APPENDIX 1
HERITAGE COMMENTS
LAND AT POND FARM, NEW ROAD, BODHAM
Application Ref: PF/14/0925
1.0
INTRODUCTION
1.01 This application proposes the erection of a single wind turbine at Pond Farm, Bodham
together with associated substation, tracks and hardstanding. The height to hub of the turbine will
be 40m and 66m to the tip of the blades. The application follows the refusal of a similar proposal for
a taller structure (60m to hub and 86.5m to the end of the blades) which was refused in 2012 and
has ultimately been remitted to the Secretary of State for redetermination (by public inquiry).
1.02 In the Inquiry into the previous larger turbine, the Planning Inspector identified that the
settings of All Saints Church, Bodham, St Peter’s Church North Barningham, Barningham Hall
(including the park and garden and the Winter Church) and Baconsthorpe Castle would all be
adversely affected by the proposed development. Despite this, he considered that the harm was
outweighed by the public benefit which would ensue. On appeal to the High Court however, the
Judge held that the Inspector did not ‘have special regard to the desirability of preserving the
building or its setting or any features of special architectural or historic interest which it possesses’ as
required by Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990.
1.03 Beacon Planning has been asked to assist North Norfolk District Council by providing
heritage advice on the revised proposal. We visited the site and heritage ‘receptors’ on 14
November and 5 December 2014. We have seen the documentation relating to this application, and
the comments and objections received and have also seen the wealth of documentation relating to
the previous application. We have however formed our own, independent view of the proposals.
1.04 For completeness, we have looked at all the sites which we feel could potentially be affected
by the development rather than just concentrating on those identified by, for example, the Planning
Inspector. We have however concentrated on Designated Heritage Assets (specifically scheduled
monuments, listed buildings, registered parks and gardens and conservation areas) rather than
seeking to identify any non-designated heritage assets.
1.05 The proposed development will not have any impact on the physical fabric of the various
heritage assets, but impact on their settings is also a consideration. Paragraph 132 of the NPPF is
clear that harm to heritage significance can occur through development within an asset’s setting and
it advises that ‘the more important the asset, the greater the weight’ which should be given to its
conservation.
1.06 The statutory duty with regard to Listed Buildings has already been referred to. The
Planning (Listed Buildings and Conservation Areas) Act 1990 places a similar duty when exercising
planning functions which affect conservation areas. Section 72 of the act requires that ‘special
attention shall be paid to the desirability of preserving or enhancing the character or appearance of
that area’. For that reason, and in the light of the High Court Judge’s comments, we have looked
again at the Baconsthorpe, Bessingham and Matlaske Conservation Areas as these are the three
closest to the proposed turbine and they contain designated heritage assets which have been
separately assessed by the applicant.
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2.0
HERITAGE ASSETS POTENTIALLY AFFECTED BY THE DEVELOPMENT
Baconsthorpe Castle (Scheduled Monument and Grade I and II Listed Buildings)
2.01 This is a clearly a heritage asset of extremely high significance. In paragraph 3.7, the
Heritage Impact Assessment (HIA) submitted by the applicant describes it as ‘a rare monument type
with fewer than 200 identified examples’. English Heritage (letter of 20/8/14) describe it as ‘an
extensive and highly valued heritage asset.’
2.02 The HIA accepts that ‘the tranquil isolated rural setting contributes to the significance of the
monument, which has a long-established relationship with its surrounding landscape’ (para 3.9)
though it feels that the landscape has ‘changed markedly’ since the construction of the Castle.
English Heritage agree that the character of the surrounding landscape is important and contributes
to the asset’s heritage significance because it is ‘an important backdrop to the site and enhances its
historic and aesthetic values’. Notably they also describe this landscape as ‘for the most part
unchanged’ in direct opposition to the views of the applicant.
2.03 In our opinion, whilst farming practices may have changed, trees and other vegetation may
have grown or been felled, none of this has affected the sense of rural isolation and tranquillity
which is an essential part of the asset’s setting.
2.04 The HIA accepts that the turbine is ‘clearly likely’ to have an impact on the setting of the
Castle. These include ‘barely discernible’ views from a ‘limited number of positions’ within the
moated area; from outside the moated area (the gardens beyond the moat, to the east of the outer
gatehouse and from within the car park) though the turbine ‘would not feature strongly’; and from
the footpath to the west of the castle where glimpses would be seen in juxtaposition with the
remains as it would from the footpath to the SW towards the Castle from Baconsthorpe village.
2.05 In English Heritage’s view, these are important locations and the wind turbine, with the
circular kinetic movement of its blades, would harm the setting of the castle and its heritage
significance.
2.06 It is important to remember that the land within the ‘scheduled area’ of this asset is quite
extensive covering the remains, former gardens, land beside the moated area and the car park.
Visitors are encouraged to walk around the site with the first interpretation board within the car
park itself. It is likely that anyone reading this board and then moving towards the path through the
outer gatehouse would see the turbine particularly due to its turning blades. This would inevitably
jar with the tranquil natural setting of the monument. As one then moved around the site, views of
the turbine would again be possible, further distracting the visitor. This harms the setting of the
asset and the contribution which this makes to its heritage significance.
2.07 It is accepted that the turbine now proposed is smaller than was previously applied for.
However it will still be noticeable and the sense of movement will be unchanged. The presence of
the nearby mast is irrefutable, but the impact of this is less than that of the turbine (despite its
greater height) because of its filigree nature and the fact that it is static.
2.08 The view from the footpath which runs immediately to the west of the Castle is also
important as, without a doubt, this would form one of the highlights of a walk in this area and the
path offers some good vantage points over the entire site. The fact that the turbine would be seen
in juxtaposition with the Castle, as is accepted by the applicant (as shown in Heritage Viewpoint 3
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[Genatec April 2014]), causes clear harm to the asset’s setting and the contribution which this makes
to its heritage significance.
2.09 In our view, this is an asset of very high heritage significance and the importance of the
tranquil, rural location to its setting appears to be accepted by all. Whilst the harm caused to the
setting, and to the significance of the asset is ‘less than substantial’, it is still significant.
Barningham Hall, including the Winter Church (Grade I and Grade II* and Grade II Registered Park/
Garden
2.10 Barningham Hall, is a substantial country house set within a parkland and with attendant
stable block and consciously designed partly-ruined church. Once again, in heritage terms, the
whole site is of very high significance. This significance is amplified by the involvement of the
famous landscape architect / architect Humphry Repton and the presence of some of his famous
‘before and after’ images and other drawings adds considerably to its heritage values.
2.11 The HIA suggests that ‘arguably the most the (sic) significant elements within the designed
landscape is the impressive west avenue’. Outstanding as this is as a device for focusing views to and
from the hall, we feel that Repton’s conscious manipulation of the landscape so that the hall is
hidden whilst travelling northwards from the south entrance until it suddenly ‘bursts’ into view is an
extremely important aspect of the building’s setting and the heritage significance of the park itself.
The fact that turbine will be visible at times along this drive before the hall is reached would
therefore have a major impact on the heritage significance of the assets.
2.12 The applicant suggests that Barningham Hall, like some other historic parklands, was meant
to be effectively ‘self-contained’ by being screened from the surrounding countryside by belts of
trees. I don’t think that this is the case here and some managed views into the surrounding
countryside were seemingly created by Repton. However, even if the parkland was meant to be
enclosed by trees, the visibility of a modern feature beyond the confines of the parkland would harm
this design intention to the detriment of the setting and heritage significance of the asset. In our
view the moving blades will create a clear distraction from within the parkland and therefore there is
clear harm, regardless of whether the parkland was meant to be enclosed from or interact with the
adjacent countryside.
2.13 The applicant accepts that views of the turbine will also be possible from within the western
avenue and probably from some higher level north-facing windows. In the case of the avenue, this
will have an impact, by possibly distracting the viewer away from the principal east-west views, but
we feel that this is a relatively minor and localised distraction particularly as the avenue was largely
there to form a viewing ‘tunnel’ from either end, rather than being enjoyed from within. The main
views from the hall face west and south and I do not therefore feel that views of the turbine from
north-facing windows will harm the hall’s heritage significance
2.14 The Church of St Mary, Barningham (the Winter Church) is itself Grade II* with its C19 south
gate separately listed Grade II and, as the entry from English Heritage’s Register of Historic Parks and
Gardens states, ‘the whole is visually important to the landscape scheme’ and it acts as a focal point
in views northwards along the drive. Again, the HIA accepts that the turbine will be visible from the
main drive when approaching the church. This therefore serves to distract the eye from what is
meant to be the ‘eye catcher’ and again causes harm to the setting of the hall, the parkland and the
building itself. The latter is further harmed by the views of the turbine through the archway in the
ruined part of the church which acts as a ‘frame’ to views as one walks up the path northwards
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before turning eastwards into the church. The presence of the path up to the archway shows that
people are encouraged to look northwards from this point.
2.15 Barningham Hall comprises a group of listed buildings of considerable importance, their
value amplified by their position within an historic park and garden which was remodelled by one of
the leading landscape architects of the day. The turbine, although not so visible as previously
proposed, will still attract attention and this will work against how the parkland was intended to be
experienced, harming the setting of the house and Winter Church and their heritage significance and
the parkland and its significance. Although this harm is ‘less than substantial’ it is still significant.
All Saints Church, Bodham (Grade II*)
2.16 This C14 church, restored in the C19 and C20 is Grade II* Listed. Its relatively isolated
location around 1km from the village it serves is typical of the relationship between many of the
medieval churches in the area and the landscape in which they sit. The Heritage Impact Assessment
accepts that the setting of the building contributes to its heritage significance.
2.17 The church and proposed turbine would be visible in the same field of view from a number
of locations, including from the A148. There will therefore be some harm to the wider appreciation
of the heritage asset in its landscape setting.
2.18 One of the clearest views of church and turbine together would be from the Grade II Listed
Manor Farm and the adjacent lane. The juxtaposition of manor and church is an aspect of the
morphology of many villages and here the lack of intervening and adjacent development serves to
emphasise this relationship and the rural, relatively isolated location. The view of the turbine with
its moving blades will harm this aspect of the setting of both buildings.
2.19 The Heritage Impact Assessment suggests that recent hedge planting along the lane will
mitigate this effect but this would only be achieved by depriving the viewer of sight of the church. In
any case, for this to be effective, the hedge will need some years to mature and then it would need
to be appropriately maintained to provide an effective screen.
2.20 The Heritage Impact Assessment suggests that the turbine will have little impact on any
views from the Church itself as it would be behind anyone entering the church. Clearly however that
means it could be visible to anyone leaving the church, including standing in the porch or on the
path to the gate and whilst walking towards the car park. The rural surroundings would be apparent
to anyone leaving the church and congregating outside and the presence of the turbine and the
sense of movement will harm this aspect of the church’s setting to the detriment of its heritage
significance.
2.21 We consider the harm to be less than substantial and, although not so great as the harm to
Baconsthorpe Castle or Barningham Hall and its associated park and church, it is nevertheless of
some significance.
St Mary’s Baconsthorpe (Grade II*)
2.22 This substantial parish church dates to the C13 and C15 and was restored in the C19. It sits
in the SE corner of the village in a relatively large churchyard between the Manor House and
Rectory. The church is within the village Conservation Area.
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2.23 The HIA acknowledges that the rural setting contributes to the building’s heritage
significance and accepts that there will be views of the turbine, across relatively open flat land to the
NE from the churchyard and across the modern graveyard on the north side of the lane.
2.24 Trees and telegraph poles and wires will be seen in the same views as the turbine but it will
still be easily noticeable from the churchyard, the lane and the modern grave yard. Importantly, it
will be visible as one leaves the church and walks down the path, out of the gate and into the lane.
Unlike the previous Inspector, I feel that this would not just be the case in winter, but at other times
of year too.
2.25 The presence of the turbine will cause harm to the contribution which its setting makes to
its heritage significance. This harm will be less than substantial but still significant.
St Peter’s North Barningham (Grade II*)
2.26 This redundant medieval church sits in a very isolated position some distance from the
nearest buildings. The HIA acknowledges that the undeveloped surroundings and rural setting
contribute to the building’s heritage significance.
2.27 The churchyard is very tightly enclosed by substantial trees and although the turbine is only
around 1.5km from the church, there are unlikely to be any views of the turbine from the church or
churchyard.
2.28 The HIA acknowledges that there will be a view of the church and turbine in the same field
of view from the SE and the turbine would be taller on the skyline than the church tower. This will
cause some harm to the appreciation of the church in its rural setting and diminishes its role as a
feature within the rural landscape. A similar impact will occur in views from the churchyard of St
Mary’s, Bessingham (see below). However these views are relatively limited and as noted above,
more immediate views towards and from the church are screened by the surrounding grove of
mature trees.
2.29 There is therefore some harm to the setting of the church but this causes less than
substantial harm to its heritage significance.
St Mary’s, Bessingham (Grade II*)
2.30 This ancient church dates to the C11 with much medieval work and was restored in the C19
and C20. It stands, in any elevated position to the north of the rest of the small village though it
does sit within the village conservation area. The HIA accepts that its isolated, undeveloped
surroundings contribute to its heritage significance. It also comments that from the western edge of
the churchyard there are clear views over the surrounding countryside and equally clear views of the
turbine would be possible from here.
2.31 The views of the turbine will be mostly from the rear part of the graveyard behind the
church. Due to the fall of the land, it appears unlikely that the church and turbine would be seen in
the same view, one would have to go past the church towards the footpath before the turbine
would become visible.
2.32 From this position however, and as illustrated in Heritage Viewpoint 21, St Peter’s Church
North Barningham is visible. Whilst it is some distance to the south of the proposed turbine, the
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latter will appear as a more dominant feature on the skyline diminishing the value of the church as a
focal point in the landscape.
2.33 In our view there would be minor harm to the setting of Bessingham Church and its heritage
significance or to the character and appearance of the Conservation Area.
St. Michael’s Plumstead (Grade II*)
2.34 Despite being commented on by the Conservation Officer in the previous application, the
HIA does not assess any potential impact on the setting of this medieval church which dates back to
the C12. The church which, although within the small village, is separated from the proposed
development by open, rising land. The previous Inspector commented that views of the turbine
would only be possible in winter.
2.35 Some views of the turbine on the skyline will be possible from the road beside the church
and from within the churchyard to the west of the tower and from the seat in the graveyard to the
rear. However, as the turbine will be over 3km away, its impact is considered to be limited as at this
distance it would appear as a fairly minor incident on the skyline. Harm to the setting and the
heritage significance is therefore considered to be less than substantial but would likely occur
throughout the year, not just in winter.
Baconsthorpe Conservation Area
2.36 The HIA has not considered any potential impact on the setting of any of the local
conservation areas including Baconsthorpe which includes the Church of St Mary. English Heritage
consider that there will be a negative impact on its wider setting.
2.37 The Baconsthorpe Conservation Area encompasses the heart of the village along The Street
either side of the Jolly’s Lane junction with a second nucleus around the church and Manor House. It
also includes a western spur around Pitt Farm, a NE block formed by the L-shaped leg of The Street
and part of New Road and an eastern leg along Church Lane to Manor Farm House.
2.38 The consequence of this is that the open land in the heart of the village, between The Street
and School Lane forms the central core of the conservation area, whilst the roads at the edges allow
views out into the open countryside and so highlight the rural nature of the place.
2.39 In our opinion, there will be some views of the turbine from between Pitt Farm and Ash Tree
Farm at the western edge of the village, from the L-shaped NE spur of the Street and New Street,
from Plumstead Road and from Church Lane. The latter will include views from the Churchyard as
one leaves the church and across the modern graveyard on the north side of Church Lane.
2.40 Further views will also be possible from the Plumstead Road junction and from School Lane,
across the open space at the heart of the conservation area. The appearance of a modern, kinetic
structure will be at odds with the rural setting of the village conservation area and will have some
impact on this designated heritage asset’s setting and on its character and appearance. This harm is
considered to be less than substantial, but nonetheless of some significance.
Bessingham Conservation Area
2.41 Bessingham has an enclosed relatively intimate character as the result of its position in the
valley bottom and the enclosing tree and shrub belts. The land rises towards the church at the
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northern end of the village. Despite this, the only obvious views of the turbine will be from the
western edge of the churchyard, and the impact of this is therefore considered to cause relatively
little harm to the contribution which the rural setting makes to the area’s character and appearance.
Matlaske Conservation Area
2.42 This attractive small village lies to the south of Barningham Hall with the south drive to the
Hall close to the centre of the village Conservation Area. The presence of the trees within the
parkland and gardens of the hall and within the village itself, mean that at a distance of around
3.5km from the turbine, no clear views would be possible and no harm to the character and
appearance of the conservation area has been identified.
3.0
CONCLUSIONS
3.01 The High Court Judge’s ruling on the previous scheme has echoed a number of recent
planning appeals and challenges in which it has been made clear that simply weighing any ‘less than
substantial harm’ to a heritage asset with any identified public benefit (as required by paragraph 134
of the NPPF) is insufficient in itself to show the ‘special regard’ to the desirability of preserving a
listed building and its setting which Section 66 of the Act requires.
3.02 Mr Justice Lindblom, in the High Court on 12 June 2014, in what has become known as ‘The
Forge Field Society’ Case more recently assessed the effect of these recent decision (Case Nos:
CO/735/2013 & CO/16932/2013). He commented:48
As the Court of Appeal has been made absolutely clear in its recent decision in ‘Barnwell’, the
duties in Sections 66 and 72 of the Listed Buildings Act do not allow a local planning
authority to treat the desirability of preserving the settings of listed buildings and the
character and appearance of conservation areas as mere material considerations to which it
can simply attach such weight as it sees fit. If there was any doubt about this before the
decision in ‘Barnwell’ it has now been firmly dispelled. When an authority finds that a
proposed development would harm the setting of a listed building or the character or
appearance of a conservation are, it must give that harm considerable importance and
weight.
49.
This does not mean that an authority’s assessment of likely harm to the setting of a listed
building or to a conservation area is other than a matter for its own planning judgement. It
does not mean that the weight the authority should give to harm which it considers would be
limited or less than substantial must be the same as the weight it might give to harm which
would be substantial. But it is to recognise, as the Court of Appeal emphasised in Barnwell,
that a finding of harm to the setting of a listed building or to a conservation area gives rise to
a strong presumption against planning permission being granted. The presumption is a
statutory one. It is not irrefutable. It can be outweighed by material considerations powerful
enough to do so. But an authority can only properly strike the balance between harm to a
heritage asset on the one hand and planning benefits on the other if it is conscious of the
statutory presumption in favour of preservation and if it demonstrably applies that
presumption to the proposal it is considering.
3.03 The Secretary of State in endorsing an Inspector’s decision at Brackenhurst College,
Southwell (PINS ref APP/B3030/A/13/2208417), came to a similar conclusion ‘…that it does not
follow that if the harm to heritage assets is found to be less than substantial, then the subsequent
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balancing exercise undertaken by the decision taker should ignore the overarching statutory duty
imposed by Section 66(I) and, like the Inspector, he therefore sees a need to give considerable weight
to the desirability of preserving the setting of all listed buildings.’
3.04 The Inspector previously identified harm to the settings of All Saints Church, Bodham, St
Peter’s Church North Barningham, Barningham Hall (including the park and garden and the Winter
Church) and Baconsthorpe Castle and to a lesser extent to the churches at Bessingham,
Baconsthorpe and Plumstead. Clearly since then the proposed turbine has been made smaller and
we have therefore reassessed the impact. For completeness, we have also looked at the
conservation areas at Baconsthorpe, Bessingham and Matlaske. In doing so, we have identified
some minor harm to the character and appearance of the Baconsthorpe Conservation Area caused
by the harm to its setting ant to views across and out of the area in which the turbine will be clearly
visible.
3.05 The harm which we have identified to the contribution which the setting makes to the
heritage significance of Baconsthorpe Castle, which is an ancient monument containing listed
buildings, and to Barningham Hall, a Grade I listed house containing other listed structures in a
designated park and garden, is of greatest concern. These are assets of the highest heritage value
and the desirability of the preservation of their settings must be given special regard. In the case of
Baconsthorpe Castle, the turbine will be a feature at odds with the isolated rural location and what
this contributes to the heritage significance of the place. In the case of Barningham Hall, the turbine
will effectively become an ‘eye-catcher’ or distraction outside the parkland serving to undermine the
design intention of the park and how it relates to the main house and the Winter Church.
3.06 Whilst the harm to these designated heritage assets is ‘less than substantial’ using the tests
in the NPPF, nevertheless it is of considerable significance.
3.07 We have also identified harm to the settings of Bodham and Baconsthorpe Churches and to
those at Bessingham and Plumstead, the latter to a slightly lesser extent. This harm is caused by the
impact which the turbine will have on the relatively isolated rural settings of the churches because
this contributes to the heritage significance of the buildings. We attribute a higher degree of harm
where the turbine will be clearly seen from the church and their immediate environs. Again this
harm is ‘less than substantial’ but nevertheless of some significance.
3.08 In our view there is also some harm to the setting of Baconsthorpe Conservation Area and
lesser harm to that at Bessingham. In the case of Baconsthorpe, this is because the turbine will
intrude in views from several streets within the Conservation Area, including around the church. In
doing so, it will introduce a clearly modern, moving structure into an otherwise relatively
undeveloped rural landscape setting. At Bessingham, a view of the turbine would be from the
churchyard only which is right at the north end of the conservation area and its impact is therefore
more limited.
3.09 Section 72 of the Act, unlike Section 66 does not specifically mention the setting of
conservation areas but does require special attention to be paid to the desirability of preserving the
character and appearance of the area. In our view there will be a relatively minor impact on the
character and appearance of the Baconsthorpe Conservation Area and less still on Bessingham. The
harm that is caused still needs to be carefully considered to fulfil the statutory test.
3.10 The previous Inspector (paragraph 58 of his report), considered that the cumulative harm to
the heritage assets caused by the previous, larger turbine was ‘less than substantial’. We would
agree that this is the case for this application for a smaller structure. However, the Inspector when
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reaching his conclusion was held not to have fully considered the statutory duty imposed by Section
66 of the Act and this is of considerable importance to our conclusions on this application.
3.11 There is a very clear presumption in favour of preserving the setting of listed buildings as
required by Section 66 of the Act. The previous Inspector identified harm to the settings of a
number of listed buildings, the applicants accept there is harm and our conclusions clearly reinforce
this. This harm needs to be considered outwith the balance required by Paragraph 134 of the NPPF.
In our view there is a significant level of harm to a number of highly-graded Listed Buildings and
there must therefore be a strong presumption against the granting of planning permission. We
would also add to this a similar presumption against approval caused by the harm which we have
identified to the character and appearance of Baconsthorpe and to a lesser extent the Bessingham
Conservation Areas.
3.12 It is not within our remit to undertake the ‘planning balance’ between the harm which we
have identified and the wider benefits which this scheme will bring. We would however advise that
in our view these would need to be ‘powerful’ (using Justice Lindblom’s word quoted above) to
outweigh the clear harm which has been identified.
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APPENDIX 2
North Norfolk District Council Conservation, Design and Landscape MEMORANDUM
To: Geoff Lyon, Team Leader, Enforcement & Special Cases Ref: PF/14/0925 From: Cathy Batchelar, Landscape Officer Date: Dec 9th 2014 Erection of wind turbine (66m to blade tip, 40m to hub height), associated substation buildings, access tracks and crane hardstanding, Pond Farm, Bodham
1.0 SUMMARY
In assessing the landscape, visual and ecological impacts of the proposal with reference to the relevant reports submitted with the application, Conservation Design & Landscape conclude that the effects of the proposed development will be more significant on landscape character, visual receptors and the setting of heritage assets than has been presented in the documentation. Officer opinion is that this proposal would be contrary to Local Plan Policies EN2, EN7 and EN8, and that, given the number of heritage assets affected, insufficient weight has been given to the duty under s.66 of the Planning & Listed Buildings and Conservation Areas) Act 1990 ‘to have regard to the desirability of preserving the building or its setting or any features of special architectural or historical interest which it possesses. 2.0 LANDSCAPE EFFECTS
The Landscape & Visual Impact Appraisal (LVIA) dated May 2014 undertaken by The Landscape Partnership has, for the most part, been carried out in accordance with recognised professional best practice (Guidelines for Landscape & Visual Impact Assessment, 3rd edition, 2013, Landscape Institute and IEMA) (GVLIA 3). The 10km radius selected as the study area incorporates key viewpoints in order to assess the potential visual and landscape effects. Likely effects are assessed at two time periods in terms of degree of change on completion of works, at Year 1 in the winter and at Year 10 in the summer in order to demonstrate the efficacy of the proposed mitigation planting. Having laid out a set of criteria and methodology for assessment in Appendix 1 of the LVIA, Conservation Design & Landscape consider that the value judgements attributed to a specific viewpoint or receptor have been under‐estimated and that the actual effects incurred as a result of this development will be more significant. Within the context of this largely traditional arable landscape of rural North Norfolk, the ratings attributed under‐value the effects on the landscape character and under‐estimate the visual effects. Specific examples are laid out below to demonstrate this misrepresentation. 1
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2.1 Tributary Farmland (TF3) The site lies within Tributary Farmland (Hempstead, Bodham, Aylmerton & Wickmere,TF3), as classified in the North Norfolk Landscape Character Assessment (SPD, June 2009) (NNLCA). A landscape value rating of High rather than Medium would be more accurate, given the number and significance of the heritage assets within the landscape type, and the fact that the site is located in a part of TF3 which has a strong character (NNLCA p. 52). A Very High Susceptibility to Change would be a more accurate assessment than High, given the high plateau topography and the nature of the proposal. The Magnitude of Change has also been underrated, with a Geographical Influence rating of High rather than Medium being more realistic and the Scale of Change more accurately assessed as High rather than Medium. This leads to an under‐estimation of the overall Significance of Effect which would be Major/Moderate rather than Moderate and which would be ‘significant according to the LVIA (2.12). Duration and Reversibility are one of the criteria used to assess Magnitude of Change. While this development would be reversible and would not be a permanent feature of the landscape, the fact that it would be in place for 25 years is, in effect, a lifetime for those who would experience the feature within the landscape. The Low rating attributed to all the Landscape Types does not reflect this and is therefore misleading. 2.2 Wooded with Parkland (WP5) This can be applied to other Landscape Types such as WP5, Wooded with Parkland, where Landscape Sensitivity is under‐rated within the LVIA as Medium, citing the rolling landform and blocks of woodland as features that would limit the degree of visual impact (8.46). It is precisely this relatively high rolling landform that would afford frequent views of the turbine from numerous locations within this small, contained and traditional Landscape Type. The NNLCA in 12.5.5 considers that the very rural, sensitive and relatively intact nature of the landscape of this Area would be considerably disturbed by the introduction of large scale features such as wind turbines or significant amounts of agricultural development. A rating of High Sensitivity with High Susceptibility would give a High Landscape Sensitivity rating which would more accurate and would accord with the NNLCA. Coupled with a more realistic Magnitude of Effect rating of Medium rather than Low, the overall Significance of Effect of a moving turbine of the scale as proposed on this Landscape Type would be Major‐
Moderate, a rating which the LVIA considers to be ‘significant’. 2.3 Valley Headlands The study concludes that the landscape effects of the development would principally affect ‘one part of the Tributary Farmlands Character Area (TF3)’ (Section 11.2 of the LVIA), as defined in the North Norfolk Landscape Character Assessment (NNLCA) (Supplementary Planning Document June 2009). The LVIA departs from the NNLCA and makes its own sub‐
division of this particular landscape type, namely Valley Headlands. This is confusing as it splits out a fundamental feature of the Tributary Farmland landscape, as the name implies. This Landscape Type is defined and created by the undulating catchment slopes that feed into these very river valleys and they form an intrinsic part of the landscape. The NNLCA acknowledges these Small River Valley Areas (p 51) but recognises that they are a key component of this landscape type. Separating them out from TF3 does not allow for an accurate assessment of the effects of the development on the defined landscape character type. It allows for a diminished effect. Most importantly, the effect on Baconsthorpe Castle, a Scheduled Ancient Monument comprising the highest grade listed buildings, which lies within TF3, has been removed from the equation and considered under the Valley Headland. 2
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This allows for misrepresentation of the effect of the proposals on the defined TF3 Landscape Type. 2.4 Cromer Ridge The site of the proposed turbine within TF3 Landscape Type is at 89.9m AOD which is one of the highest points in North Norfolk. The location here on Cromer Ridge is directly contrary to the advice within the NNLCA which in 5.3.5 states’ the landscape is moderately sensitive depending upon the location within the area and the type of development proposed. Some parts may be suitable for small scale wind turbine siting taking care not to place them so prominently that they are apparent for miles (i.e. near the Cromer Ridge). Comprising glacial moraines and forming some of the highest land in East Anglia, Cromer Ridge extends for 14km across North Norfolk and is a highly significant landscape feature within an otherwise gentle low‐lying undulating landscape. This is reinforced by its reference as a ‘key characteristic of the landscape of Central North Norfolk’, as described in the Natural England National Character Area 78 Central North Norfolk. In 8.22 and 8.23 the LVIA seeks to diminish this important consideration by claiming that the NNLCA does not define Cromer Ridge nor does it consider how this ridge is more sensitive than other ridges in North Norfolk. It also argues in 8.24 that the site location is on the ‘less sensitive’ section of the Ridge and that this diminishes the effect. Raising these issues does not detract from the fact that a 66m high turbine sited at one of the highest points in North Norfolk on the domed plateau formed from the Cromer Ridge would be visible for miles around as illustrated by the wide extent of the Zone of Theoretical Visibility (Genatec, Figure 1) and the Topographical Map (Genatec, Figure 8). The extent of high level topography within the 10km radius in Figure 8 demonstrates clearly where long range views of the turbine would not be obscured by vegetation. Furthermore the LVIA concludes in 11.2 that the turbine ‘would not be considered incompatible with the Norfolk landscape and the character of Cromer Ridge’. At 66m to blade tip, this is a medium (not small) scale turbine that would be highly significant on the skyline. The skyline itself is highlighted in the NNCLA as a prominent characteristic of the rolling landscape and long uninterrupted views of TF3, the receiving landscape type. There are no other medium scale on‐shore turbines in this part of North Norfolk and to conclude that the turbine would be compatible with this landscape is misleading. To also claim that it would be compatible with the character of Cromer Ridge is also erroneous. The Ridge forms an almost continuous wooded backdrop on the horizon when viewed from inland. The addition of a prominent moving turbine could in no sense be considered as a ‘compatible’ element. 2.5 Masts and blades The presence of the two existing transmitter masts is used in 8.17 of the LVIA to justify a ‘localised change’ to the landscape of TF3 arguing that ‘the effect on the skyline would be of adding another element to the existing character rather than introducing a new element…’ The effect of the constant moving element of the blades has been underestimated and this distracting feature would constitute a new element in the landscape. The existing masts are latticed structures which give some degree of transparency as opposed to the solid composition of a turbine. Again, this aspect of the proposal and its effect both on the landscape character and receptors has not been given due consideration and weight in the overall assessment. 3
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3.0 HERITAGE ASSETS
3.1 Landscape Effects Norfolk is renowned for hosting the greatest concentration of medieval churches in the world (Norfolk Churches Trust). These designated assets form an important component of the landscape character of the county and their landscape setting is an intrinsic part of their significance. The siting of these and other heritage assets, their relationship with their parish, together with the inter‐visibility between the assets were all part of the design considerations in their original sitings. GVLIA3 in 5.29 notes that ‘areas of landscape whose character is judged to be intact and in good condition, and where scenic quality, wildness or tranquillity, and natural or cultural heritage features make an important contribution to the landsape, or where there are important associations, are likely to be highly valued’. Within the Tributary Farmland landscape type (TF3), Bodham church, Baconsthorpe church, North Barningham church, Plumstead church and Bessingham church are all designated Grade II* assets that would, to varying degrees, be impacted by the development. Baconsthorpe Conservation Area would also be affected by the proposal. This will inevitably have a negative impact on the landscape character and the perception of these key buildings within their landscape. This is a key consideration in assessing the effects of the development on the landscape of TF3. Within the LVIA (p.48) the effects on the setting of these significant buildings and the resulting impact on the landscape character have been under‐assessed. This does not accord with the duties under s.66 and s.72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 which were highlighted in the High Court appeal decision for the previous 86.5m high turbine (Planning ref: PF/11/0983). Baconsthorpe Castle holds the highest designations and its relatively unchanged quiet pastoral setting is an important feature of this highly valued heritage asset, as reinforced in the representation by English Heritage. The landscape setting is a highly significant component of this important asset and, as such, is very sensitive. Situated 1.7km east and in an elevated position, the turbine would intrude on this important setting and would significantly affect the landscape character. This has not been given due consideration within the LVIA and has been diluted by being incorporated into the effects on a supplementary Landscape Type, not defined in the NNLCA. Within the Wooded with Parkland Landscape Type (WP5), Barningham Hall with its highly designated buildings and Grade II registered Park & Garden, is a significant component of the form and character of this landscape. Frequent views of this historic designed landscape within its pastoral setting are gained from the minor roads within WP5 and the effect of the juxtaposition of the turbine and the parkland in views from outside the Hall within this Landscape Type has been under‐assessed. Using selected viewpoints, the LVIA concludes that the significance of effect on the Grade II registered Park & Garden of Barningham Hall would be Moderate Adverse. While it acknowledges that this is a landscape of Very High Sensitivity, the rating of a Low Scale of the Change that would result is inaccurate. The views gained beyond the Park from within are all of a traditional rural landscape with minimal signs of modern development. Although distant, the introduction of a moving turbine into this context would result in a much higher Scale of Change. 4
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3.2 Visual Effects Conservation, Design & Landscape consider that the visual effects on heritage assets have been underrated. GVLIA3 (6.33) advises that visitors most susceptible to change include visitors to heritage assets where views of the surroundings are an important contributor to the experience. This is applicable to the medieval churches of North Norfolk where, as already explained above, the setting of these assets was a key factor in their original siting. As an integral part of the landscape of the area, the visual impact of the proposed development on their setting has not been given sufficient weight in the submitted LVIA. The LVIA has not given sufficient weight to the visual effect of the proposal on visitors to Baconsthorpe Castle (Scheduled Ancient Monument, Grade I and Grade II listings). The visual effects on the Castle have been assessed using only one viewpoint. This not give a true reflection, given that the Castle can be approached from any one of four separate footpaths from the North, South, North East and South West. Furthermore, once within the Castle grounds, the visitor will gain repeated views of the turbine from several of the various ruins that make up the asset e.g. close to the Gatehouse entrance, from the inner courtyard and from the edge of the moat. This modern element will detract from the experience of appreciating the castle in its traditional historic landscape setting, a key feature of this heritage asset as highlighted by English Heritage in their representation dated 20/08/2014. Factors making up the Magnitude of Change have been under‐valued, resulting in a Low rating that is not realistic. For example in the case of VP13, Baconsthorpe Castle Footpath 3, the size of the change is rated as Low, whereby in accordance with the LVIA rating criteria in Table 11 a rating of Medium would be a more accurate representation of the change that would occur. This would then raise the overall rating to Major‐Moderate, a Significant Effect. This can also be applied to VP12: Wells Farm Cottage, Barningham where the Value of the view is assessed as Low. This view is of St Peters Church, North Barningham (Grade II*) in its elevated landscape setting and, although viewed from a minor road, is worthy of a Medium rating. The introduction of the turbine into this view would dramatically alter the significance of the church within this view and the significance of effect has been underrated. The LVIA criteria for Value of a View (Table 8) does not accord with the advice within GVLIA3 (6.37) which states that judgements relating to the value attached to views should take account of the relation to heritage assets. Table 8 does not give sufficient weight to this, placing undue emphasis on the extent to which a view is publicised and known. Furthermore, there are a limited number of defined categories which results in too broad an assessment, e.g. a Low value rating as attributed to the pastoral view at VP12 would presumably also apply to a view of a degraded industrial landscape? The LVIA conclusion, in 11.9, that the Magnitude of Change incurred by the addition of the turbine would be ‘incidental’ to the overall context and appreciation of the features in the historic landscape under‐values the significance of the place and role of these recognised land mark features within the North Norfolk landscape and pays little regard to the high number of heritage assets that would be affected by this proposal. 4.0 VISUAL EFFECTS
Within the LVIA, visual effects are assessed by combining the magnitude of the change that would be incurred with the sensitivity of the receptor to derive a significance of impact. 5
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The LVIA concludes that the most significant visual effects (Major Adverse) would be experienced at two properties in the vicinity of Camp Farm (VP1). Two other viewpoints are assessed as Major‐Moderate Adverse (VP2 Plum Lane & VP3 Hill Farm). Given the proximity of these properties to the turbine, the mitigation measures proposed such as instant hedging and large oak trees will have minimal beneficial effect, as reflected in the Significance of Effect in Year 10 and acknowledged in 9.22. Although not addressed in the current guidance (GVLIA3), the LVIA in Section 9, discusses the concept of ‘overbearing’ at some length, citing recent case law to back their argument that this development would not be ‘overbearing’ on any of the properties. Clearly each case is different and must take into account the nature of the setting and context of the dwellings. Given the proximity of the dwellings combined with the elevated and open nature of the landscape around the site and the acknowledged significant adverse effect, Conservation Design & Landscape are of the opinion that the visual effect could be considered to be overbearing, certainly on properties close to the site along Osier Lane and at Hill Farm on Rectory Road. The visual effects incurred by users of Bodham Footpaths 8 & 9 and the Sustrans Regional Cycle Route 30 have been briefly assessed within the LVIA (9.41 and 9.42), but little emphasis attributed to these receptors who would be significantly affected, given the proximity of the turbine. GVLIA 3 (6.33) assesses users of public rights of way, those engaged in outdoor recreation and visitors to heritage assets as ‘visual receptors highly susceptible to change’. Mitigation planting is used to justify a diminished effect, but this would only be after a significant period of time and would be less effective than anticipated, given the height of the turbine. The effects of the turbine on views experienced by road users of the A148 main tourist route through North Norfolk are assessed via Viewpoints 4, 5 & 6. The conclusion of Minor Adverse for all three locations does not take into account the repeated views of the moving blades that would be experienced, albeit not in the near view. Viewpoint 6, A148 between High Kelling and Bodham does not account for the combined view of the turbine and All Saints Church, Bodham. Along this stretch of road the significance of the church in the landscape will be overshadowed by the scale and movement of the turbine. GVLIA3, in 6.22, emphasises the importance of ‘sequential’ views along key transport corridors and notes that viewpoints should account for ‘the full range of different types of people who may be affected’. In relation to this proposal, road users should include holidaymakers, commuters and residents. The susceptibility of these receptors to the introduction of a large scale feature such as a turbine will vary and this has not been accounted for within the submitted LVIA. The A148 delineates the southern boundary of the Norfolk Coast AONB. While there would be distant views of the turbine from this part of the designated landscape, due to the distance away and the wooded nature of the sloping land north of the road, Conservation Design & Landscape consider that the identified special qualities of the AONB, such as the elements of wilderness and the dynamic coastal features complemented by rising agricultural land, will not be adversely affected by this proposal. It is worthy of note that the GVLIA3 (in section 6.33) lists visual receptors who are most susceptible to change. These are residents at home, people engaged in outdoor recreation, visitors to heritage assets or other attractions where views of the surroundings are an important contributor to the experience, communities where views contribute to the 6
108
landscape setting enjoyed by residents in the area. Within the context of the rural landscape of this part of North Norfolk, a popular holiday destination, all these receptors are relevant. Collectively, this general under‐rating gives a diminished effect of the proposal and does not therefore portray an accurate representation of the visual effects that would result from this development. 5.0 ECOLOGY
The Ecological Assessment Report submitted by Wild Frontier Ecology dated March 2014, relies largely on survey data from the previous application of 2011, apart from a fresh Phase One Habitat Survey, Badger Survey and desk study undertaken in March 2014. The British Standard for Biodiversity (BS 42020:2013) advises in 6.2 that the shelf life of any given survey depends on the type of survey undertaken, environmental conditions at the time of survey and the degree to which the conditions have altered. The study notes that the most significant change in the habitats around the turbine since the date of the last turbine proposal (2011) is the installation of a 7.9ha solar farm in the field immediately adjacent to the site of the current turbine, which is the same location as the previous proposal. The consequences of this changed habitat are predicted to be a reduction in use of the area by wintering open field species such as golden plover and lapwing. However the management of the land beneath the solar panels as grazed grassland may lead to net positive effects on the local bird population. In 5.4 of their submission, Wild Frontier acknowledge that the ornithological survey data is out of date (undertaken in Nov 2009 to Dec 2010 by Wold Ecology), but in 5.1.2 consider that the data is still relevant and that changes to the surrounding habitat are not significant, as revealed in the updated Phase 1 Habitat Survey. It is therefore considered that the ecological data gathered is sufficient to conclude that there will be no significant impacts on ecological receptors. The previous application included Collision Risk Modelling to further consider impacts on the limited number of pink‐footed geese which were recorded over flying the site. The Ecological Report is of the view that given the lowered turbine height that is the subject of this proposal, the hazard area is reduced and collision rates would be proportionately lower and this is a fair assessment. Several species of bats were recorded during the 2012 surveys at varying levels of frequency. These surveys are just within the lifespan of recorded data in accordance with BS 42020:2013. In line with Natural England’s advice contained within Technical Information Note TIN051, the Survey recommends siting of this particular turbine model (Directwind 54) at least 67m buffer distance between the blades and the nearest linear features in order to mitigate potential collision risks on the local bat population. The proposed turbine position is 83m from the nearest linear feature (bracken bank with mature trees) which is well within this recommended threshold and is a significant factor in mitigating negative effects on ecological receptors. The specific mitigation and enhancement measures laid out in 7.1 include timing of clearance work, particular construction working methods, hedgerow planting and on‐going management of the site and are proportionate to the limited ecological impacts which are predicted. 7
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6.0 MITIGATION PLANTING
Mitigation planting is shown in Genatec Fig 10 of the LVIA Figures Document and referred to in para. 3.70 of the submitted Planning Statement. It includes 1.7km of native hedgerow in the vicinity of the site and a 0.5ha block of woodland north of the site designed as a means of reducing the significant visual effects that will be incurred by close receptors and from further afield. The planting proposals will reinforce former field boundaries and are in accordance with enhancement measures cited in the NNLCA for TF3. Figure 10 also includes the mitigation planting which forms part of the recent solar farm development and this is referred to in para 3.50 of the Planning Statement as providing benefits to this proposal. Constructed in early 2014, the required planting is of an extremely poor standard, has not been fully completed, is not to the required specification and has received no aftercare. With such poor quality planting, the beneficial screening effects will not be realised for a long time. It is unfortunate that the transport assessment necessitates removal of a significant section of hedgerow at the junction of New Road/Rectory Road to facilitate delivery of turbine components to site, as this mature hedge would have provided an amount of screening for the residents of Hill Farm. While this is to be replaced, it will be many years before it forms an effective screen. The mitigation package appears to include a financial sum of £5,000 per annum to the North Norfolk Landscape Enhancement Fund (para 5.6 of the Planning Statement). The Council is not aware of this particular fund, what it aims to achieve and on what basis it would be managed. It is therefore unclear as to the overall benefits of this aspect of the mitigation. Given the vertical scale of the development and the high level topography, the beneficial effects of the proposed planting in screening the turbine and reducing the negative effects on receptors, assets and landscape will, in reality, be limited. To this end, little weight can be applied to these proposed mitigation measures in consideration of the ‘planning balance’. 7.0 ACCESS
The submitted Transport Report by Genatec concludes minimal disruption to road users during the transportation of turbine components to the site. The proposed route includes the requirement for sections of road widening, verge removal, hedge removal and tree pruning/removal. Unlike the previous application, this submission does not include an Arboricultural Implications Assessment to determine the lasting impact of the preparatory route works on the existing vegetation. It can therefore only be assumed that the likely impact will be similar to that as laid out in PF/11/0983. As recommended by the Inspector, a Construction Traffic Management Plan including detailed vegetation reinstatement should be imposed by condition. 8.0 CONCLUSION
The LVIA concludes in 11.12 that the proposed turbine would be ‘compatible with the local landscape and would not result in any unacceptable harm to either the landscape resource or visual receptors’. This demonstrates a lack of appreciation of the significance of the number of heritage assets that are such recognised land mark features of the North Norfolk landscape that would be affected by this proposal, nor does it recognise the value of this largely traditional landscape to both residents of the area or to the numerous holiday makers who come to the area for these very reasons. As already stated, GVLIA3 highlights the importance of heritage features and their setting in the assessment of the value of a 8
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landscape and the significance that should be attributed to ordinary landscapes that do not benefit from designations. With regard to the previous application (PF/11/0983), in s43 of the High Court decision, the judge concurs with the Inspector’s judgement in paras. 61 & 62 of his decision that the harm that would be incurred to the landscape did constitute a breach of Policy EN2 of the Local Development Plan and that this carries weight in striking the planning balance. This assessment demonstrates that, contrary to the conclusions of the submitted LVIA, this latest proposal would also incur harm to the landscape (particularly TF3 and WP5) and the numerous heritage assets and their settings that are intrinsic to those landscapes and to receptors within these landscapes. Conservation Design & Landscape conclude that the reduction in height of the turbine is not proportional to the reduction in the landscape and visual impact. This is demonstrated by comparison of the Zones of Visual Influence submitted in both applications, which show that due to the high level site location, the visual effects are not proportionally reduced. In consideration of all these issues, the proposal is therefore assessed as being contrary to Policy EN2 and to EN8 and on these grounds is recommended for refusal. With regard to Policy EN7: Renewable Energy, it is a matter of careful judgement whether this ‘large scale renewable energy proposal’ can be considered to ‘deliver economic, social, environmental or community benefits that are directly related to the proposed development and are of reasonable scale and kind to the local area’. Benefits in terms of renewable energy potential will need to be considerable in order to outweigh the harm that has been demonstrated. Regards
Cathy Batchelar
Landscape Officer
9
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APPENDIX 3
NORTH NORFOLK DISTRICT COUNCIL
Environmental Health
Memorandum
To:
Geoff Lyon - Planning
From:
Sally Nicholson - Environmental Protection Team
Extension: 01263 516181
Our Ref:
WK/140009836
Date:
05 November 2014
Re: PF/14/0925 - Erection of wind turbine with a hub height of 40m and blade
tip height of 66m with associated substation buildings, access tracks and crane
hard standing
I met with the applicant David Mack and his noise consultant Clive Bentley from Sharps
Redmore on Thursday 21st August.
The report produced in 31st March 2014 found that the proposed wind turbines would
meet the target noise levels.
However we discussed the position with the original noise report produced in January
2011 being based on ETSU-97, and that this report had been revisited using the IOA
guidance. We agreed that a further survey is required following The Good Practice
Guide to the application of ETSU-97 for the assessment and rating of wind turbine
noise produced by the IOA May 2013.
Therefore we agreed that this requirement would be conditioned; a proposed condition
is:
“Prior to construction of the turbine, a supplementary noise assessment shall be
carried out and a report submitted setting out the findings, as applied to the specific
wind turbine to be installed. The assessment shall be made using the methodology
recommended in “The Working Group on Noise from Wind Turbines Final Report
September 1996: ETSU-R-97 The Assessment and Rating of Noise from Wind
Farms” and in accordance with the Institute of Acoustics “A Good Practice Guide to
the Application of ETSU-R-97 for the Assessment and Rating of Wind Turbine
Noise”. The target level for each wind speed derived from this assessment will be
reported and the limit value to be applied will be either this target level or the values
in Table 1 below, whichever is lower. No construction shall take place until the
report and derived target levels have been approved in writing by Local Planning
Authority.”.
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Table 1:
Wind speed at 10m height
(m/s)
Sound level, LA90, dB
3
4
5
6
7
8
9
10
35.
0
35.
0
35.
8
37.
0
37.
8
38.
4
38.
7
38.
7
If the applicant decided to carry out this noise survey before the decision was made
on this planning application then this condition will not be required.
As with the previous application I would like to add the following planning condition:
“In the event that the Local Planning Authority receives a noise complaint which
appears to be of substance, and once the wind turbine operator has been notified of
the complaint in writing by the Local Planning Authority, the wind turbine operator
shall, at its expense, employ a suitably qualified noise consultant approved by the
Local Planning Authority, to undertake an appropriate noise assessment of the noise
emissions from the wind turbine at the complainant’s property following procedures
first agreed by the Local Planning Authority. A report of the assessment shall be
provided in writing to the Local Planning Authority within 60 days of the request
under this condition unless this period is extended by the Local Planning Authority in
writing. If the findings of this report identify that the wind turbine is causing noise
levels considered to be of detriment to the amenity of the nearby residential
properties, a scheme shall be included in the report detailing remedial works
reasonably necessary to address the noise complaint, and these works shall be
implemented in full in accordance with an agreed timescale.”
Any queries please contact me.
Sally Nicholson
Environmental Protection Officer
01263 516181
ep@north-norfolk.gov.uk
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APPENDIX 4
ENGLISH HERITAGE
. ·'
EAST OF ENGLAND OFFICE
Direct Dial: 01223 582710
Direct Fax: 01223 582701
Mr G Lyon
North Norfolk District Council
Planning Service, Council Offices
Holt Road
Cromer
Norfolk
NR27 9EN
Our ref: P00428047
20 August 2014
Dear Mr Lyon
Notifications under Circular 01/2001, Circular 08/2009 &
T&CP (Development Management Procedure) Order 2010
LAND AT POND FARM, NEW ROAD, BODHAM, NORFOLK
Application No PF/14/0925 -erection of wind turbine with a hub height of 40m
and blade tip height of 66m with associated substation buildings, access tracks
and crane hardstanding
Thank you for your letter of 24 July 2014 notifying English Heritage of the above
application.
Summary
· The application proposes the erection of a wind turbine which stands 40 metres to the
hub with a maximum height to the tip of the blades of 66 metres on land at Pond Farm,
Bod ham, Norfolk. Our interest is the potential harm to the setting of a number of highly
designated heritage assets near the proposed turbine where we have provided advice
on the previous application for a turbine at this site. We have considered the current
application in relation to this and the previous application. Despite the reduction in the
height of the proposed turbine, we consider the development would be harmful to the
significance of a number of highly designated heritage assets.
English Heritage Advice
This turbine is reduced in height from previous application, in spite of this, it is clear
from the ZTV (LVIA fig 1) submitted with this current application, that the turbine would
be situated on a prominent location and the hub and blades would be visible from a
considerable distance, and from a number of key locations in this landscape.
Information provided by the applicant includes heritage specific photomontages which
show that this development would have a harmful impact upon the setting and
significance of the schedule~ monument and grade I listed Baconsthorpe Castle and
the grade I listed Barningham Hall and its grade II registered parkland. It would also
2~
BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
•
, www.english-heritage.org.uk
English Heritage is subject to the Freedom.o f Information Act. 2000 (FOIA) and Environmen tal Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
/
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· 'ENGLISH HERITAGE
EAST OF ENGLAND OFFICE
harm the significance of the medieval churches of All Saints' Church, Bod ham, grade
II*, StMary's, Baconsthorp~. grade II*, and St. Mary's Church, Barningham Winter,
grade II*. It would have a negative impact on the wider setting of the more distant
churches at North Barningham and Bressingham, and the Baconsthorpe Conservation
Area.
Baconsthorpe Castle is a grade I, scheduled monument (refer to paragraph 132
National Planning Policy Framework). It is in the Guardianship of English Heritage and
is popular with visitors. It is an extensive and highly valued heritage asset which
includes the remains of an impressive moated manor site, gatehouse and associated
gardens. The character of the landscape in this area is an important consideration and
contributes to the significance of the asset. The landscape is for the most part
unchanged and provides ah important back drop to the site and enhances its historic
and aesthetic values. English Heritage continues to express concerns about the
impact of the turbine on the site. The photomontages show that the turbine would be
visible from a number of locations from within the asset, and it would also be visible in
conjunction with the monument from important locations such as the public footpath to
the south and west of the site. We consider the turbine, in particular the kinetic circular
motion of the blades and the modern form of the blades, would erode the rural
character of this location which contributes to the significance of the Castle. This
would result in harm to the significance of Baconsthorpe Castle.
Barningham Hall is a grade I listeq house set in a registered parkland, grade II. The
most significant phase for t~.e place was the remodelling of the house and park by
Humphry and John Adey Repton. Repton's red book images indicate how the main
southern approach to the building was adapted to specifically reveal the imposing
house. The images submitted with the planning application are unhelpful in that they
do not replicate the view in .ttie Repton red book painting, but they do give an
impression of the likely impqct of the turbine on the house and park. In our view, the
turbine would be visible in th~ important approaches to the house from the south, but
also within the avenue and in a number of key views from and to the north west of the
Hall.
·
The partially ruined grade li * church of St Mary, Barningham Winter is also an integral
structure within the park. This medieval church formed part of the Reptons' adaption of
the park and it was incorporated into the designed landscape as an eye catcher. The
proposed turbine would also be visible from within the ruined church, critically, in views
to the north that include the church. The reduced height of the turbine means it would
not be as dominant at this location as earlier proposals but we consider that the motion
of the turbine blades would erode the significance and rural character of the park and
would result in harm to the wider setting of the Hall and church.
-
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
'
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org. uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
115
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E N GLISH HER I TAGE
EAST OF ENGLAND OFFICE
In addition to the Castle and the· Hall, the landscape is notable for the number of
important medieval churches and ~mall historic rural settlements. We are concerned
about the impact upon the setting of a number of highly graded medieval parish
churches such as those at Bod ham and Baconsthorpe. The impact of the development
on the parish churches in the landscape should be considered from both close and
distant viewpoints. The images provided by the applicant do not allow a full
appreciation of the turbine's visual impact on the significance of these churches but do
give an indication of the likely scale of the turbine in relation to the churches and show
that the turbine would be visible from both Bod ham and Baconsthorpe churches and
churchyards. There would be a harmful impact on the rural setting of these churches
and their significance. It would also have a negative impact on the wider setting of the
more distant churches at North Barningham and Bressingham, and Baconsthorpe
Conservation Area.
The Planning (Listed Buildings and Conservation Areas) Act 1990 provides that in
considering whether to grant planning permission for development which affects a
listed building or its setting the local planning authorities shall have special regard to
the desirability of preservin'g the building or its setting (section 66(1) of the 1990 Act).
Special attention should also be paid to the desirability of preserving or enhancing the
character or appearance of a conservation area in the exercise of any powers under
the planning Acts (paragraph 72 of the 1990 Act). This duty under section 66(1) of the
1990 Act was recently considered in the a number of cases, in particular the decision
of the Court of Appea l in the East Northamptonshire, English Heritage and the
National Trust v SoS for Communities and Local Government and Barnwell Manor
Energy Ltd (2014) and the decision of the High Court in the recent judicial review for
the previous turbine application at Bodham in relation to this case (North Norfolk
District Council v SoS for Communities and Local Government and David Mack
(2014).
The National Planning Policy Framework (NPPF) identifies protection and
enhancement of the historic en\(ironment as an important element of sustainable
development and establishe~ a presumption in favour of sustainable development in
the planning system. Within the NPPF the conservation of heritage assets is
considered as a core principle. 'It states that, in order to achieve sustainable
development, economic, social and environmental gains should be sought jointly and
simultaneously through .th~ planning system (paragraph 8).
The NPPF also provides th?t the significance of a heritage asset can be harmed or
lost by development within its setting, and requires the local planning authorities to
give 'great weight' to the conservation of designated heritage assets and the more
important the asset, the greater the weight should be (paragraph 132). This paragraph
also notes that as heritage assets are irreplaceable, any harm to significance requires
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Informa tion Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR) .
All informa tion held by the organisation
be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
, ,
will
116
a
ENGLISH HERITAGE
EAST OF ENGLAND OFFICE
'clear and convincing' justification. Paragraph 134 of the NPPF says where a
development proposal will lead to less that substantial harm to the significance of a
designated heritage as'set, this ~arm should be weighed against the public benefits of
the proposal.
,.
Furthermore, paragraph 137 provides that local planning authorities should look for
opportunities for new development within the setting of heritage assets to enhance or
better reveal their significance. Proposals that preserve those elements of the setting
that make a positive contribution to, or better reveal the significance of the heritage
assets should be treated favourably.
Recommendation
We have considered the current proposals in light of the legislation, government policy
and English Heritage guidance. We have concluded that the erection of a single wind
turbine in the vicinity of the grade I listed and scheduled site of Baconsthorpe Castle,
the grade I Barningham Hall, and grade II registered park and the church at
Barningham Winter, the churches at Bodham and Baconsthorpe would result in harm
to the significance of these 'a~s~ts through inappropriate development to their setting.
It would also have a negative impact on the wider setting of the more distant churches
at North Barningham and Bressingham, and Baconsthorpe Conservation Area. We
conclude that the development would be harmful to designated heritage assets in
terms of paragraphs 132 and 134 of the NPPF and does not satisfy the public benefit
test in paragraph 134. The;NPPF requires local planning authorities to weigh any
public benefit deriving from renewable energy generation against harm to the historic
environment. Unless your authority is satisfied that there is a clear and convincing
justification for the harm and that' this is outweighed by the public benefits of the
development, we recommend that the Council should refuse the application.
Yours sincerely
~~
I
Will Fletcher
Inspector of Ancient Monuments ·
e-mail: will.fletcher@english-heritage.org.uk
.
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 SBU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org. uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOJA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
117
APPENDIX 5
Miss Rachel Evans
Assistant Safeguarding Officer
Ministry of Defence
Safeguarding – Wind Energy
Kingston Road
Sutton Coldfield
West Midlands B75 7RL
United Kingdom
Your Reference: PF/14/0925
Our Reference: DIO/SUT/43/10/1/7694
Telephone [MOD]: +44 (0)121 311 2195
Facsimile [MOD]:
+44 (0)121 311 2218
E-mail:
DIOODC-IPSSG3a@mod.uk
Mr G Lyon
North Norfolk District Council
Council Offices
Holt Road
Cromer
Norfolk
NR27 9EN
11 August 2014
Dear Mr Lyon
Please quote in any correspondence: 7694
Site Name: Land at Pond Farm
Proposal: Erection of 1 Wind Turbine
Planning Application Number: PF/14/0925
Site Address: New Road, Bodham
Thank you for consulting the Ministry of Defence (MOD) on the above Planning Application in your communication
dated 24 July 2014.
I am writing to tell you that the MOD has no objection to the proposal.
The application is for 1 turbine at 67 metres to blade tip. This has been assessed using the grid references below
as submitted in the planning application or in the developers’ or your pro-forma.
Turbine
100km Square letter
Easting
Northing
1
TG
13970
38220
In the interests of air safety the MOD will request that the development should be fitted with aviation safety
lighting. All turbines be fitted with 25 candela omni-directional red lighting or infrared lighting with an optimised
flash pattern of 60 flashes per minute of 200ms to 500ms duration at the highest practicable point.
The principal safeguarding concern of the MOD with respect to the development of wind turbines relates to their
potential to create a physical obstruction to air traffic movements and cause interference to Air Traffic Control and
Air Defence radar installations.
118
Defence Infrastructure Organisation Safeguarding wishes to be consulted and notified of the progression of
planning applications and submissions relating to this proposal to verify that it will not adversely affect defence
interests.
If planning permission is granted we would like to be advised of the following;
•
•
•
the date construction starts and ends;
the maximum height of construction equipment;
the latitude and longitude of every turbine.
This information is vital as it will be plotted on flying charts to make sure that military aircraft avoid this area.
If the application is altered in any way we must be consulted again as even the slightest change could
unacceptably affect us.
I hope this adequately explains our position on the matter. If you require further information or would like to
discuss this matter further please do not hesitate to contact me.
Further information about the effects of wind turbines on MOD interests can be obtained from the following
websites:
MOD: https://www.gov.uk/mod-safeguarding
Yours sincerely
Miss Rachel Evans
Assistant Safeguarding Officer – Wind Energy
Defence Infrastructure Organisation
SAFEGUARDING SOLUTIONS TO DEFENCE NEEDS
119
120
APPENDIX 6
Geoff Lyon
From:
Sent:
To:
Cc:
Subject:
Hamilton, Ken <kenneth.hamilton@norfolk.gov.uk>
19 August 2014 14:58
Geoff Lyon
Will Fletcher (Will.Fletcher@english-heritage.org.uk); Cathy Batchelar; Dack, Zara
PF/14/0925 Land at Pond Farm, New Road, Bodham
Dear Geoff,
The application as submitted included a heritage impact assessment (HIA) by Grover Lewis
Associates, which sets out their opinion on the impact of this development on the historic
environment. The Historic Environment Service consider that the degree of harm to the historic
environment has been considerably played down in this document, particularly with reference to
the impact on Baconsthorpe Castle. As you know, Baconsthorpe Castle is a scheduled
monument. The NPPF states that applications which harm the significance of scheduled
monuments should be wholly exceptional, and that the harm done should be weighed against the
benefits of the proposal (para. 132, 134).
The HIA does not discuss the significance of the earthworks of the formal garden, other than to
state that they are scheduled along with the castle. In fact, as well as their association to the
castle, the formal gardens are significant in their own right. Although they are undated, they are
likely to predate the 1650 partial demolition of the castle, and are hence a well preserved example
of (probably) 17th century formal gardens unaffected by later redesign and planting. The best view
of these gardens is from the west, from both the car park and the path between the two
gatehouse. The HIA states that “the proposed wind turbine would not feature strongly, with only
the upper part of the turbine blade would be visible [sic]”. In fact, viewpoint HVP1 shows almost
one half of the entire blade sweep as visible above the trees, distracting from the main view of one
of the subtler, yet no less significant, aspects of the scheduled monument. The effect would be to
emphasise the post-Industrial farmland character of the setting of the formal gardens over the
subtler earthworks, thereby detracting from their significance as formal gardens.
Contrary to the HIA, the turbine would be very clear when approaching the castle from the north
west (see, for example, HVP3), where the introduction of a large, modern, moving element will
alter the setting considerably. In fact, the position of the turbine is such that the north wall of the
castle will lead the eye towards the turbine, distracting it from the designated heritage asset (HVP
3 and 8), and offering considerably more than the “glimpses” suggested by the HIA. The HIA
states that in every case the turbine would be smaller than the telecommunications mast – this is
true. However, the turbine would be moving, rather than static, and hence the eye would be drawn
to it. It could be argued that in this location, the presence of the turbine would also draw attention
to the telecommunications mast, thereby enhancing the feel of a modern industrialisation of what
is currently a very rural setting.
Hence the claim that the turbine would have “some minor visual impact” on the setting of the
monument considerably plays down the impact that this proposed development will have. The
playing down of the impact, together with the lack of appreciation of the effect of movement on the
human eye lad the HIA to greatly underestimate the harm done to the significance of this
designated heritage asset.
As with Baconsthorpe Castle, the HIA underplays the impact of the turbine on All Saints’ Church,
Bodham, particularly with respect to the view from the churchyard. While it is true that visitors to
the church would have the turbine at their back as they approach the church, the turbine will
become a prominent feature in the view from the south door of the church. Whilst the degree of
1
121
harm to the significance of the heritage asset is not substantial, it is nonetheless greater than
stated in the HIA.
The HIA discusses the significance of Barningham Hall and Park, making reference to a number
of watercolours by Humphry Repton. One of Repton’s trademarks was the creation of designed
views that opened up suddenly (so called “bursts”), and he published on the necessity of
designing the entrance to a house and garden to show it at its best advantage (see, for example,
Repton (1803) Observations on the Theory and Practice of Landscape Gardening, chapter XI) It is
strange, then, that there is no viewpoint for the first moment that one sees the Hall, and no
discussion of this view in the HIA. It is the view depicted in one of the watercolours mentioned in
the HIA. It is therefore impossible to confirm the assertion in 3.41 of the HIA that the view
illustrated by Repton would be unaffected by the turbine. Certainly the turbine would be visible in
that view, and hence there would be a degree of harm to the significance of the heritage asset,
not only through alteration to its setting, but also to its artistic significance.
Barningham Winter church, particularly, was one of Repton’s subjects, as it features in his
illustrations. It is fairly clear that the view from the north door is a designed view, with the
demolition of the nave, but retention of the south porch leading the viewer into a “burst” at the
north door. Whilst this view has, to a degree, been compromised by static modern telegraph
poles, it retains its artistic significance as a vista of a rural scene. As can be seen form HVP18, in
fact the turbine hub would be visible above the trees, and so more than half of the blade sweep
area would be visible, and would introduce a rotating modern industrial element to an otherwise
static rural scene. As with the other assets listed above, there is therefore harm to the significance
of a designated heritage asset, and that harm is underplayed by the HIA.
The HIA fails to address the impact of the proposed development on undesignated heritage
assets, including the below-ground impact of turbine construction, and there is no evidence that
the authors of the HIA have consulted the Norfolk Historic Environment Record (contra para.128
of the NPPF). The applicant has included the results of a magnetometer survey, which identifies a
number of archaeological features likely to be impacted upon by this development. However,
these are unlikely to be of national importance, and the mitigation of the impact of development on
them could be secured via a set of conditions, should permission be granted. I have appended a
suitable set of conditions to this email.
In summary, therefore, while we do not object outright to this proposal, there is harm to the historic
environment (considerably greater harm than is detailed in the heritage assessment), and the
Planning Committee must judge whether the benefits of this proposal outweigh that harm, in
accordance with paragraphs 132 and 134 of the NPPF.
Yours aye
Ken
If planning permission is granted, we request that it be subject to the following conditions, in
accordance with Paragraph 141 of the NPPF:
A) No demolition/development shall take place/commence until a Written Scheme of Investigation
has been submitted to and approved by the local planning authority in writing. The scheme shall
include an assessment of significance and research questions; and
1. The programme and methodology of site investigation and recording
2. The programme for post investigation assessment
3. Provision to be made for analysis of the site investigation and recording
2
122
4. Provision to be made for publication and dissemination of the analysis and records of the site
investigation
5. Provision to be made for archive deposition of the analysis and records of the site investigation
6. Nomination of a competent person or persons/organization to undertake the works set out
within the Written Scheme of Investigation
B) No demolition/development shall take place other than in accordance with the Written Scheme
of Investigation approved under condition (A).
C) The development shall not be occupied until the site investigation and post investigation
assessment has been completed in accordance with the programme set out in the Written
Scheme of Investigation approved under condition (A) and the provision to be made for analysis,
publication and dissemination of results and archive deposition has been secured.
The Historic Environment Service will provide a brief for these works on request.
________________________________
Ken Hamilton PhD FSA MIfA
Senior Historic Environment Officer (Planning)
Historic Environment Service
Environment, Transport and Development
Norfolk County Council
Direct dial telephone number: 01362 869275
Mobile telephone number:
07748 761354
E-mail: ken.hamilton@norfolk.gov.uk
General enquiries: 0344 800 8020 or information@norfolk.gov.uk
www.norfolk.gov.uk
-To see our email disclaimer click here http://www.norfolk.gov.uk/emaildisclaimer
3
123
APPENDIX 7
Date:
05 August 2014
Our ref: 128003
Your ref: PF/14/0925
Mr G Lyon
North Norfolk District Council
Holt Road
Cromer
Norfolk
NR27 9EN
Sustainable Development
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
BY EMAIL ONLY
T 0300 060 3900
Dear Mr Lyon
Planning consultation: Erection of wind turbine with a hub height of 40m and blade tip height of
66m with associated substation buildings, access tracks and crane hardstanding
Location: Land at Pond Farm, New Road, Bodham
Thank you for your consultation on the above dated 31 July 2014 .
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
The Wildlife and Countryside Act 1981 (as amended)
The Conservation of Habitats and Species Regulations 2010 (as amended)
Natural England’s comments in relation to this application are provided in the following sections.
Statutory nature conservation sites – no objection
Based upon the information provided, Natural England advises the Council that the proposal is
unlikely to affect any statutorily protected sites or landscapes.
Protected species
We have not assessed this application and associated documents for impacts on protected species.
Natural England has published Standing Advice on protected species. The Standing Advice
includes a habitat decision tree which provides advice to planners on deciding if there is a
‘reasonable likelihood’ of protected species being present. It also provides detailed advice on the
protected species most often affected by development, including flow charts for individual species to
enable an assessment to be made of a protected species survey and mitigation strategy.
You should apply our Standing Advice to this application as it is a material consideration in the
determination of applications in the same way as any individual response received from Natural
England following consultation.
The Standing Advice should not be treated as giving any indication or providing any assurance in
respect of European Protected Species (EPS) that the proposed development is unlikely to affect
Page
1 of 2
124
the EPS present on the site; nor should it be interpreted as meaning that Natural England has
reached any views as to whether a licence is needed (which is the developer’s responsibility) or
may be granted.
If you have any specific questions on aspects that are not covered by our Standing Advice for
European Protected Species or have difficulty in applying it to this application please contact us with
details at consultations@naturalengland.org.uk.
Local sites
If the proposal site is on or adjacent to a local site, e.g. Local Wildlife Site, Regionally Important
Geological/Geomorphological Site (RIGS) or Local Nature Reserve (LNR) the authority should
ensure it has sufficient information to fully understand the impact of the proposal on the local site
before it determines the application.
Impact Risk Zones for Sites of Special Scientific Interest
Natural England has recently published a set of mapped Impact Risk Zones (IRZs) for Sites of
Special Scientific Interest (SSSIs). This helpful GIS tool can be used by LPAs and developers to
consider whether a proposed development is likely to affect a SSSI and determine whether they will
need to consult Natural England to seek advice on the nature of any potential SSSI impacts and
how they might be avoided or mitigated. Further information and guidance on how to access and
use the IRZs is available on the Natural England website.
We would be happy to comment further should the need arise but if in the meantime you have any
queries please do not hesitate to contact us.
For any queries regarding this letter, for new consultations, or to provide further information on this
consultation please send your correspondences to consultations@naturalengland.org.uk.
We really value your feedback to help us improve the service we offer. We have attached a
feedback form to this letter and welcome any comments you might have about our service.
Yours sincerely
Aileen Finlayson
Sustainable Development Consultation Team
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125
APPENDIX 8
N Baker
Head of Planning and Building Control
North Norfolk District Council
Holt Road
Cromer
Norfolk
NR27 9EN
Norfolk Coast Partnership
South Wing
Fakenham Fire Station
Norwich Road
FAKENHAM
Norfolk NR21 8BB
Tel: 01328 850530
email: aonb@norfolk.gov.uk
www.norfolkcoastaonb.org.uk
5 August 2014
Dear Mrs Baker,
Application ref PF/14/0925: Erection of a wind-turbine of 40m hub height and 66m tip height
and associated infrastructure at Pond Farm, Bodham NR25 6PP
Summary response
We do not raise an objection to this application.
Full response
Thank you for providing us with the opportunity to take part in the consultation on this planning
application.
My comments relate only to the potential effects of the development on the landscape quality of the
Norfolk Coast Area of Outstanding Natural Beauty (AONB) and on the views from the AONB. I have
not commented on the local viewpoints closer to the proposed site of the turbine and/or the impact
on the landscape outside of the AONB boundary. I have not assessed any impacts on the wildlife of
the area and suggest that Natural England should comment on this aspect.
In general, the NCP is in favour of renewable energy and, within our current Action Plan, we have an
action 'C3.2.b. Promote use of renewable energy technologies that do not affect the area's natural
beauty.'
However, renewable energy schemes, and particularly wind power schemes, can have a highly
significant impact on the natural beauty of the landscape and so we approach each project on an
individual basis.
We note that experience has shown that visibility of wind turbines is highly dependant on weather
and light conditions and that in some cases, despite use of best practice assessment guidance, the
actual turbines may appear clearer and larger than photomontages indicate.
This application is a revision of an earlier application, PF/11/0983: Erection of a wind-turbine of 60m
hub height and 86.5m tip height and associated infrastructure at Pond Farm, Bodham NR25 6PP.
Having assessed the new application, our comments are similar to those made on PF/11/0983.
This proposed wind turbine sits to the south of the AONB and we recognise that it will be screened
from many coastal areas of the AONB by the rise of the Cromer ridge. It appears that the current
The Partnership is funded by Natural England, Norfolk County Council, North Norfolk District Council,
Borough Council of King’s Lynn & West Norfolk and Great Yarmouth Borough Council
126
Norfolk Coast Partnership
Page 2
proposal, being 40m hub height and 66m tip height, will have less visibility from across the AONB
than the original proposal of 60m hub height and 86.5m tip height.
There appears to be little, if any, cumulative effect from other wind turbine developments or
proposals (the majority of which are for off-shore schemes to the north and east of the AONB
boundary) but there is a cumulative impact from the two adjacent telecommunications masts and, to
a lesser extent taking into account the distance, the local electricity lines and poles. We note that,
since the first application, solar arrays have been constructed in the area but, with low height at a
distance to the AONB boundary, we do not consider that these have a significant visual impact on
the AONB.
However, though this cumulative effect does not appear to be significant at the moment, any further
additions, for example addition of another wind turbine in the area, would raise concerns and require
a new assessment.
Based on current information and site visits, the NCP does not raise an objection to the planning
application for this project.
I would appreciate if you would continue to involve the Norfolk Coast Partnership in any future
consultations of relevance to the landscape of the AONB.
Yours faithfully,
Estelle Hook
Policy and Partnership Officer
127