.7% amongst the local flock population of c. 500 is not considered to be significant
other than at a local level.
Bat Survey
The survey carried out by Eco-Native, dated 10/10/10 uses accepted methodology. Field
survey work is minimal but adequate. The proposed post installation monitoring is relevant.
Great Crested Newt Survey
The survey dated 10/10/10 carried out by Eco-Native acknowledges its limitations due to the
time of year and the fact that the pond had dried out. However adequate mitigation is proposed
in the event of these species becoming apparent.
In conclusion, the submitted Ecology report has followed accepted methodologies and
adequately considered all potential impacts on local ecology that may be incurred as a result of
this development. In this regard the LPA has paid due regard to its duties under the Natural
Environment & Rural Communities Act 2006 and this element of the submitted application is
therefore deemed to be compliant with Core Strategy Policy EN9: Biodiversity & Geology.
CONCLUSION
The LVIA has been set out according to accepted methodologies, but in its current form the
judgements made within the document have not been sufficiently objective or consistent.
Further specific information is also required as laid out in the response above.
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A more rigorous and objective assessment is also required of the effects of the development on
the landscape within the 5km study area, in particular on the TF3 Tributary Farmland
Landscape Type.
To conclude, it is not possible to fully assess the true landscape and visual impact implications
of the proposed development with the information so far provided in support of this planning
application.
Cathy Batchelar
Landscape Officer
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