8 DEVELOPMENT CONTROL COMMITTEE – 21 OCTOBER 2009 APPLICATION NO DC/09/0491/FUL LOCATION Land At Former Airfield Upper Holton Holton Halesworth Suffolk EXPIRY DATE 17 September 2009 APPLICATION TYPE Full Application APPLICANT Bernard Matthews Green Energy (Halesworth) Ltd PARISH Holton PROPOSAL Installation of 5 wind turbines, with a maximum height to tip of 100m, a permanent meteorological mast, substation, access and tracks and associated infrastructure DO NOT SCALE Reproduced from the Ordnance Survey mapping with the permission of the Controller of Her Majesty’s Stationery Office © Crown Copyright. Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings. SUMMARY This application seeks consent for 5 wind turbine generators on land at the former airfield in Holton. A comprehensive Environmental Impact Assessment accompanies the application. The main issues raised by the proposal concern Government and regional targets for renewable energy generation, the visual effects of the proposal on the surrounding landscape, the impact on residential properties in the locality, including noise and shadow effects, the impact on wildlife and ecology and the traffic and highway implications. 25 SITE DESCRIPTION The site covers an area of approximately 2.81 hectares and is located on the former World War II airfield some 2km north of Holton and 1km east of the A144. A number of turkey sheds, currently vacant, are housed on the old concrete runways and an established food processing factory is located to the south, on part of the former airfield. Land between the runways is farmed on an arable basis. A public right of way, consisting of a bridleway and a public footpath runs along part of the southern boundary and along the eastern boundary of the site, between the proposed development and Scalesbrook Wood. As might be expected given its former use the site is flat and featureless apart from the existing turkey sheds. It is however surrounded by largely undeveloped gently undulating farmland interspersed with a scattering of isolated farmhouses, rural roads and hedgerows and small woodlands. The site and surrounding landscape falls within two landscape character types, namely Plateau Claylands and Ancient Estate Claylands – Suffolk Landscape Character Typology – 2008. The site does not form part of any local or national landscape designation. The nearest landscape designations are the Broads National Park (9.4km) and the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (3.2km). The Special Landscape Area is a local designation which lies some 2.3km of the nearest proposed turbine. PROPOSAL This planning application is for a wind farm consisting of 5 wind turbine generators, a metrological mast, substation access tracks and hardstanding areas, underground power and telecommunications cabling, and temporary construction/decommissioning compound. The proposed operational lifetime of the project is 25 years. Each of the proposed wind turbines would have a rated capacity of up to 2.3MW and the site would meet the equivalent average annual electricity needs of over 5140 homes. The turbines would all be located on arable land between the former runways within the central to eastern part of the site. Each has a height to the hub of 64.5m and a rotor diameter of 71m, giving an overall blade tip height of 100m. It is proposed to finish the turbines in a semi matt grey colour. The metrological mast is a galvanised steel lattice structure with an height of 65m. It would be located just south of the central part of the site, adjacent to the former east-west runway. The proposed 11kV substation is a single storey freestanding building measuring 5.6m x 4.6m and 3.5m high and located adjacent to the site entrance. Access to the site would be gained via the existing access off Butt`s Road although some minor modifications to it would be necessary to facilitate the delivery of components. Where possible it is proposed to utilise existing tracks/runways within the site. New tracks will be required up to each wind turbine and hardstandings at the bases. Other works include cabling trenches and a temporary construction/decommissioning compound on former runway located centrally within the site. An Environmental Statement accompanies the application in accordance with the Town and Country Planning (EIA) Regulations 1999. An amendment to the position of turbine 4 move it 15m further away from the bridleway. CONSULTATIONS/COMMENTS Neighbour consultation/representations 166 residential properties in the locality and surrounding area were notified. 99 responses received objecting for the following reasons: - Unsightly and an eyesore - Detrimental to outlook from residential property - Unduly prominent/visual impact – will spoil the character of the countryside - Generation of renewable energy does not outweigh the visual impact on the countryside - Support principle but should be smaller/lower - Inefficiency of wind turbines as an energy source 26 - Harmful to wildlife/biodiversity, especially birds Noise pollution, especially at quiet times eg night Inappropriate scale dominates the surroundings Could set a precedent for further wind turbines and industrial development Detrimental effect on tourism Harmful to health due to noise, shadow flicker, vibrations Proximity to public footpath/bridleway Wind turbines are more appropriately located off-shore Danger to low flying aircraft Will affect TV and mobile phone reception 6 responses support the proposal: - Great green idea - Replacement of some fossil-fuel based energy - Would make a magnificent statement on a rather featureless ex-airfield - The need to produce re-newable energy is urgent Westhall Wind Watch Westhall Wind Watch raise a number of issues with the proposal as follows: - Viability of the site as a wind resource due to a lack of relevant data - Landscape impact due to the written evidence being considerably underestimated, does not match with the evidence in figures and photomontages and requires complete reassessment. - Rights of Way due to the close proximity to the adjacent bridleway which must be seen as an obstruction. Anything that impedes the existing legal access is an obstruction. Our understanding of `impedes’ covers anything that might render the use of the highway unsafe for the user. - Turbine separation distances. A separation distance of 4 times the overall height should be the target for National Trails and Ride UK routes, as these are likely to be used by equestrians unfamiliar with turbines, and a distance of 3 times the overall height from all other routes, including roads with the 200m recommended in the Technical Guidance to PPS22 being seen as the minimum, where it is shown in a particular case that this would be acceptable. Horses may be frightened by moving blade shadow and may be disturbed by the presence of moving blades. - Noise, as no evidence is given as to why a 700m buffer zone to residential properties is relevant and is an entirely arbitrary figure. The noise assessment at Moat Farm is invalid as it is not the nearest property. The noise assessment should be repeated at Trewens Farm. The effects of Vibroacoustic Disease, together with associated dangers to health, have not been addressed. - Holton Village Conservation Area as no photographic evidence has been provided to show that the turbines will not have a visual impact nor affect the view from dwellings in the Conservation Area. - Impact on Listed Buildings. The applicant should be asked to re-visit all 21 properties on its list, and make a determination of the visual impact upon them all, based on winter and summer sightings. In addition a petition signed by 72 people object to the proposal on the grounds of the impact on the landscape, including the AONB, and the skyline within Westhall and surrounding parishes and would degrade the quality of life for residents. Consultees Environmental Health - Environmental Protection No adverse comments. The noise assessment has been undertaken by competent experts in the field of WTG noise assessment in accordance with the most up to date relevant guidance. The results indicate compliance at all times with the relevant limits recommended by the guidance. The report deals with infrasound by pointing out that this was a feature of early designs of turbines with down-wind blades, which caused interference between the aerodynamic noise of the blade 27 and the turbulent wake of supporting column. The turbines proposed for this development (in common with most modern designs I am aware of) are equipped with up-wind blades, eliminating this noise source. I do not regard this as an issue in this case. The report also deals with ground borne vibrations very comprehensively. In short, studies have been undertaken indicating that ground-borne vibration (if any) from wind turbines such as those proposed in this location will be orders of magnitude below the threshold of human perception, even at high wind speeds. I am satisfied there is no possibility of any impact to human health or statutory nuisance from ground-borne vibrations from the turbines proposed under normal operating conditions. Conservation Officer It is very clear that in gently undulating countryside such as within this area, any installation of wind turbines of this height will be visible far and wide and certainly beyond 2km. Although there are a number of historic sites in the area which will be little affected, the turbines will appear here and there in views as one travels about the district. This very significant impact on the historic landscape needs to be carefully weighed against the positives that such an installation will certainly offer. Of the 21 listed buildings within 2km of the nearest turbine 10 are screened or largely screened by topography and/or vegetation, 5 are considered to be moderately affected and 6 major/moderate. Having visited a number of the latter, I can confirm that the impact on these would be severe, due largely to their proximity to the site but also to their orientation backing onto, or side onto, the development site, which would lead to massive intrusion of the turbines within their settings. This is an impact which will affect any similarly orientated building in sight of the turbines, for many miles around. The impact on the nearby conservation area of Holton is described in the environmental statement as being moderate/minor, affecting views of the grade ii* listed church. The impact on Halesworth conservation area has not been assessed as it is outside the 2km zone. There is no doubt that the proposal will have an impact in views from the town from some areas, particularly from the south, but this needs to be quantified in order for a full assessment of impact to be made. English Heritage have drawn attention to the need for some further assessment of impact. Whether this impact proves to be acceptable may depend on whether the turbines are seen as being attractive, as it is clear they will be seen from far and wide. We know that the settings of at least 6 listed buildings will be severely compromised; however this impact may be considered to be acceptable when weighed against the greater good that this proposal offers. Suffolk County - Rights Of Way Turbines 4 and 5 are close to the Rights of Way network and in particular the bridleway. We would recommend these are relocated further away, a distance of 200m as per the British Horse Society guidance. As a minimum we would request that the distance between a wind turbine and the public right of way is the fall over distance of the turbine and the blades should not be permitted to over sail the routes. The amended position of Turbine 4 will meet our minimum desired distance of the turbine from Bridleway 16. County Planning Officer Suffolk County Council does not object to the proposal. It is concluded that due to the overwhelming need for a more sustainable approach to development and the commitment we must make to sourcing renewable energy, this site is considered appropriate for the location of wind turbines, subject to conditions covering decommissioning and landscape restoration, a programme of deliveries for all materials and components, archaeological work and landscape improvements to offset visual intrusion. Comments: Turbine 4 is only 20m from the bridleway and turbine 5 50m away. SCC would therefore like the applicant to investigate whether these could be relocated to increase separation. 28 Advice should be taken from the Environmental Health Officer regarding potential health impacts. Ensuring the turbines rotate in the same direction may alleviate some concerns. SCC recommend that evidence is provided to show that statutorily protected sites and species will not be adversely affected and further recommend that all proposed mitigation measures are enforced. SCC would like the applicant to consider whether there is an opportunity to provide low cost green energy to adjacent development directly. SCC is pleased to see the applicant is prepared to support a community benefit scheme. Suffolk County - Archaeological Unit No objection subject to a condition to ensure that an accurate record is made of any archaeological features or finds. No objection to amended position of turbine 4. Suffolk County - Highways Department The development can be accommodated satisfactorily. In order to minimise impact on the road network a programme of deliveries for all materials and components is requested. Broads Authority The Authority does not wish to raise an objection on landscape grounds. Suffolk Coastal District Council were consulted on the 9 June 2009. Suffolk Coasts And Heaths Project The AONB unit is sympathetic to the development of renewable power installations and are not objecting to the proposal. However we are keen to ensure no negative impact on the AONB from such installations. Concern is raised about the potential for seeing the turbines from the top quarter of the AONB (Kessingland to Dunwich). It is suggested that further visualisations from within the AONB are considered. Following further visualisation work the 11 AONB points now give us the level of information we need to make an informed decision, on behalf of the protected landscape. Whilst there is no doubt that the wind farm will have a widespread visual impact on the AONB and therefore should most definitely be considered as being in the AONB`s setting, the AONB Unit is content that this impact is not significant at any of the locations, other than perhaps Point 6 & 7 Wenhaston, Bicker`s Heath & the A145 at Sotherton, respectively. These locations are however on the very edge of the AONB. As such, the AONB Unit raises no objection to the development proposal. Natural England Natural England has no objection to the proposal. Comments: - Support the conclusion that the turbines and mast will result in a significant change in character of site landscape within about 4km of the site but will not adversely affect the special qualities of the AONB. Recommends further information on the visual impact from the small part of the Ancient Estate Claylands LCT within the AONB designation. - Recommends that Turbine 4 is repositioned further away from the bridleway, preferably 200m. - Recommend a condition for post-construction monitoring of bird and bat impact. Environment Agency – Drainage Recommend a condition for the provision and implementation of pollution control. 29 Civil Aviation Authority There may be a need to install aviation obstruction lighting to some or all of the wind turbines. NATS NATS has no safeguarding objection to the proposal or amended position of turbine 4. Royal Society For The Protection Of Birds The RSPB is supportive of renewable energy projects providing that adverse impacts upon wildlife are avoided by appropriate siting and design. Renewables offer an opportunity to modify or reverse the deleterious changes associated with climate change arising from an over-reliance upon fossil fuels. Whilst the RSPB has no major concerns, we would to see the following improvements undertaken prior to consent being given: - an improved mitigation package for harriers, kestrel and barn owls a comprehensive biodiversity enhancement package to mitigate for and a commitment for on-going monitoring of waders, Barn Owls, raptors and other notable species using the site, both during construction and post-construction. Suffolk Wildlife Trust The nesting season is more appropriately defined as being from the beginning of March to the end of July. We are satisfied with the proposed mitigation and pleased to note the intended post construction monitoring of bird and bat populations. Suffolk Preservation Society - Good application and congratulates the level of detail submitted but criticises the photo montages being taken in summer when winter visibility would be greater with loss of leaf cover, and the type of camera lens used. - Believes the application should be refused for the following reasons: - Visible over a large area and will impact on the AONB and other designated landscapes. - It will adversely affect and impair the setting of many listed buildings and conservation areas. - There is an absence of vertical intrusions in the area, turbines would destroy the special ambience. - Aviation warning lights would inflict the night sky with light pollution. - Noise Go-East were consulted on the 9 June 2009. Renewables East were consulted on the 9 June 2009. Defence Estates No objection. In the interests of air safety, the MOD requests that the turbines are fitted with aviation lighting. All turbines should be fitted with 25 candela omni-directional red lighting at the highest practical point. OFCOM There are currently no fixed link end(s) within fixed link path(s) that cross a 1800m radius coordination area for the proposed turbine location. National Grid With respect to our operational electricity and gas transmissions networks the risk is negligible. British Wind Energy Association were consulted on the 16 June 2009. English Heritage There are a number of listed buildings and scheduled ancient monuments in the surrounding area and conservation areas in Halesworth and Holton. By virtue of their height the turbines would be highly visible within the predominantly flat landscape as is shown in the zone of theoretical 30 visibility. We have concerns that the assessment covers too small an area and does not take into consideration the cumulative impact of the turbines on the cultural heritage. There are a number of designated sites that lie beyond the 2km zone but still in relatively close proximity to the proposed development where all five turbines would be visible. These include the scheduled site at Brookhall Farm, St Peter`s Church and the Huntsman and Hound in Spexhall, Henhamgreen Farm and Church Farm at Sotherton, Blyford Church and Slough Farm, Westhall Grade II*, St. Andrews Church, Wissett and St. Peters Church, Brampton, Grade I, and Halesworth Conservation Area. We recommend the study area is extended to consider the impact on these sites. Sites within 2km of the nearest turbine that should be assessed are St Peter`s Church, Holton and St. Andrew`s Church, Westhall and the setting of Blyford Church, Grade I, across the Blyth Valley. Beacon Farmhouse is listed Grade II* and is situated in open landscape to the north-east of the site. Given the visibility of the turbines in viewpoint 2, just to the west of the farmhouse, we recommend this is properly assessed. There are other vulnerable views within the historic town of Halesworth that we recommend warrant preparation of visualisations. Following receipt of additional visualisations as requested, English Heritage comment as follows: The analysis notes that there would be no impact on two of the sites, a moderate/minor impact on five and a moderate impact on a further four. The analysis records that the turbines would be visible to varying extents at all the sites except where no impact is identified. The visualisations are annotated to note the extent of the proposed turbine view; however the turbines themselves have not been depicted. This makes it difficult to gauge the precise relationship of the turbines to the sites and to assess their impact. An understanding of the relationship between the two in principle views, such as at the entrance to and within the churchyard at Westhall, would enable your authority to assess whether there are any unfortunate juxtapositions which would compromise the settings of the buildings, for example a turbine seeming to rise from the church tower. We recommend your authority requests these visualisations in relation to the churches at Blyford and Westhall. This would enable the juxtaposition of the turbines and the churches to be considered and, if necessary, to mitigate the impact by omitting or relocating individual turbines. Spexhall Parish Council - It would be better if the turbines were off-shore - Some of the properties in the parish would be adversely affected by the line of sight and possible noise. This will have an effect on the value of properties. Other observations: Should permission be granted, we feel the number of turbines on this site should be restricted to 5. Halesworth Town Council Support in principle subject to minimisation of impact on surrounding villages Other observations: Councillors note this issue is the concern of the surrounding villagers. Westhall Parish Council The Parish Council recommend refusal of planning permission on the following points. - It is noted that on the Bernard Matthews site plan and map of the area adjacent to Holton airfield they have omitted to show Westhall Village as a whole and their application only refers to “Mill Common” which is only a part of Westhall that will be affected. All these turbines will be within the parish boundary of Westhall. - The turbines will have a huge impact on all areas of the village, both visually and with noise. On reference to BM noise monitoring exercise the one comment that is constant is that all you can hear is bird song (no noise). These turbines will affect the quality of life of all residents and especially those living closest to the turbine. There are a number of Listed Buildings within Westhall governed by rules to maintain such buildings, the wind turbines will impact on their assessment as a listed building and as such destroy the history of the 31 - - - - surrounding area and landscape. Westhall Church is considered the second best example of its kind in Suffolk and the wind farm will impact on its image. There are health issues in that turbines also produce a low frequency thump which affects the young and the elderly and can cause cardio logical problems; this has been researched by the French National Academy of Medicine and the Portuguese National Centre for Occupational Diseases. Stress induced illness will be caused by lack of sleep due to noise when generating at night. The flicker caused by the blades has been known to affect people who suffer with migraine or epilepsy. There are Rights of Way issues in that some of the turbines are too close to bridleways and footpaths and as such do not comply with the legal requirements to ensure the safety of horse riders and walkers. There is no RISK ASSESSMENT document, just a constant mention of in line with government guidelines. The factory itself will be less than 700m from the turbines. The turbines will be a hazard to military aircraft that regularly carry out training exercises in the area. Both the MOD and CAA have admitted there will be a problem should wind farms be erected in the area. The planning application goes against WDC Local Development Core Strategy Document in which it states that the peace and tranquillity of the countryside will be protected. We are aware that to prevent global warming and carbon emissions it is necessary to employ other means of generation as the world is dependant upon a constant supply of electricity; but this should not be to the detriment of our quality of life, in particular the residents of Westhall Parish. The Parish Council reiterates its objection in respect of the amended position of Turbine 4. Waveney Byway and Bridleway Association I cannot understand why they have sited turbines 4 and 5 in the vicinity of a public right of way. Therefore I object on safety grounds. It is essential that horses and riders are encouraged to use public bridleways to get them off increasingly dangerous roads. They do not need another hazard on what should be an enjoyable route. PUBLICITY The application has been the subject of the following press advertisement: Category Published Expiry Publication Major Application, 12.06.2009 02.07.2009 Lowestoft Journal Public Right of Way Affected, Environmental Impact Assessment, Environmental Impact Assessment, 12.06.2009 02.07.2009 Eastern Daily Press Environmental Impact Assessment, 12.06.2009 02.07.2009 East Anglian Times Major Application, Public Right of Way Affected, Environmental Impact Assessment, 12.06.2009 02.07.2009 Beccles Journal and Daily Bungay 32 SITE NOTICES The following site notices have been displayed: WDC General Site Notice Reason for site notice: Environmental Impact Assessment, Major Application, In the Vicinity of Public Right of Way, Potential Public Interest, Date posted 11.06.2009 Expiry date 01.07.2009 PLANNING POLICY The UK Government, as a signatory to the Climate Convention, is actively seeking to achieve its commitments under the Kyoto Protocol to reduce its greenhouse gas emissions by 12.5% below 1990 levels by 2012. In the Climate Change Bill 2007 the Government has set a target of reducing CO2 emissions by 60% by 2050. To contribute to this reduction, 10% of all production should be from renewable sources by 2015 and 20% by 2020. Running alongside this, suppliers of electricity are required to provide 15% of the supply by 2015 from renewable sources. The East of England Plan (see below) has set a target of 10% consumption from renewables by 2010 (with an additional 4% from offshore) rising to 17% by 2020 (with a total of 44% to include offshore). Operationally, there is 2.75MW of installed capacity of onshore wind (Ness Point, Lowestoft). There are three further consented onshore wind projects in Suffolk at Parham Airfield (7.8MW), Kessingland (6MW) and Harrods (0.225MW). The total onshore wind capacity in Suffolk is therefore 16.78MW. PPS1 – Delivering Sustainable Development PPS1 sets down the Governments commitment to ensuring new development is sustainable. Key principles include the reduction of energy use and emissions and protection and enhancement of the natural and historic environment. The supplement to PPS1 (Planning and Climate Change) recognises that climate change represents a potentially catastrophic threat that must be addressed. The Government believes that climate change is the greatest long-term challenge facing the world today and that addressing it is the principal concern for sustainable development. PPS7 – aims to promote more sustainable patterns of development by protecting the countryside for the sake of its intrinsic character and beauty, the diversity of its landscape, heritage and wildlife, the wealth of its natural resources and so it may be enjoyed by all. It advises that, in determining planning applications, authorities should provide for the sensitive exploitation of renewable energy sources in accordance with the policies set out in PPS22. PPS9 – sets out the Governments objectives for nature conservation. PPG15 – provides guidance in respect of development which will affect the historic and built environment. PPS22 – Renewable Energy PPS22 and its Companion Guide contains the Government`s national planning policy advice relating to renewable energy projects. PPS22 confirms that increased development of renewable energy sources is vital to facilitating the delivery of the Governments commitments on both climate change and renewable energy. These include a target of generating 10% of UK electricity from renewable energy sources by 2010 and 20% by 2020, and the suggestion that still more renewable energy will be needed beyond that date. Key principles of PPS22 include: Renewable energy developments should be capable of being accommodated throughout England in locations where technology is viable and environmental, economic and social impacts can be addressed satisfactorily. The wider environmental and economic benefits of all proposals for renewable energy projects, whatever their scale, are material considerations that should be given significant weight in determining whether proposals should be granted planning permission. 33 Small-scale projects can provide a limited but valuable contribution to overall outputs of renewable energy to meeting energy needs both locally and nationally. Planning authorities should not therefore reject planning applications simply because the level of output is small. Development proposals should demonstrate any environmental, economic and social benefits as well as how any environmental and social impacts have been minimised through careful consideration of location, scale, design and other measures. The Companion Guide sets out information on wind turbines. It sets out that the principle of harnessing wind energy by wind turbines is well established and that wind turbines make a significant contribution to electricity supply in Europe and the UK. The Guide sets out a number of issues specific to developments of this type that need to be considered when determining an application for planning permission including noise, landscape and visual impact, listed buildings and conservation areas, safety, proximity to roads and public rights of way, ecology, archaeology, electromagnetic interference, shadow flicker and constructional and operational disturbance. PPG24 – Planning and Noise States that noise can be a material consideration in the determination of planning applications. Development should not cause an unacceptable degree of disturbance. ENG2 - East of England Plan Policy ENG2 states that the development of new facilities for renewable power generation should be supported, with the aim that by 2010 10% of the regions energy and by 2020 17% of the regions energy should come from renewable sources. These targets exclude energy from off shore wind, and are subject to meeting European and international obligations to protect wildlife, including migratory birds. Based on these estimates of energy consumption these targets equate to the following targets for installed capacity: - at least 1192 Megawatts by 2010 (820 MW excluding offshore wind); and - at least 4250 Megawatts by 2020 (1620 MW excluding offshore wind. Core Strategy – January 2009 One of the key sustainability issues in the Core Strategy (adopted January 2009) is climate change and a recognition that there is a need to increase the use of energy from renewable resources. It acknowledges that there may be isolated locations where less sensitive landscapes accommodate onshore wind turbines. Policy CS16 on the natural environment states that proposals for development are expected to retain and add to local distinctiveness, retain tranquillity, avoid fragmentation of habitats and seek to enhance wildlife corridors and networks. In addition, proposals should conserve and contribute towards the enhancement of landscape character, biodiversity and geodiversity of the District. The proposed development should not have an adverse impact on a number of sites including the visual setting of the Norfolk and Suffolk Broads, habitats and species in the Suffolk Biodiversity Action Plan and locally recognised sites of biodiversity and geodiversity importance, including County Wildlife Sites and Local Nature Reserves. Policy CS17 aims to protect and enhance the built and historic environment. Proposals for development are expected to conserve or enhance the character and setting of conservation areas, listed buildings, scheduled ancient monuments sites of archaeological interest and their settings and the local distinctiveness of existing non-designated built environments. Waveney Local Plan: Policy ENV1 - Areas of Outstanding Natural Beauty and Heritage Coast States that proposals for development which would have a material adverse impact on the landscape will not be permitted unless it can be demonstrated that there is an overriding national need. Policy ENV20 – Conservation Areas Aims to protect the character of conservation areas. 34 Policy ENV23 – Listed Buildings Aims to protect the character and setting of Listed Buildings. Policy DC1 – Waveney Interim Local Plan Aims to protect residential amenity. PLANNING CONSIDERATIONS A members site visit was held on 31st July 2009 and members visited existing wind turbines at Swaffham and north Pickenham on 6th August 2009. Minutes of these meetings are attached. The main issues to take into account in the determination of this application are: - Planning policies - Landscape/visual impact - Impact on wildlife and ecology - Impact on the surrounding historic built environment - Noise - Shadow effect and residential amenity - Electromagnetic interference - Traffic and transportation - Footpaths and bridleways Planning Policy Relevant planning policies are set out above. PPS22 sets out the national planning policy advice relating to renewable energy and sets out targets for generation electricity from renewable energy sources. PPS22 recognises that of all renewable technologies wind turbines are likely to have the greatest visual and landscape effects. However, the impact of turbines on the landscape will vary according to the size and number of turbines proposed and the type of landscape involved, and these impacts may be temporary if conditions are attached to planning permissions which require the future de-commissioning of the turbines. It is clear that the Government has a strong commitment towards renewable energy and that the development of renewable energy resources, including the erection of on-shore wind turbines, is an important element in facilitating this commitment. The impact of the proposal on the local environment has to be balanced against the supportive nature of these policies and the wider environmental benefits of this proposal. The question that needs to be answered is whether the impacts that would result from the proposal are so great to warrant refusal having regard to the national policy position. Landscape/Visual Impact The ES accompanying the application states that a landscape and visual assessment was undertaken to assess potential effects of the proposal on the landscape character and the visual amenity of the locality over a 15 km radius study area. A total of 15 viewpoints were selected to be representative of the main views of the site and photomontages and wireframes are used to illustrate predicted views. A Zone of Theoretical Visibility (ZTV) has also been created which indicates the areas where topography may permit views of the turbines. The ZTV illustrates that the turbines would potentially be visible from much of the study area. However the results of screening effects of vegetation and built structures would greatly fragment and reduce actual visibility. The viewpoint analysis identifies 4 villages where there would be limited views from some properties. However, apart from Stoven, no significant change in view for residents would occur due to the partial visibility of the turbines. Turbines would also be visible from properties in Cox Common and Mill Common and Bacons Green Road where there would also be a significant change in view. Some residents within parts of Halesworth with clear views of the turbines would experience a significant change in their visual amenity. Beyond 4.5 km from the site the ES considers that there would be no significant change in views. 35 There are 16 individual properties within 1km of the nearest turbine. The ZTVs suggests that the hubs and tips of the proposed turbines would be visible from each of these properties. Due to the proximity of the of the proposed windfarm to these properties this would result in a significant change in view for these residents. However, it is unlikely that a wind farm proposal in any location would not result in some significant effects on landscape character and visual amenity of the immediate locality. However, it is considered that significant effects are not necessarily unacceptably adverse. For the closest residential properties parts of the turbines will be clearly visible, although the degree of visibility and effect on visual amenity will vary with the time of day and year, different weather conditions, lighting and visibility conditions and different wind directions resulting in the changing orientation of the blades. The closest point of the Suffolk Coast and Heaths AONB is approximately 3.2km from the site. It is not anticipated that the proposed development would have any significant change in landscape character beyond 4km and there are only limited views of the site from within the AONB. Most of these views would be beyond 6km from the proposed turbines from only a small part of the AONB. At its closest point the Broads National Park will be over 9.4km from the nearest proposed turbine. At this distance the ES states that the proposal would not bring about a significant change in the character of the Park. The Special Landscape Area is a local landscape designation located approximately 2.3km south of the nearest proposed turbine. It is not considered that the proposal would have any significantly adverse impacts on the character or appearance of the SLA designation. The ES states that for users of A Class roads there would generally be no significant change of view except for those motorists using the route between Halesworth and Stone Street. On B Class roads the main views of the turbines would occur along the parts of the B1124 and B1123. Users of footpaths and bridleways close to the proposal would experience a significant effect on their visual amenity due to the proximity of the proposed turbines. The definitive route of Bridleway 16 is closer to turbine 4 than the actual route on the ground. There is no statutory distance of separation between a wind turbine and a public right of way. However the PPS22 companion guide indicates that “fall over distance is considered an acceptable separation, and the minimum distance is often to be taken to be that the turbine blades should not be permitted to oversail a public right of way”. An amended plan has been submitted relocating turbine 4 to ensure its blades do not oversail the definitive route of the bridleway. Suffolk County Council Rights of Way raise no objection to the amended position of turbine 4. The ES acknowledges that it is unlikely that a proposal to site a new wind energy development in the UK would not result in some significant effects on the landscape character and visual amenity of the immediate locality. However, significant effects are not necessarily unacceptably adverse. Whilst the proposal would become a defining characteristic of the landscape of the site and immediate locality, wind turbines are a relatively recent addition to our environment and there is no consensus of opinion on the most appropriate types of landscape in which to site the various scales of wind energy development. The five proposed wind turbines will become a defining characteristic of the landscape of the site and local area within 3.5-4km of the nearest turbine. It is considered that any proposed wind farm, by its very nature, will inevitably have some impact on landscape and visual amenity. However these effects have to be balanced against the Governments firm commitment to renewable energy generation. National, regional and local planning policies, whilst recognising the value of local landscapes, primarily seek to protect those landscapes designated for their national importance, including National Parks and AONB`s. The site does not lie within a National Park and the AONB is some 3.2km away at its nearest point. It is worth noting that the two 125m high wind turbines at Africa Alive, Kessingland were only some 200m from the AONB boundary but nevertheless allowed by the Appeal Inspector. Should consent be granted conditions could ensure the colour of the turbines is a white colour and that there is no advertising upon them. 36 Ecology The ES assesses the potential impacts of the proposal on ecological receptors comprising ecological habitats, flora and fauna, including birds. Detailed surveys were undertaken for breeding and wintering/migratory birds, bats, reptiles and amphibians (including great crested newts), badgers and habitats (including plant species). A number of species protected by legislation were found to be present on the site, namely Schedule 1 (high concern) bird species, bat species, grass snake and great crested newt. Impacts on the various species were considered, with potentially significant pre-mitigation impacts identified. Therefore mitigation measures to avoid adverse impacts are proposed and can be conditioned. These measures include mitigation during construction to avoid nesting farmland birds and disturbance to important species. Proposed enhancements include restoration of the pond in the south of the site to improve its reptile and amphibian habitat and an ongoing management plan for the semi-improved grassland and ponds on the site. It is proposed that existing farming activities would continue up to the wind turbine foundations and hardstandings. It is considered that no significant issues of concern on biodiversity issues have been raised to warrant a refusal of planning permission. Natural England raise no objection to the application. Natural England recommend that turbine 4 is re-positioned further away from the adjacent bridleway, preferably a distance of 200m as recommended by the British Horse Society. As mentioned above it is proposed to ensure that turbine 4 will not oversail the bridleway but that there is no statutory distance of separation. Therefore it is considered that there is insufficient justification to require a 200m separation. Natural England also request that comments made by Suffolk Coast and Heaths AONB for additional visualisation work are taken into account. Natural England support the proposed mitigation measures for farmland breeding birds, kestrel, brown hare reptiles and great crested newts and also recommends post-construction monitoring of bird and bat impacts. If the proposal is considered acceptable these issues can be covered adequately by conditions. Impact on the surrounding historic built environment The applicant has undertaken extensive assessment of the proposal on the historic environment. The ES accompanying the application assesses the indirect visual impact of the proposal on scheduled monuments, conservation areas, listed buildings within 2km of the nearest proposed turbine. The potential effects on the wider historic landscape are also assessed. There are 21 Grade I, II* and II listed buildings within 2km of the nearest proposed turbine. None of these buildings fall outside the ZTV and therefore all have been assessed. It was found that 10 listed buildings are screened or largely screened by topography and/or vegetation such that the proposed turbines would not affect key views from or of them. Of the remaining 11 the ES considers that the predicted effect of the proposed turbines on 6 of them would be major/moderate, which would be significant. The 6 listed buildings in question are Moat Farmhouse, Laurels Farmhouse, Pastures Farmhouse, White House Farmhouse and its associated barn and Red Barton. However a significant effect is not necessarily adverse. In each case the Assessment of Effects states that only parts of some of the turbines/rotor sweeps will be visible when viewing the buildings. None of them were considered to have important views from or of them and the proposed turbines were not adjacent to them or within the immediate or wider setting and so would not result in visual dominance when considering the listed building and its setting. Holton Conservation Area is located 1.8km south of the nearest proposed turbine. The ES states that the turbines would not be adjacent to the Conservation Area or within the immediate or wider setting and therefore would not be visually dominant. 37 There is only one Scheduled Monument, Moat Yards, within 2km of the nearest proposed turbine. It is situated 1.3km north and the ES states that the proposed turbines would be clearly visible in views from just beyond the vegetation surrounding the moat, looking south. However the ES states that the proposed turbines would not result in visual dominance and therefore the predicted effect is moderate which would not be significant. It is clear from the consultation response above that English Heritage are not objecting to this proposal. However in response to their comments the applicant undertook additional survey work and visualisations in respect of all 11 listed buildings referred to, including 9 that lie beyond 2km from the proposed turbines, and Halesworth Conservation Area (which also lies more than 2km from the site). English Heritage notes that the additional analysis shows no impact on 2 of the listed buildings, a minor/moderate impact on 5 and a moderate impact on 4. On this basis English Heritage do not raise any objection although it is recommended that further assessment is undertaken in respect of the churches at Blyford and Westhall. However, after detailed consideration of the comprehensive assessments submitted in the initial ES and further assessments undertaken, together with visits to each of the sites, it is considered that further assessment of these two churches is not warranted. A detailed assessment of Westhall church is provided in the ES which shows there is potential for partial visibility of 1 or 2 turbine hub and blades obliquely from the church entrance in winter months and partial visibility of all 5 turbines from limited parts of the churchyard, resulting in a moderate effect that would not be significant. Whilst it is agreed that a slight change to the understanding and appreciation of the church would occur as a result of the proposed turbines it is considered that the extent of mature and dense tree cover surrounding the churchyard is such that the impact on it would not be unduly harmful. Blyford church has also been assessed in detail both in the original ES and in the further analysis and found generally not to be visible in the wider landscape, except from the B1123 where the turbines would be seen as separate to the church and its wider setting. It is agreed that from the church itself and immediate setting, the proposed turbines would be visible from only a very limited section of the churchyard and that these views would be limited by rising intervening farmland. Accordingly it is considered that the impact on the church would not be significant and that further assessment is not required. The additional information also includes a cumulative impact assessment on the historic environment as a whole as requested by English Heritage. By combining the Scheduled Monuments, Listed Buildings and Conservation Areas the following can be summarised: i) ii) iii) no significant effects predicted on the settings of two Scheduled Monuments out of 29 listed buildings assessed a significant effect predicted on 6, each of which is located approximately 1.2km of the nearest proposed turbine No significant effect predicted on either Holton or Halesworth Conservation Areas. Whilst it is accepted that the proposed windfarm will have some impact on the setting of some listed buildings the issue to address is whether the impact undermines the special characteristics of the reasons for the building being listed. Of the 6 listed buildings where the predicted effect is considered in the ES to be significant, it is considered important to note that, in each case, there would only be a moderate change to the understanding and appreciation of the building and its setting. With the distances involved, the topography of the area and existing vegetation parts of turbines and blades may well be seen from a number of listed buildings however their listing status will not be significantly affected by the proposed development. Furthermore it is considered that any impact that does result will be temporary given that the windfarm, if approved, would remain for no more than 25 years as any consent would be subject to decommissioning which would require the removal of the turbines. It is therefore considered that any limited impact upon listed buildings is outweighed by the wider environmental benefits (including climate change) that will be delivered by the proposed development. 38 Noise Local residents have raised concerns about the noise implications and health concerns (in particular vibroacoustic disease and wind turbine syndrome) in respect of the proposed development. The ES includes an assessment of the potential noise impact based guidance as set out in ETSU-R-97. This method of noise assessment is in accordance with guidance in PPS22. The assessment indicates that baseline noise measurements were taken at six locations representative of the nearest residential properties to the site. Predictions of wind turbine noise were made based upon a warranted sound power level data for Enercon E70 2.3 mw wind turbines. The assessment shows that the predicted noise levels meet the fixed night time limit and lower day time limit described in ETSU-R-97, under all conditions. Concern has been raised by some respondents about vibrations from wind turbines and the effect this can have on health. The PPS22 Companion Guide states that there is no evidence that ground transmitted low frequency noise from wind turbines is at a level to be harmful to human health. A study of low frequency noise and vibration around a modern wind farm was carried out by ETSU which found that vibration from wind turbines, as measured from 100m from the nearest machine, was well below criteria for human exposure in critical working areas such as precision laboratories. At greater distances from wind turbines vibration levels will be even lower. The Councils Environmental Health Officer raises no objection and notes that the noise assessment has been undertaken by competent experts and in accordance with the most up to date relevant guidance. It is therefore considered that the proposal complies with the relevant guidance and an objection on noise/vibration grounds could not be justified. Appropriate conditions could be applied to any grant of planning permission to ensure noise limits remain within recommended guidelines. Shadow Flicker When the sun is specifically positioned with respect to a wind turbine or moving blade and the window of a neighbouring property a shadow may be cast on the window. A shadow flicker assessment was undertaken which identified 3 properties with the potential to experience shadow flicker. The assessment has determined that shadows may be cast on the identified properties for a maximum of 59 days a year and for no more than 27 minutes on any one day. The ES states that the wind farm control system can be programmed to switch off the turbine during the times of potential effect whenever the conditions for shadow flicker exist. It is therefore considered that any issues in respect of shadow flicker and residential amenity can be adequately mitigated against by an appropriate condition should consent be granted. Traffic and Transportation The ES gives consideration to access to the site and impact on the surrounding highway infrastructure. It indicates that abnormal load vehicles will approach the site from the north along the A144 and then Sparrowhawk Road and Butts Road to the site entrance. The total construction period is estimated to be nine months with the most significant traffic volumes occurring during the first four months with the most significant vehicular movement in any one day being associated with the delivery of concrete for the turbine foundations. Each of the foundations will require approximately 33 deliveries in one day, therefore there will be five days when peak traffic volume will occur. With respect to turbine components there would be a total of 110 traffic movements. During construction and decommissioning movements of exceptional loads will be restricted, wherever possible to off-peak times to minimise disruption on the road network. It is considered that traffic generated by the proposal will be restricted to a relatively short period and can be adequately accommodated within the highway network. As noted above the Highway Authority raise no objections to the proposal. Proximity to Public Footpath/Bridleway As will be noted above a public footpath/bridleway runs to the south of the proposed windfarm and some objectors raise concern about the close proximity, particularly of turbines 4 and 5. On this issue PPS22 Companion Guide states that the minimum distance is often taken to be that the turbine blades should not be permitted to oversail a public right of way. In the case of the proposed 39 windfarm this equates to a blade length of 35.5m. Turbine 4 has been relocated 56m north of the actual route of the public right of way on the ground (and 35.5m of the definitive route) and turbine 5 is positioned 41m west of it. With regards to safety PPS22 Companion Guide notes that experience indicates that wind turbines are a safe technology and that there has been no example of injury to a member of the public. The British Horse Society`s recommended separation distance (200m) is non-statutory. Turbines 4 and 5 exceed the minimum required oversail distance and therefore it is considered that an objection on these grounds could not be justified. Terrestrial Television Reception Terrestrial television reception can be affected by turbine towers and the movement of the blades. The ES states that 156 houses have been identified that may suffer interference to television reception although it is not possible to accurately predict the exact number until all five turbines are erected. To mitigate against any adverse effect the developer proposes to undertake a preconstruction terrestrial television survey. Any dwellings that do experience interference as a result of the proposed development would be visited by a qualified engineer to resolve the issue. Conclusion The application raises many issues and has divided opinion both from the public and the various consultees. The positioning of wind turbines in the open countryside has predictable and well documented impacts, many of which are raised in this report. In determining this application Members will need to balance up several conflicting issues. The balance to be struck between the supportive nature of national, regional and local policies and the impact of the five proposed turbines on the character of the wider countryside and the associated visual impacts represents the biggest issue to address. Central government is clearly supportive of renewable energy developments. It recognises that tackling climate change and reducing greenhouse gasses is one of the biggest challenges ever faced and one that cannot be ignored. PPS22 sets out the key principle that renewable energy development should be capable of being accommodated throughout England in locations where the technology is viable and environmental and social impacts can be satisfactorily addressed. Opinions on wind turbines in the landscape are very subjective, leading to a wide range of views from the very negative to the very positive. The key material planning considerations which need to be balanced against this policy context are the impact of the proposed turbines on the surrounding landscape, listed buildings in the locality and residential amenity. Wind turbines, by their very nature are modern industrial features that are atypical of Waveney Districts landscape. The issue of impact of the proposal on the wider landscape has been made by the majority of objectors. In determining the application Members need to address the significance of these impacts. Whilst the impacts are widely recognised it is a matter of judgement whether they are of sufficient nature to justify refusal of the application. It is suggested that significant weight is given to the following factors: 1. the application proposes the retention of the turbines for a period of 25 years and on proposed decommissioning of the site the visual effects will be reversed, therefore there will be little permanent impact on the wider landscape. Technological advancements are such that there is every possibility that electricity will be generated in many different ways over the time period. 2. The application site does not fall within any national landscape designation type. The Suffolk Coast and Heaths AONB (approximately 4km to the east of the site) is the nearest such designation. 3. There is no overall agreed position on the significance of the impact of the proposed turbines on the wider landscape. 4. The design and positioning of the proposed turbines will mitigate some of the impacts 40 On this basis and whilst recognising the nature of consultee responses and the level of local objection it is considered that on balance greater weight should be afforded to national and regional planning policies in respect of the generation of renewable energy. The five proposed turbines would generate up to 24200 MWh of electricity per year, equivalent of the energy requirements of some 5140 dwellings. This is a significant contribution that would offset up to 20,800 tonnes of carbon dioxide each year. Having taken detailed account of the varied issues it is considered that the various impacts are not sufficient to warrant refusal of the application. Therefore it is considered that, on balance, the proposal should be approved. The application is well detailed and the proposal accords with national and regional policy and will generate a substantial amount of electricity from a renewable source in accordance with the wider government agenda. Whilst there will be particular local impacts in an area of surrounding countryside, these impacts are not considered to be so significant as to warrant refusal of planning permission. Subject to appropriate conditions the impact of the proposal can be mitigated to a satisfactory extent. RECOMMENDATION APPROVE subject to conditions covering: time limit of 25 years and notification to local planning authority of first generation of electricity, amended position of turbine 4, height of the wind turbine system and blade length, submission of construction management plan, removal of any turbines that fail to produce electricity for a continuous period of 12 months, mitigation measures for farmland breeding birds, kestrel, brown hare, reptiles and great crested newts, post construction monitoring of bird and bat impacts, alleviation of shadow flicker, alleviation of electromagnetic interference, archaeology, details of the design, colour and specification of the turbines, no logo or adverts to be displayed, noise emissions, noise measurement protocol, aviation lighting, hours of operation of construction phase, no external lighting, all blades to rotate in the same direction, decommissioning programme and landscape restoration, details of materials and component delivery. BACKGROUND PAPERS CONTACT Case File DC/09/0491/FUL held in Planning Office, Customer Service Centre, The Marina, Lowestoft Phil Perkin, Principal Planning Officer, 01502 523073 41 Minutes of a site meeting held on Friday, 31 July 2009 at 10.00am Members present: J Groom (Chairman), S Allen, G Elliott, P Flegg and M Ryland Appendix A Officers present: R Cox (Committee Officer), P Perkin (Principal Planning Officer) and A Reynolds (Principal Environmental Health Officer) Others: Phil Richmond (Bernard Matthews Project Manager), Johny Rankin (Agent), Representatives From Westhall, Holton and Spexhall Parish Councils and Mr Simpson-James (Resident/Objector) DC/09/0491/FUL – INSTALLATION OF 5 WIND TURBINES; LAND AT FORMER AIRFIELD UPPER HOLTON, HALESWORTH The Chairman welcomed Members to the site meeting. He reminded them that the visit was a fact finding one and that any decision would be made at a future meeting of the Committee. Phil Perkin, Principal Planning Officer outlined the proposal. He explained that each turbine would be 64 metres high to the hub of the turbine, the maximum height to the tip of the blade would be 100 metres. The turbine would generate sufficient electricity for 5,000 houses for a year via the national grid. The site for the proposed wind turbines was not within a national designated area and the proposal was in line with the Government guidelines in reducing the carbon footprint. An Environmental Statement/Assessment had been produced which detailed any listed buildings in the area, which could be affected by the proposal. The Project Manager confirmed that this particular site was one of three that had been investigated. He confirmed that each turbines output would be 28% at full capacity. The site visit moved around to several different locations within the village to gauge the potential impact from different points surrounding the site. Parish Councillors expressed serious concern about the size of the turbines and the visual impact on the surrounding area. Also Members were informed that day-to-day operations on site could be heard from neighbouring properties some distance away. The meeting was concluded at 11.25pm Chairman 42 Minutes of a site meeting held on Thursday, 6 August 2009 at 9.00am Members present: J Groom (Chairman), S Allen, P Ashdown, M Cherry, G Elliott, P Flegg, I Graham, S Keller, P Light and M Ryland Officers present: R Cox (Committee Officer), P Perkin (Principal Planning Officer) and A Reynolds (Principal Environmental Health Officer) WIND TURBINES SITE VISIT TO SWAFFHAM AND NORTH PICKENHAM WIND FARM, NORFOLK The Chairman welcomed Members to the site meeting. Firstly Members visited the EcoTech Visitor Centre at Swaffham and viewed the 100 metre high wind turbine. The Manager of the Eco Tech Centre gave Members some vital statistics of the turbine. Unfortunately the turbine was having essential maintenance undertaken and as a result no tours up the turbine were running. Prior to the site visit a national paper had printed an article on people suffering from health problems as a result of living near wind turbines, particularly from low frequency components of the noise they generate. Members asked for clarification of the arguments advanced in the article and how it should influence their thinking on the subject. Andrew Reynolds explained that there were various sources of noise from wind turbines and several conflicting opinions circulating about the effects and likelihood of each type of noise. Research into these phenomena was being undertaken across the world and the newspaper article seemed to be based at least in part, on some of the recent research being carried out in Portugal. He explained that the current government guidance on the subject was “Planning Policy Statement 22 - Renewable Energy” (published by the Office of the Deputy Prime Minister). This in turn refers to a document entitled “The Assessment and rating of Noise from Wind farms” (also referred to as ETSU-R-97) which sets out in detail the methodology which should be followed in cases like this. Any other research and any articles and objections based on it, is interesting, but we would need compelling reasons to depart from the statutory guidance. The applicant’s Environmental Impact Assessment had been compiled by an acoustic consultant who were recognised experts in the field of wind turbine noise assessment and they had specifically addressed the issues of low frequency noise and vibration from the proposed development. As a result, there were no reasons to set aside the assessment methodology set out in ETSU-R-97 and therefore, no reasons to disagree from the overall conclusions presented by the applicant’s Environmental Impact Assessment. Members then visited the North Pickenham wind farm. The meeting was concluded at 13.15pm Chairman 43