Borough of Poole - Response to Statutory Consultation - Preliminary Environmental Information (PEI3)
This report follows the structure of the non technical summary document which considers offshore and onshore impacts.
Overall the PEI3 concluded that there were no significant impacts on any element identified in the scoping report, subject
to mitigation.
Feedback to Navitus Bay Development team comprises:

Appendix A: A Review of PE13 to consider the adequacy of mitigation and the draft Socio Economic and Tourism
chapter of the EIA.

Appendix B: An Independent ‘IEMA’ review of the PEI3.
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Appendix A: Review of the PEI3 – Adequacy of Mitigation
Affected
Offshore and
Onshore
Elements
Physical
Processes
Offshore Water
Quality
Phase
Potential
identified risk
to receptor and
outcome
Proposed Mitigation Measures
Comments
Construction,
Operational and
decommissioning
Coastal
features, wave
or tidal
movements
N/A
Physical Processes – this refers to
modelling that has been
undertaken and this should have
included wind, wave and sediment
transport modelling. Request to
NBDL see results to compare with
similar reports held by Coastal
Works Manager Borough of Poole.
There is a drafting error in the
numbering of tables (two tables are
numbered 5.5 (pages 16 & 37) and
there is no Table 5.12.
Construction
Spillages of
contaminants
resulting in
increased water
turbidity levels
Adoption of embedded
mitigation and Implementation of
suitable controls including
Environmental Management
Plan, Pollution Control and
Spillage Response Plan.
Adequate for negligible impact on
water quality.
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Affected
Offshore and
Onshore
Elements
Offshore Air
Quality
In-Air Noise
e.g. Percussive
techniques
associated with
piling
Phase
Potential
identified risk
to receptor and
outcome
Proposed Mitigation Measures
Comments
Construction and
operation
None Modelling shows
there would be
no noticeable
increase in air
pollution at any
phase.
N/A
N/A
Works to be undertaken within
fixed noise limits. Assumptions
are made that the 50dB
threshold imposed during
construction and 35dB during
operation will not be exceeded.
Adequate.
None, as report
states that it was
screened out of
EIA process in
Construction,
consultation with
Operation and
LPA EHOs. Best
Decommissioning
practice
guidance to be
applied during
all phases.
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Affected
Offshore and
Onshore
Elements
Benthic Ecology
Fish and shellfish
ecology
Marine mammals
and megafauna –
e.g. basking
sharks, bottlenose
dolphins
Phase
Construction and
Operation
Construction,
Operation and
Decommissioning
Construction,
Operation and
Decommissioning
Potential
identified risk
to receptor and
outcome
Proposed Mitigation Measures
Comments
Adverse effects
from spillages of
contaminants
harming seabed
sediment
habitats
Adoption and Implementation of
suitable controls including
Environmental Management
Plan, Pollution Control and
Spillage Response Plan.
Adequate.
Noise and
disturbance to
commercially
and ecologically
important
species and
their habitat
Standard Mitigation is proposed
e.g. soft start procedures and
ongoing consultation with
Natural England.
Adequate.
Auditory injury
from piling
noise.
Standard Mitigation is proposed
e.g. soft start procedures and
ongoing consultation with
Natural England.
Satisfactory at this stage.
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Affected
Offshore and
Onshore
Elements
Offshore
Ornithology
Phase
Operation
Potential
identified risk
to receptor and
outcome
Proposed Mitigation Measures
Comments
Impact on key
and migrant
seabirds and
migratory
species
Mitigation would have to
address likelihood of harm to
seabirds from collision with
turbine blades, particularly
gannets.
Ongoing discussion with Natural
England.
What evidence is there to show
that there is no equal risk to other
seabirds?
Seascape Landscape and Visual Impacts
The Seascape, Landscape and Visual Impacts have been assessed separately using methodology derived from best practice
guidance, Visual Representation of Windfarms (2006), a Scottish Natural Heritage commissioned report. The use of visual
representations in the form of photomontage images forms part of the wider landscape and visual impact assessment within an
Environmental Impact Assessment. The industry standard 50mm lens used in the visualisation images could be misleading and
according to industry expert Alan Macdonald’s book, “Windfarm Visualisation” the use of the 50mm may not represent a realistic
prediction of their impact. This issue has been raised with NBDL particularly since evidence gathered for the University of Sterling
report has led to new visualisation standards being adopted by the Highlands Authority. A revised consultation document released
on 23rd May 2013 until 19th July 2013 suggested a number of key changes to the way visualisations are produced. It
recommended images are presented at a focal length of 75mm and increase the size of images presented to 260mm in height. To
remove viewing limitations e.g. needing to view from an exact distance or reducing the need to view curved images. The
photomontage images produced for the public consultation have not addressed the provisions of the draft guidance. Navitus have
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not recognised the public concern that was being expressed in relation to the visual impact.
The developer has assessed thirty five representative coastline viewpoints from a broad geographical study area. These were
developed in consultation with stakeholders and statutory consultees, including the Borough of Poole. The viewpoints were then
assessed in terms of their sensitivity to receptor (i.e. category of person – local resident, visitors) and how, depending on how
often they made use of the site, they would perceive the wind turbines on the horizon. Representative visualisations of an 8MW
wind turbine layout from these viewpoints out to sea were produced. In addition, a number of viewpoints were assessed for their
impact from a 5MW turbine layout, including night-time views, one of which includes the view from Sandbanks beach.
Photomontage images and Wireframes for viewpoints in Poole are shown from Sandbanks Ferry Port (No. 14), Sandbanks Beach
(No. 15) Sea View Constitution Hill (No. 16) and Branksome Dean Chine Community (No. 17). Should the 8MW scheme be built,
visitors to these areas will be able to see a cluster of turbines, approx. 12 miles out to sea. The photomontage representations
provided, as taken through a 50mm lens, do not enable visitors to determine the number of turbines (136 for an 8MW scheme) but
they will be visible to the naked eye. Therefore, the PEI3 has predicted that there will be a major-moderate impact on the principal
receptors (i.e. local residents (principal receptors) at Branksome Dene Chine and temporarily on ferry passengers crossing on the
Poole to Cherbourg ferry. The SLVIA also highlights the significant impacts on local residents at Sandbanks beach. Major
moderate to moderate impacts are predicted to be experienced by residents in coastal settlements, visitors to beaches, cyclists
who are in areas up to 9 miles from the wind park. No viewpoints in the SLVIA from Poole will be closer than 12 miles distance
from the proposal. Navitus Bay contend that whilst the project will not change the intrinsic character of the Jurassic Coast,
Dorset’s AONB or the Dorset Heritage Coast, even through strategic views towards these designations and the wind park, have
been assessed as presenting as a major-moderate level of visual harm and would not trigger the need for mitigation.
The SLVIA concludes that while some residents may experience temporary effects during the construction and decommissioning
stages, overall there will be no significant adverse impacts.
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Affected Offshore
and Onshore
Elements
Offshore
archaeology
The setting of
heritage assets
Phase
Potential
identified risk
to receptor and
outcome
Proposed
Mitigation
Measures
Strategy for
Potential for
mitigating
damage to
impact on
fluvial sediments
archaeological
from the last
Construction and
features
glacial period
Decommissioning
including the
(more than
use of exclusion
12,000 years
zones around
ago) and
archaeologically
maritime/aviation
important
archaeology.
features.
Operation
Visual harm to
the appearance
of the Jurassic
Coast.
Ongoing
consultation
with Natural
England.
Comments
Adequate.
Adequate.
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Affected Offshore
and Onshore
Elements
Shipping and
Navigation
Commercial
Fisheries
Phase
Construction,
Operation and
Decommissioning
Construction,
Operation and
Decommissioning
Potential
identified risk
to receptor and
outcome
Proposed
Mitigation
Measures
Comments
Navigational
hazards to
seagoing craft
including
recreational,
commercial,
military and
emergency
response
activities
Hazards within
tolerable level
of risk subject
to monitoring.
Discussions
and
assessments
are ongoing
with
stakeholders
Adequate.
Safety buffers
around the
turbines and
cabling will
result in loss of
access
Discussion and
appropriate
mitigation
developed with
fishermen and
other
consultees
through the
fisheries liaison
programme.
Adequate.
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Affected Offshore
and Onshore
Elements
Aviation and Military
Activity
Other offshore
infrastructure
Phase
Construction,
Operation and
Decommissioning
Construction
Construction and
Telecommunications
decommissioning
and Broadcasting
phases
Potential
identified risk
to receptor and
outcome
Proposed
Mitigation
Measures
Comments
Turbine Area
visible to civil
radar equipment
at Bournemouth
Airport, creating
“clutter” on the
displays.
Discussions
ongoing with
Airport operator
to identify
appropriate
mitigation
measures to
remove impact.
Adequate.
Piling and other
noise
disturbance to
interfere with
survey
equipment.
Designated
navigational
channels,
information and
commercial
agreements
with
stakeholders
Appropriate.
Interference to
TV reception
Satellite TV
offered to
properties
affected.
No comment.
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Affected Offshore
and Onshore
Elements
Offshore Socioeconomic and
Tourism
Offshore Recreation
Phase
Potential
identified risk
to receptor and
outcome
Construction,
operation and
decommissioning
No adverse
effects. Minor
beneficial impact
with regard to
local supply
chain and
tourism. Job
creation, skills
and training
opportunities.
Construction and
operation
Proposed
Mitigation
Measures
Comments
The Council would wish to maximise opportunities
for local businesses to bid for contracts, assess
local training needs and create employment.
Involvement with the strategy for procurement
would be essential for the Council to ensure these
opportunities are realised. We note the
developers’ commitment to funding appropriate
infrastructure to allow local authorities to deliver
measures to enhance and promote tourism.
Turbine area is used as one of the locations for
deep water diving. Poole Harbour is a popular
embarkation point. Explore the impact on diving
clubs by engaging further with them on the
construction and operational phases of the
project.
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Affected Offshore
and Onshore
Elements
Climatic Factors
Phase
Construction,
operation and
decommissiong
Potential
identified risk
to receptor and
outcome
Not yet
determined
Proposed
Mitigation
Measures
Comments
Not yet
determined
A consideration of the effects of the proposals on
both negative and positive impacts on climate
should be undertaken for the final EIA in
accordance with the provisions of the EIA
regulation.
(See over for comments on draft Socio-Economic and Tourism impacts).
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Socio Economic and Tourism Impacts
The assessment considered the potential impact of the off and onshore components of the Project on the local supply chain and
local tourism industry, specifically in relation to the tourism economy and individual businesses.
The draft Socio Economic and Tourism chapter of the EIA
The chapter is in two parts. Part A sets out the scope of the assessment, the methodology and consultation approach, the potential
Impacts and potential mitigation from a socio economic perspective, here: Part B is the technical report on the visitor survey
Findings in the summer season (2012) here.
The Council have been asked to comment on the draft chapter by 11th October 2013.
An assessment was undertaken of the primary research which underpins the evidence and informs the findings of the likely impact
of the wind park on local tourism. The research has been conducted by suitably accredited persons under appropriate quality
assurance criteria. This guarantees that the research has been carried out to the highest standards and that the evidence gathered
is appropriate.
The review considered selection bias and found that appropriate methods were employed to reduce this. Confidence levels for the
sample size, were sufficient and would produce reliable results when combining findings from both the spring and summer surveys.
While there may be fewer tourists in spring and the distribution of respondents varied depending on the season, if comparability
was important, field work could have been extended to increase the sample size for any future study.
Where potential adverse impacts on tourism are identified, mitigation measures should be set out in the final ES and informed by a
strategy for delivering public realm improvements, a visitor centre and to facilitate other environmental enhancements that would
promote tourism without harming the natural environment.
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