Appendix 5 NORTH NORFOLK DISTRICT COUNCIL Environmental Health Memorandum To: Geoff Lyon - Planning From: Sally Nicholson - Environmental Protection Team Extension: 01263 516085 Our Ref: WK/110019795 Date: 23 April 2012 _____________________________________________________________________ Re: PF/11/0983 - Erection of wind-turbine maximum hub height 60m, maximum tip height 86.5m. On the 3rd October 2011 I sent my initial comments to planning regarding this turbine, I had several areas of concern and highlighted them and recommended refusals due to my concerns see the memo attached. In response to this memo I had discussions with the applicant and the noise consultant regarding my concerns. The noise consultant then produced an Addendum to the noise report which reviewed the original assessment; see document “Addendum to noise assessment for a proposed wind turbine at Pond farm, Bodham.” Project number 0910285 produced 21st October 2011. The addendum answered the queries we had in our initial memo: 1. We have serious concerns due to the low background noise in the areas monitored around the turbine; and we are not satisfied that the projected noise levels from the turbine would not give rise to noise complaints at the nearby residential properties. The noise consultant responded that the majority of wind farms and wind turbine installations take place in areas with low background noise. The ETSU guidance recognises this and makes the following comment: “The recommendation of the Noise Working Group is that, generally, the noise limits should be set relative to the existing background noise at nearest noise-sensitive properties and that the limits should reflect the variation in both turbine noise source and background noise with wind speed. We have considered whether the low noise limits which this could imply in particularly quiet areas are appropriate and have concluded that it is not necessary to use a margin above background approach in such 5.1 low-noise environments. This would be unduly restrictive on developments which are recognised as having wider national and global benefits. Such low limits are, in any event, not necessary in order to offer a reasonable degree of protection to the wind farm neighbour.” (Paragraph 11, of the Executive Summary) The consultant went on to say: “In the light of this guidance (and the detailed recommendations within the body of the document), it is clear that Government policy (which specifically recommends the use of this guidance) backs the use of the limits which we have used, and that this includes areas where there are low background levels.” With further consideration to the report in line with the ETSU guidance and the review carried out in the addendum, along with the discussions with the noise consultant we agreed that the noise consultant had followed the correct procedures and that we are now satisfied that although the background noise levels are low this assessment has been carried out with this in mind. During our discussions we decided that a condition should be attached in the event that when the turbine was installed and if noise were to be experienced then this can be implemented: “At the request of the Local Planning Authority (LPA) following a justified noise complaint the wind turbine operator shall, at its expense, employ a suitably qualified noise consultant approved by the LPA, to undertake an appropriate noise assessment of the noise emissions from the wind turbine at the complainant’s property following the procedures agreed by the LPA. A report of the assessment shall be provided in writing to the LPA within X days of the request under this condition unless this period is extended by the LPA in writing. If the findings of this report identify that the wind turbine is causing noise levels considered to be of a detriment to the amenity to the nearby residential properties, a scheme shall be included in the report detailing remedial works, and these works shall be implemented in full.” 2. There is no clear justification to the proposed daytime noise fixed limit proposed by the consultant in table 4.2, and as to why the upper noise limit of the criteria (detailed in 2.5) is acceptable? Through discussions with the noise consultant and the addendum to the report it became clear that environmental protection had misunderstood the limits, and in fact the upper limit was not used. The consultant had produced a variable limit using the methodology laid out in ETSU. This was determined with reference to background levels and subject to a lower limiting value (which is at the lower end of the specified range). We subsequently had a meeting with the acoustic consultant and he talked us through the workings, and how he calculated the target level. This answered our above query. 5.2 3. It has not been confirmed which wind turbine shall be installed, therefore I feel it is not possible to carry out an adequate assessment to the impact on residential properties. The acoustic consultant confirmed that there are two wind turbines being considered (the Enercon E-53 and the Enercon E-48) and the original assessment looked at only one (the E-53). The noise characteristics for each are slightly different. He produced a table that gives the sound power levels for each wind turbine. Manufacturer’s data for wind speed at 10m against sound power levels: Due to our concerns the noise consultant reviewed the original report and re ran it using the E-48. The table above shows that the E-48 noise levels are generally a little higher than for the E-53. The original assessment looked at the E-53, so the addendum includes a re-run the model using the E-48 sound power levels. Table 3.2 in the addendum and table 4.2 of the main report show the noise readings at the varying wind speeds: Table 3.2 Predicted sound pressure levels at the Pylons as a result of operation of the proposed turbine (E-48) Table 4.2 Predicted sound pressure levels at the Pylons as a result of operation of the proposed turbine (E-53) 5.3 This shows that the predicted noise readings at the pylons are similar and actually slightly lower at the lower wind speeds. We discussed that we would condition the planning permission appropriately to reflect this issue. “The Enercon E53/E48 800 kW 60 metre turbine shall be installed and maintained in accordance with the manufacturers specifications; If a different model turbine is to be used the turbine details should be submitted to and approved in writing by the LPA prior to the commencement of the development.” 4. Has the applicant given consideration to the effects of wind shear? The addendum details the procedure in which wind shear is calculated, I myself also read the article in the Acoustics Bulletin published in March 2009. The acoustic consultant then revised the assessment to use the derived values to take account of windshear, which still showed the results as being complaint with ETSU. Conclusion Through discussions and the further information supplied to myself and my colleagues, we were now satisfied that the assessment has been carried out following ETSU-R-97, on assessing noise from wind turbines, which is the recognised current guidance and that sufficient noise monitoring had been undertaken and that we now had enough information to make an informed decision. In conjunction with this addendum myself, my colleagues Paul Clarke and Mark Whitmore met with the noise consultant and the applicants to go through the noise report and addendum to discuss it further and so any queries could be discussed. We decided that as ETSU is the recognised guidance and that this has been followed and that the proposed wind turbine has met these criteria. Therefore, we had no further objection to the installation of this turbine. We are now satisfied that we have sufficient information to make a decision on this proposed turbine and we have no further objection, provided that the following conditions are applied: 5.4 The conditions we decided upon are as follows (see memo 2): 1. Type of Turbine “The Enercon E53/E48 800 kW 60 metre turbine shall be installed and maintained in accordance with the manufacturers specifications; If a different model turbine is to be used the turbine details should be submitted to and approved in writing by the LPA prior to the commencement of the development.” 2. Condition “At the request of the Local Planning Authority (LPA) following a justified noise complaint the wind turbine operator shall, at its expense, employ a suitably qualified noise consultant approved by the LPA, to undertake an appropriate noise assessment of the noise emissions from the wind turbine at the complainant’s property following the procedures agreed by the LPA. A report of the assessment shall be provided in writing to the LPA within X days of the request under this condition unless this period is extended by the LPA in writing. If the findings of this report identify that the wind turbine is causing noise levels considered to be of a detriment to the amenity to the nearby residential properties, a scheme shall be included in the report detailing remedial works, and these works shall be implemented in full.” We feel these conditions are workable and measurable to address the concerns of the residents and ensure that if as ETSU indicates the turbine shall not be detrimental to the amenity in relation to noise, if there is a subsequent problem when the turbine is installed this matter can be addressed by enforcing these conditions. If you have any further queries please contact me. Regards Sally Nicholson Environmental Protection Team 5.5 NORTH NORFOLK DISTRICT COUNCIL Environmental Health Memorandum To: Geoff Lyon - Planning From: Sally Nicholson - Environmental Protection Team Extension: 01263 516181 Our Ref: WK/110019795 Date: 3rd October 2011 _____________________________________________________________________ Re: PF/11/0983 - Erection of wind-turbine maximum hub height 60m, maximum tip height 86.5m, associated infrastructure, single-storey substation building, access tracks and crane hard standing Further to the receipt of the noise report produced by Sharps Redmore Partnership “Noise Assessment for a proposed wind turbine at Pond Farm, West Beckham, North Norfolk” dated 7 January 2011 and the additional information submitted on 20 September 2011. The Environmental Protection Team has considered this report against the ETSU-97 guidance and the World Health Organisation guidance along with consideration of the residential amenity of the nearest properties. On assessing the above noise report the following issues have been identified: • We have serious concerns due to the low background noise in the areas monitored around the turbine; and we are not satisfied that the projected noise levels from the turbine would not give rise to noise complaints at the nearby residential properties. • There is no clear justification to the proposed daytime noise fixed limit proposed by the consultant in table 4.2, and as to why the upper noise limit of the criteria (detailed in 2.5) is acceptable? • It has not been confirmed which wind turbine shall be installed, therefore I feel it is not possible to carry out an adequate assessment to the impact on residential properties. • The applicant appears not to have given consideration to the affects of wind shear. 5.6 Therefore, on the current information we have we recommend refusal. If you have any queries please contact me. Regards Sally Nicholson Environmental Protection Officer 5.7